View source for BECO-92-126, Application for Amend to License DPR-35,revising TS Sections 1.0,4.3,4.4,4.5,4.6,4.7 & Associated Bases to Conform SRs for ASME Code Class 1,2 & 3 Pumps & Valves to IST Program, Per 10CFR50.55a(g)(5)(ii)

{{Adams
| number = ML20106E172
| issue date = 10/30/1992
| title = Application for Amend to License DPR-35,revising TS Sections 1.0,4.3,4.4,4.5,4.6,4.7 & Associated Bases to Conform SRs for ASME Code Class 1,2 & 3 Pumps & Valves to IST Program, Per 10CFR50.55a(g)(5)(ii)
| author name = Anderson R
| author affiliation = BOSTON EDISON CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000293
| license number = 
| contact person = 
| document report number = BECO-92-126, NUDOCS 9211060177
| package number = ML20106E175
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 11
| project = 
| stage = Request
}}

=Text=
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r.t 10CfR50.90 BOSTON EDISON Ngnm Nuclear Pow Suten flody Hdi Road hvmoutn. Massachusetts 02360 Roy A. Anderson Senior Vice Pfetident - Nucleaf October 30, 1992 BECo 92-126               -
V. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555                                                                                                    _
License DPR-35 Docket 50-293 Proposed Change to Technical Specification Sections 1.0, 4. L 4.4.,_4.5. 4.6. 4.7 and Associated Baie.Ji Boston Edison Company proposes the attached cnange to Appendix A of Operating License No. DPR-35 in accordance with 10CFR50.90. Boston Edison considers that this change brings the Piigrim Nuclear Power Station (PNPS) Technical Specifications into confermance with the Inservice Test (IST) Program.
The change creates a new section in the Technical Spe;ifications to specify limiting conditions of operation and surveillance requirements for inservice                                            ,
code testing. The change also incorporates ti. term " Refueling Interval" in the definitions to specify the interval between designated ASME Code Section XI surveillances and revises the definition of surveillance interval to allow the 25% tolerance to be applied to the refueling interval period of twenty four months. Other changes have been made to provide consistency by requiring quarterly testing to be performed in accordance with the PNPS IST program.
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9211060177 921030 PDR     ADOCK 05000293 P                    PDR

BOSTON EDISON COMPANY U. S. Nuclear "egulatory Commission Page 2 This change provides consistency by performing testing to a single test program and increases component availability by reducing unnecessary testing and wear on components.
These changes are being submitted as required by 10CFR50.55(a)(f)(5)(ii).
B/s          x R. A. Anderson Commonwealth of Massachusetts)
County of Plymouth)
Then personally appeared before me, Roy A. Anderson, who being duly sworn, did state that he is Senior Vice President - Nuclear of Boston Edison Company and                                           7 that he is duly authorized to execute and file the submittal contained herein in the name and on behalf of Boston Edison Company and that the statements in said submittal are true to the best of his knowledge and belief.
My commission expires: Ocde4t# 4 ffff" DATE 1(PUP IC [bu CNOTARY BRS/cic/ts cc: See Page 2 Attachments:      (A) Description of Change (B) Revised Technical Specification Pages (C) Marked-Up Pages from Current Technical Specifications cc:   M. R. Eaton, Project Manager                                              Mr. Robert Hallisey, Director Division of Reactor Projects - I/II                                        Radiation Control Program Office of Nuclear Reactor Regulation                                       Mass Dept. of Public Health Mail Stop: 1401                                                            305 South Street U. S. Nuclear Regulatory Commission                                        Jamaica Plain, MA 02130 1 White Flint North 11555 Rockville Pike Rockville, MD 20852 U. S. Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 Senior NRC Resident Inspector                                                                                     l Piig-im Nuclear Power Station                                                                                     l

  . ~_    _ ..._ _ . _ _ ._             _ _.-....- _ _                    _ _        _  _ .____._ _      -_
ATTACHMENT A Changes are proposed to Pilgrim Operating Licenst No. DPR-35 Sections 1.0, 4.3, 4.4, 4.5, 4.6, 4./ and their associated Bases. Also a new section is being added ta-specify the requirements for Inservice Code Testing.
Surveillance Requirements for testing of ASME Code Class 1, 2 and 3 or equivalent pumps and valves are being revised to perform testing in accordance                      -
with the PNPS IST Program. The proposed change adds the tern REFUELING INTERVAL to the definitions and revises the term SURVEILLANCE-INTERVAL to.
allow the 25% schedule tolerance to be applied to the REFUELING INTERVAL. test period. The change also adds Section 3.13 to the Technical Specifications to specify Limiting Conditions of Operation and Surveillance Requirements for Inservice Code Testing.
The specific changes are identified by change bars in the margins of the affected pages in Attachmer.t B and the marked-up current Technical Specification pages in Attachment C. To minimize the impact of the changeLon existing plant procedures the existing format was used where possible.
The following sections and pages are affected by this change:
Sectiqn                                       Paae 1.0                                           4, 5a 4.3.G                                         85                                .
4.4.A                                         95, 96                            6 4.5.A                                          103, 104 4.5.B                                          106 4.5.C                                          107 4.5.0                                          108 4.6.0                                          126 4.7.A                                          155a, 156, 157 The following section and pages are being added:
Sectinn                                       Paae                              :
3/4.13-                                       2059 , 205h, 205i Reason for-Chanae:
1       The Technical Specifications are being revised to conform the surveillance                          -
l       requirements for-ASME Code Class 1, 2, and 3 pumps and valves to the IST
       -Program as required by-10CFR50.55a(g)(5)(ii).
Presently, PNPS Technical Specification surveillance requirements-are not consistent with-the PNPS Inservice Test. Program. When. conflicts exir' between                     <
L       a revised:IST Program and Technical Specifications, -10CFR50.55a(g)(5)(ii) _
,       requires an-amendment-be' sought to conform the techniel specifications to the              -
I revised program. The PNPS IST progran is being ravisad for its third-                               ~
successive 120 month-inspection-interval per 10CFRR.55a and complies with the
       -1986 edition of the AS:1E Boiler and Pressure Vessi. Code, Section-XI'.                             ,
l
                                                              - e L

p
,n Y
A1TAtllMENT A ibis change also adds a new section to the technical ;peelf i cations (Section 3.13) to specify Limiting Conditions of Operation and Surveillance Requirements for ASME Code Class 1, 2, and 3 or equivalent pumps and va'ves.
Also the term refueling ...terval is added to t he definitions to spor,ify the
(                             p'.n loJ of time batween designated ASME Section XI surveillances, normally performed during refueling outagrs, and allows the 25% schedule tolerar.co to be applied to the refueling interval period of 24 months.
This change contorms the technical specification to the SI program, provides consistency by perfonaing testing to a single test progr..a, uses test methods approved by tht. NRC, and incre6es component availability by reducing unnecessary testing and wear on equipment.
Anothr propcsed administrative change removes Section 4.6,0.5.                                                                                                This section is obsolete and was applicable only during Cycle 6 and Cycle 7.
The follnwing is a description of the specific changes being made delineated by Technical Specification section:
hilim.JL4dG RJACllyJTY C@iROL lhe surveillance Requirement for cycling the scram dischargo volume vent and drain valves is baing revised to test the valves quarterly in accordance with section 3.13 "1.                                     'VICE CODE TES11NG". The requirement to verify the valves are open on a mc                                                y basis is not being changed. lesting in accordance with the IST Program .                                            aires cycling these valves on a quarterly basis and does not change the int.aded surveillance requirement. Performing testing to a single NRC approved test program simplifies compliance while ensuring the intendeo surveillances are performad.
Additiont.11y, the requirement to stroke time test the Scram Discharga Volume Drain and Vent valves closed during each refueling outage is revised to require performing this test during each refueling interval.                                                                                    This change conforms this surveillance requirement to the PNPS IST Program and limits the interval between tests to that specified in Section 3.13 (i.e., ence every 24                                                                                           ,'
months). The cu- 'nt interval (each refueling outage) does not provide a limit to the time period between tests.                                                                            This change conforms the Technical Specifications to the IST Program, and prescribes a test frequency consistent with ASME, B&PV Code, Section XI requirements, hclion 3/4.4. A STANDBY 11 QUID CONTROL SYSTQi LSHL(1                                                                  _
The Technical Specification requirement to perform monthly pump testing is being revised to quarterly. This change conforms the surveillance requirements to th- IST Program and provides assurance of normal system availability.                The quarterly test ensures pump performance meets established operational criteria and provides trending information on flow rate, tank lovel, vibration, lubrication levels and verifies the technical specification specified flow and system head acceptance criteria are met. The existing technical specification monthly testing requirement results in excessive testing of the components and corresponding wear.                                                                              Increased equipment wear and the potential for increased unavailability of equipment due to frequent

AT1ACitMEN1 A testing tend to offset the added assurance of operability that monthly
      ~
functional pump tests may provide. The quarterly test provides comprehensive test data points and a more conclusive assessrent of operational readiness.
Industry experience and a review of PNPS procedures and surveillance records indicates quarterly testing is sufficient to maintain pump performance and to assess operational readiness.
1 Testing of the Standby liquid Control (SBlC) system relief valves is being revised to allow testing the valves in accordance wit! section 3.13 of the proposed technical specification and change the test frequency from once per                         ,
cycle to once per refueling interval.             This change also revises the setpoint              .
for testing the SBLC system relief valves from its existing range of.1275 to                         l 1800 psig to the relief valve setpoint of 1425 psig. The existing test.                              '4 criteria was put in place due to the test methods utilized during-initial station operation, lhe relief valves were tested in-situ and the setpoint of                         -
1425 1 50 psig was difficult to achieve; therefore, Technical Specifications were amended to demonstrate the relief valves would operate within the design
,                         parameters of the system, lhe lower limits were chosen because the lower                           i
:                         limit of 1275 psig is above the reactor vessel design pressure and the upper                         '
limit of 1000 psig is the overpressure limit of the SBLC System This provided realistic setpoint criteria tused on the test methods employed at the time, were consistent with the design intent, and allowed in situ testing.                           '
Revising the setpoint to_the more stringent manufacturer's set _ pressure of 1425 psig i 43 psig and-testing in accordance with the methods prescribed in the IST Program provides assurance of operability and supplies critical date                         t
:                       for assessing relief valve condition that is not obtainable with the present functional testing. Changing the testing frequency from once-per-cycle to                            l once per-refueling interval brings the technical specification frequency into                       >
conformance with the IST Program.
e The once-per-cycle requiremen; to manually initiate the SBLC system (Section 4.4.A.2.b) and pump the baron solution through the recirculation path and back
* to-the SBLC system solution tan _k is being deleted. The proposed quarterly                          ;
test exceeds the current requirement because the test method used verifies the i
pump flow, system head. and the recirculation flowpath, thus, satisfying the L                         once-per-cycle surveillance on a quarterly basis. -The once per-cycle requirement to manually initiate the SBLC system and pump domineralized water                        ,
into the reactor vessel is being changed to perform this test once per refueling interval. This test checks for proper operation of the explosive valves and proper operation of the pump and valves. Testing the pumps, valves, and explosive valves will be in accordance with the methods and                             >
frequencies prescribed in the ASME B&PV code. Also an editorial change is being made to Section 4.4.A.2.c to state "This test checks ..... pump capacity," Operability was changed to capacity-to more accurately describe                            .
                        -the purpost of the test.
The associated bases sections have been revised to reflect the above changes.                      3 Sf1ClElfAIlDlLJLM CORE AND'CONTAIMGT C00WS SYSmiS The surveillance requirements for Core Spray, LPCI, HPCI and'RCIC testing is4 l
being revised to change the frequency of pump and Motor Operated Valve-Operability testing from monthly to quarterly. lhls change conforms the                              :
technical specifications to th? PNPS ISl Program and requires terting-                              j
                                                                                       .-             -             =

A1TACHMENT A 4
according to current industry standards. _ industry and Plant experience demonstrates that testing on a quarterly basis provides assurance of pump 4
operability. Testing on a monthly basis subjects the equipment to increased J
wear and the potential for increased unavailability of equipment due to                          j
,         unnecessary testing offsetting the assumed added assurance of monthly testing.
                                                                                                          ]
!         Containment Cooling System Surveillance requirements for Reactor Building.                      !
Closed Cooling Water System (RBCCW) and Salt Service Water System ($SW) are                     j being revised to perform pump and valve testing in accordance with the IST                       '
Program, Section 3.13 of the proposed technical specifications. Testing in accordance with the IST Program requires testing on a quarterly basis and does not change the intended surveillance requirement. Performing testing to a single NRC approved test program simplifies compliance and ensures intended                     l surveillances are performed.
MLtion 32idl$A.HlLR!DEllU VALES                                                                 ,
i e
lhis change conforms the technical specification surveillance-requirements-to               i the PHPS IST Program. Presently, technical specifications require one. safety                  ;
valvo and two relief / safety valves to be checked or replaced with bench checked valves nnce per operating cycle. This change revises the test                           ,
requirements to be in accordance with Section 3.13 of the technical specifications. Test frequencies will be those specified in ANSI /ASME OM-1                    ,
that have been reviewed and approved for use by the NRC.       The PNPS IST Program             ,
will conform to the 1986 Edition of Section XI of the ASME Boiler and Pressure Vessel Code, Subsection _IWV. Subarticle IWV-3510, Safety and Relief Valves                   !
Tests, specifies that ANSI /ASME OM-1 be used for test frequency, test                         '
procedure, and corrective action. Invoking the requirements of the IST
* Program will require the valves that are replaced to be tested arior~ to                      i resuming operation.- If all the valves are replaced, they must ae tested                      >
within twelve months. These additional requirements ensure prompt detection-and correction of any problems. Presently, the Technical Specifications require the relief / safety valves to be checked or replaced.' The IST. Program                ,
         -amplifies the Technical Specification requirements by specifying testing methods, the time period for complaing testing, and the corrective action to                ,
be taken when the valves fail to meet acceptance criteria. Compliance to                      .
ANSI /ASME OM-1 Test Code satisfies the existing Technical Specification                      '
requirements and enhances safety by imposing additional testing-requirements when there are failures.
httie 3/4.7. A PRl(MBL@l{leINMEN1                                                             -
This change conforms the technical specification surveillance requirements for' testing primary ' containment isolation valves to the PNPS_ IST Programi The' requirement to cycle the normally open valves, verify main steam isolation-                   2 valve operability, and to test pressure suppression chamber / reactor building:
vacuum breakers once per quarter ~is being revised. Testing will be in accordance with the-lST Program, retaining the same test frequency-                           i requirements but performing the testing to a single test program (i.e., the-                  -
IST Program).
This change also revises the instrument line flow check valves surveillance-requirement such that testing _will be in accordance with the IST Program._ The frequency is changed from once-per-cycle to once-per-refuelingEinterval, def.ined_as at least once every 24. months.- Testing on a~once_per cycle basis-ties the requi_rement to.an 18 month' frequency which-is inconsistent with.the-              .
current industry stedards:(ASME Section XI). -This change allows' testing to_                 -
    ,A  w u. -            - - .           --        . - - - - - - . -            a-     . . - . . :-d

ATTACHMENT A be commensurate with os e+ at refueling outage schedules and precludes unnecessary planned out*                     5  accomplish testing once per cycle. The PNPS 151 Program Relief Requm                     . 22 was reviewed and approved by the Commission to allos testing once dur;ng each refueling outage. Testing at a frequency of once each refueling interval limits the time interval between tests and will be in conformance with the revised PNPS IST program.
A new section, Section 3.13, is being added to the t:chnical specifications to specify limiting conditions of operation and surveillance requirements for Inservice Code Testing. This new section is modeled after the BWR Standard Technical Specifications.
IMnMnamm_pijf tslan11Lta_nLLLa rJttdil931d@.tauo.n lhe Code of federal Regulations (10Cfi A0.9.) requires liter. sees requesting an amendment to provide an analysis, using the standards in 10CFR50.92, that determines whether a significant hazards consideration exists. The following analysis is provided in accordance with 10CfR50.91 and 10CfR50.92 for the proposed amendment which conforms the Technical Specifications to the PNPS IST Program by revising surveillance requirements where conflicting requirements exist and specifying testing for ASME. Code Class 1, 2, and 3 or equivalent pumps and valves to be performed in accordance with the PNPS IST Program.
: 1. lhe 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.
This proposed change does not alter any equipment configuration .c operation at Pilgrim.
Current Technical Specifications require testing at the same frequency specified in the PNPS IST Program for Scram Discharge Volume and Primary Containment Isolation Valves. This change requires testing at the same                    I frequency and has not changed the intended surveillance requirement; therefore, it does not involve a significant increase in the probability or consequences of an accident previously evaluated. Testing will be perfnrmed in accordance with the 1986 Edition of the ASME Boiler and Pre',sure Vessel Code, Section XI except where relief has been granted by the Commission per 10CFR50.55(a)(g)(6)(ii).
Frequency of testing will be changed for pump and M0V operability frcm monthly to quarterly for the following Core and Containment Cooling Systems; Core Spray, low Pressure Coolant injection, Reactor Core Isolation Cooling, and High Pressure Coolant injection. This change reduces excessive testing of safety related system pumps and valves and conforms the PNPS Technical Specification to the IST Program. Monthly testing of pumps and valves results in increased testing without providing a significant increase in safety.                The proposed change requires testing to the latest industry standards which exceed the existing technical specification surveillance requirements by specifying test methods that establish operability and establishes parameters for monitoring degradation to predict future equipment performance and failures. The proposed surveillance frequency does not involve a significant increase in the probability or consequences of an accident previously evaluated, l

!                                                                     AT1ACliMENT A fest frequencies for Scram Discharge Volume Drain and Vent valves, Standby Liquid Control System (SLC) relief valves and explosive valves, Safety and Relief Valves and Primary Containment Vacuum Breaker and Instrument Line flow Check Valve specified as once per-cycle or during a refuuling outage are being revised to once during a refueling interval.             -
lhis change adds the term REFUELING INTERVAL to Section 1.0 nf the Technical Specifications providing a test frequency for ASME Code,                  i Section XI, lWP and IWV surveillance require e ts of at least once every 24 months.
The change in frequency from once during each refueling outage to once each refueling interval as applied to testing of the Scram Dischargo Voluine Vent and Drain valves and the Primary Containment Vacuum Breakers provides a limiting time for performing surveillances. Current technical specifications do not provide a limiting time between surveillances; hence,the length of an operating cycle or refueling outage can delay tests beyond the proposed interval of two years. Therefore, the proposed            ,
amendment enhances safety by providing a limiting time between surveillance tests. The proposed change conforms the PNPS Technical                 !
Specifications to the PhPS IST Program and limits the period between surveillances; therefore,it does not involve a significant increase in the probability or consequences of an accident previously evaluated.                ,
The testing frequency for SLC relief valves is being changed to once each refueling interval as specified in Section 1.0 of PNPS Technical Specifications. This change et,nforms the technical specifications to the PNPS IdT Program which requires testing in accordance with ASME/ ANSI OM-1. Testing the explosive valves once-per-cycle is being changed to            ,
once-each-refueling interval as specified in Section 1.0 of PNPS Technical Specifications. This surveillance test checks explosion of the charge associated with the tested loop and the operation of the SLC system. Pump and valve operability.is verified quarterly in-accordance with the PNPS IST program. Manual initiation of the SLC systen, once-per-           .
refueling-interval verifies the system by checking for proper operation of switches and circuit continuity. Performing this test at a frequency             ,
of once-per refueling interval-tests the explosive valves Li accordance with ASME B&PV Code, Section XI. The circuit and switches required for system actuation are reliable and testing once per-refueling interval meets the intended surveillance requirement of testing during refueling i                                   outages. Testing to the latest industry standards provides assurance of operability by testing using prescribed methods at frequencies recognized by the NRC as appropriate. -A testing frequency of once-per refueling:
l                                   interval returns the intent of the technical specification to test during refueling outages, but imposes a restriction by providing a limiting time of two years. This change does not involve a significant increase in the l                                   probability or consequences of an accident previously analyzed.
l The setpoint of the SLC system relief valves is being changed to the manufacturer's stamped setting of 1425 psig 43 psig. The current technical specifications allow a range of 1275 to 1800 psig. This reflects past test practices. Current test procedures remove relief l                                  -valves from the system for bench testing-allowing accurate determination I
of the setpoint. Testing to the manufacturer's-stamped setpoint enhances l                                   safety by detecting drift cnd degradation of the relief valve as well as assuring operability. The past test practices ensured the design intent             ,
  ~                    . - , - - -

ATTACHMENT A of the system to prevent the loss of sodiun pentaborate via lifting of                           l the relief valve at too low a pressure and protecting the system from overpressure. Testing to the latest industry standards and to the                               ;
manufacturer's stamped setpoint enhances safety by providing a means to assess the condition of the relief valve as well as their operational                           l readiness; hence,this change does not involve a significant increase in                          ;
;                                      the probability or consequences of an accident previously analyzed.                             {
An editorial change is also being made to clarify the explsnation of the-surveillance test that initiates the SLC system and pumps demineralized water into the reactor vessel. lhe explanation describes the components                         ,
that are tested and changes the word " operability" to " capacity" where                        ,
the pump test is described. 1his change is editorial in nature, provides                        ,
a better description of the test,and does not impact the probability or.-                       !
consequences of an accident previously evaluated.
Safety and Relief Valve testing is being revised to test in accordance with the PNPS IST Program.             Testing to the ASME/ ANSI OH 1 criteria i
requires valves to be tested to the current industry standards. The test                        ;
i                                      frequency is changed from once per-operating cycle to once-per refueling                        i interval,         lhe frequency for once per-operating cycle testing is 18                      I months instead of the 24 months imposed by refueling interval testing.                          l Testing to the ASML/ ANSI OM-1 criteria requires the relief / safety valves to be tested prior to resuming operation of the station, it provides an                         ;
alternative to this testing by allowing the replacement of all relief / safety valves with pretested valves with a requirement for testing
* the replaced valves within 12 months. These requirements provide assurance of operational readiness and, coupled with prescriptive                               :
corrective action, ensures failure is quickly identified.                   This benefits       i l                                      safety offsetting the increased test interval and does not cause a l                                      significant increase in the probability or consequeates of an accident                          ;
previously evaluated.
Recctor Coolant System Instrument Line Flow Check Valves -testing is-currently required once per-cycle.                   This is being revised to test'in           ,
accordance with the PNPS :ST Program at a frequency of once per refueling interval. This change has already been reviewed by the NRC in the                               '
l                                      Technical Evaluation Report (TER) for the.PNPS IST Program Relief Request RV-22 (TAC'No M74785). This change will conform the PNPS Technical                              r Specifications to the PNPS IST Program and is in accordance with an approved relief request. Testing at a frequency coinciding with refueling outages does not significantly lengthen the test interval and does not involve a significant increase in the probability or-consequences of an accident previously evaluated.
Refueling outage testing of the drywell-pressure suppression chamber vacuum breakers is being' revised to~ allow testing-during each refueling                       e interval.- A refueling interval test frequency of two years _ satisfies the-                    .
intent of the technical specifications to perform the testing during refueling cutages while ensuring the intended frequencies are not
* exceeded by limiting the time-that could elapse between tests. Refueling                        ,
outages currently occur on-a frequency coinciding with the proposed change; therefore, this change does not offectively increase the test interval. between tests. This change conforms the PNPS Technical Specifications to the PNPS IST Program and does not involve a significant l                                      increase in the probability or consequences of an accident. previously.
eyaluated.
bm.                            _ . _ _               _..      .m._                  _ - - , . - _ _        _         --    _  _  u.,,_

e                                                                                                                                       ;
ATTACllMENT A 4
5 The requirement to perform as-found testing of safety relief valves-                              !
during Cycle 6 and Cycle 7 is obsolete and is being deleted. This change is editorial because the reoutrements are no longer in force, and it does not increase the probability or consequences of an accident-previously evaluated,                                                                                        i Adding a new section to specify Limiting Conditions of Operation and                              }
Surveillance Requirements for ASME Code Class 1, 2, and 3 components imposes established requirements and does not increase the probability or consequences of an accident previously evaluated.                                                 ;
: 2.       The operation of Pilgrim Station in accordance with the propoaed amendment will not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed changes which revise testing frequencies and/or perform                   .
testing in accordance with the IST Program do not alter the design-or                            !
change the operation of Pilgrim Station and, therefore, will not creato                         3 the possibility of a new or different kind of accident from any accident                          -
previously evaluated.                                                                            i l                                    Adding the term Refueling Interval to the definitions and incorporating this term where applicable provides a method of specifying test intervals                        i associated with-ASME Section XI IWP and IWV requirements. This conforms                        ''
the PNPS technical specifications to the PNPS IST Program and does not create the possibility of a new or different kind of accident 'previously evaluated.                                                                                       !
Revising the setpoint for testing the Standby Liquid Control Systen from
* a range of 1275 to.1800 psig to the manufacturer's stamped setting of 1425 psig i 43 psig rnsults in testing the-relief valves to industry -
standards. .It also provides more conclusive results for tracking degradation and drift; thus, the proposed change is inherently                                   ,
conservative and will not create the possibility of a new or different kind of accident previously evaluated.
Editorial changes to more clearly describe surveillance requirements and-deleting an obsolete requirement do not change technical specification requirements; therefore, these changes do not create the possibility of.a new or different kind of accident previously analyzed.
Adding a new section to the technical. specifications to specify limiting conditions of operation and surveillance requirements imposes further                            !
limits, hence, the change does not create'the possibility of a new or:                           ~
different kind of accident previously evaluated.-
: 3.        The operation of Pilgrim Station in accordance with the proposed amendment will not involve a significant reduction in the margin of safety.
The current technical specifications were written-prior to the--
development of. ASME 5ection XI resulting in the test. requirements and'
  ~
frequencies being based on limited industry experience. The crrent industry standards reflect practical requirements and provide ' assurance                        ;
equipment;is capable of performing its safety function when required.
                                                                         -8<

ATTACHMENT A                                  ,
I i
Revising test intervals from once per-cycle to once each refueling interval extends the time between tests by six months. Testing will be performed in accordance with and at intervals specified in PNPS IST Program that meets the requirement of the ASME B&PV Code Section XI except where ielief has been granted by the Commission as allowed by                     !
;                                10CfR50.55(a)(g)(6)(i).                                                                  l l
This change also changes the testing frequency for Core and Containment                  !
Cooling system pumps and motor operated valves from monthly to quarterly             .)
conforming the technical specification to the PNPS IST Program and                      ,
current industry standards. Industry experience has demonstrated this                    i
,                                frequency assures the operational readiness of ASME Code Class 1, 2, and                I 3 pumps and valves. As discussed under l ' above the proposed test                       I frequencies provide adequate assurance of jstem operability. Therefore,                  l the. proposed amendment does not involve a significant r duction in the                  l
;                                margin of safety.
                                                                                                                      .]
Adding the term Refueling interval to the definitions of- technical                  -;
specifications requires testing at a frequency of once per refueling interval instead of once per refueling outage. Refueling outages                     .,
L                                currently occur approximately every two years but could extend beyond two               l years if the unit is in an extended outage. When refueling outages occur             .
at a frequency of aaproximately 2 years, changing the frequency to i                                refueling interval having a frequency not to exceed two years does not-involve a reduction in the margin of safety. llowever, when the time                    !
: i.                               between refueling outages extends beyond two years changing to a frequency of refueling interval limits the period between surveillance                 ,
tests irrespective of when refueling outages occur and in this ca:,e is                 l l
conservative. Changing the frequency of refueling outage to refueling interval for the applicable components does not involve a significant
: l.                               reduction in the margin of safety.                                                     -
Changing the criteria for testing the SBLC system relief valve from a                ,
range of 1275 to-1800 psig to the manufacturer's stamped setpoint of 1425            a; i
psig i 43 psig is conservative and reflects the current industry l                                standards. Therefore, this proposed change does not involve a                           f l
significant reduction in the margin of safety.
* Removing an obsolete-surveillance requirement, reformatting the text and other editorial changes do not change the technical specification requirements; therefore, these changes do not involve a significant                     :
reduction in the margin of safety.                                                      ,
l Adding a new section to.the technical specifications imposing limiting -
conditions of operation and surveillance requirements for. Inservice Code .
Testing is conser',ative and does _not involve a significant reduction in the margin of safety, o
l~
This proposed change has been reviewed and recommended fnr approval-~by.the
* Operations' Review Committee and reviewed by the Nuclear Safety Review and Audit Committee.
V hhedule of Chance                                                                          j This change will-be implemented 6 months after BEco's receipt of its approval by the NRC.
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