ML20067E345

Application for Amend to License DPR-35,changing Tech Spec 3/4.7, Primary Containment Integrity to Delete Ref to Specific Date of 10CFR50,App J & Remove Table 3.7-1 Re Primary Containment & Reactor Vessel Isolation Valves

ML20067E345
Person / Time
Site:	Pilgrim
Issue date:	02/06/1991
From:	Gina Davis BOSTON EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20067E346	List: BECO-91-012, Proposed Tech Specs Re Limiting Conditions for Operation & Surveillance Requirements for Primary Containment Integrity & Primary Containment Isolation Valves ML20067E345
References
BECO-91-012, BECO-91-12, NUDOCS 9102140204
Download: ML20067E345 (5)

Text

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+ . 9. L , 10CFR50.90-I

. [f BOSTON EDISON Pilgrim Nucisar Power Station Rocky Wil Road Plymouth, M ssachusetts 02360 3

George W. Davis s ne Vce President - Nucleu BEco 91- 012 U.S. Nuclear Regulatory Commission Document Control l Desk Hashington, DC 20555'- -

License DPR-35  ;

Docket 50-293 PROPOSED-ADMINISTRATIVE TECHNICAL SPECIFICATION Q{ANGE TO SECTION- 3/4.7: PRIMARY CONTAINHENT-INTEGRITY ,

-Boston Edison-proposes the attached changes to Section 3/4.7 " Primary

' Containment' Integrity" -Of:the Pilgrim Nuclear Power Station Technical -

Spect ficationsdiniaccordance With 10CFR50.90. - The proposed change deletes

- reference to aispeciI:lc date of 10CFR50 Appendix J and removes Table 3.7-1 q

-" Primary. Containment and Reactor Vessel Isolation Valves".-

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-The requested changes are described in Attachment A, the revised Technical

- Specificatio_n'pages 'are in -Attachment B, and the current Technical .

' Specification.pages, annotated to indicate the requested revisions, are _in  !

-Attachment;CL '

., N }-t/v1 G. H. Davis HTL-/ rec /5076 1 Attachmentst i l Signed Originalgand 37 Copies

-cc:. See.next'page_

~ Commonwealth of Hassachusetts)

-Countyfof Plymouth: ). ~'

LThen personally' appeared before me, George H. Davis,'who-being duly sworn, did state- that. he-is Senior :Vice President - Nuclear of Boston Edison . Company :and

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 stateme 'Th['"'

said submittallare ,true to-the best of his knowledge'and belief. #

4 .... . . ..E My commission. expires: Na</3,/Pht_ / 'Mh 4- s 7 DATE NOTARY PUBLIC *f

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9102140204 910206 bf'N PDR ADOCK-03000293 .

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PDR ;f: -1 f y

• . , BOSTON EDESON COMPANY

, U. 'S. Nuclear Regulatory Commission Page 2 cc: Mr. R. Eaton, Project Manager Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Mail Stop: 14D1 U. S. Nuclear Regulatory Commission 1 White Flint North 11555 Rockville Pike Rockville, MD 20852 U. S. Nuclear Regulatory Commission Region-I 475 Allendale Road King of Prussia, PA 19406 Senior NRC Resident Inspector Pilgrim Nuclear Power Station Mr. Robert H. Hallisey, Director Radiation Control Program Massachusetts Department of Public Health 150 Tremont Street, 2nd Floor Boston, MA 02111 i

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. ATTACHMENT A TO BECo LETTER 91- 012 ErgppnLChance

,The proposed changes to the Pilgrim Technical Specifications are administrative in nature and do not change plant design or configuration.

Technical Specification Section 4.7.A.2-.a and its associated bases state that primary containment testing is done "in accordance with 10CFR50 Appendix J, as amended thru September 22, 1980." The proposed change deletes "as amended thru September 22, 1980."

This proposed change deletes Table 3.7-1 which contains a partial list of primary containment and reactor vessel isolation valves. The entire list of primary containment isolation valves is contained in the updated Final Safety Analysis Report and plant procedures.

Technical Specification Sections 3.7. A.2.b, and 4.7. A.2.b.2 are modi fied in this proposed change by deleting the reference to Table 3.7-1.

The words " primary containment" are being added to sections 4.7.A.2.b.l.a and '

4.7.A.2.b.l.b for clarity.

ReasonLforChanae-Effective November 15,1988 (53FR45890), Appendix J to 10CFRSO was modified to permit licensees to use the Mass ' Point analysis as an alternative to other approved analyses. The Pilgrim Technical Specifications, as written, do not allow use of this change.

HeLare required to comply with-the latest revision to 10CFR50 Appendix J unless an exemption exists. He propose to delete the date of the code leaving the Pilgrim Technical Specifications to state that Primary Containment Leak Tests are performed "in accordance with 10CFR50 Appendix J, with exemptions..."

Deletion of Table 3.7-1 reduces an administrative burden from both the-utility and the NRC because future. changes to this table would be made in accordance with'10CFR50.59 rather than through a change to Technical Specifications. The operability, surveillance, and test requirements for containment isolation ,

valves are unchanged by this proposed change. The list of isolation valves willibe maintained in the Updated Final Safety Analysis Report (Tables 5.2-4 and 7.3-IF and in the plant procedures.

QLtar.{nination of No S-lanificaat Hazards The proposed amendment deletes a reference to a' specific date of 10CFR50 Appendix J, adds words for clarity, and removes the list of " Primary

--Containment. and Reactor Vessel Isolation Valves" from Technical Specifications.

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. ATTACHMENT A TO BEco LETTER 91-012-

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The Code of Fe'deral Reaulations,-10CFR50.91' requires that at the time a licensee requestscan amendment, it must provide to the Commission its

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--analysis,-using- thef standardsiin 10CFR50.92, about the issue of no significant hazards co_nsideration.' iTherefore, in accordance vith '10CFR50.91 and 10CFR50.92:the following analysis has been performed.-

-1. _ The operation of Pilgrim Station in accordance with the proposed amendment

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will not. involve a significant. increase in the probability or consequences ,

of an accident previously. evaluated.

The proposed change deleting the specific date of 10CFR50 Appendix J does not involve a significant increase.in the probability or -- -

consequences of an accident previously' evaluated. This change.is

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administrative in nature. It-allows; Primary Containment Testing to be ~

s -performed in~ accordance with' the current revision of 10CFR50 Appendix J. This change-does not affect-plant operation or design. 7

-The= proposed removal 1of Technical Specification Table 3.7-1 " Primary

' Containment and Reactor Isolation Valves":does not-involve a significant increase in the. probability or: consequences of an accident' previously analyzed. Relocating themtable's information to other

. control. led-documents does not affect the probability or consequences of anyopreviously analyzed accident because no: hardware changes are being proposed, sand because isolation valve operability and surveillance

requirements are not relaxed.

2. The operation of Pilgrim Station in accordance with the proposed amendment

, will not_. create _ the possibility of a. new or different kind of accident from any accident'previously evaluated.

The proposed amendment;does not_ create the possibility of a new or ,

.different kind of accident than previously evaluated because-the prop'osed change;is, administrative in nature and no physical alterations of. plant configuration or changes to setpoints or operating parameters.  ;

.are proposed.

-3. The-operation of Pilgrim Station in accordance -with the proposed amendment  !

will not involve 1a significant reduction infa margin of. safety, i

lThe proposed amendment 'does notiinvolvefa significant reduction -in a L marginlof safety because Primary Co'ntainment Testing will continue-to R be conducted in:-accordance with the-latest? version of 10CF350 Appendix l- Ji  :

1R emoving Table 3.7-1 from the Technical Specifications does not involve

.a= significant- reduction in._a margin of. safety because operability and.

p' surveillance criteria for valves' needed fortcontainment integrity are- "

nottbeingl relaxed.

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.. ATTACHMENT A TO BECo LETTER 91- 012 This change has been reviewed and approved by the Operations Review Committee, and reviewed by the Nuclear Safety Review and Audit Committee.

Schedule of Chance This r.hange is required prior to startup of Pilgrim Station from Refueling Outage #8. This change will be implemented within 30 days following Boston Edison's receipt of its approval by the Commission.

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