ML19351A545

Application for Amend to License DPR-35,revising Tech Spec Section 1.0, Definitions, to Replace Existing Definition Surveillance Frequency W/Definition Allowing Extension of Intervals by 25%,per Generic Ltr 89-14

ML19351A545
Person / Time
Site:	Pilgrim
Issue date:	12/07/1989
From:	Bird R BOSTON EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19351A546	List: ML19351A545 ML19351A548
References
BECO-89-176, GL-89-14, NUDOCS 8912190282
Download: ML19351A545 (5)

Text

10CFR50.90 l

.. .. Generic Letter 89-14 N O

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Pilgrim Nuclear Power station Rocky Hill Road Plymouth, Massachusetts 02360 BECo 89- 176 Ralph G. Bird December 7, 1989 senior Vice President - Nuclear U.S. Nuclear Regulatory Commission Document Control Desk Hashington, DC 20555 License DPR-35 Docket 50-293 PROPOSED TECHNICAL SPECIFICATION CHANGE TO SECTION 1.0: DEFINITIONS Boston Edison proposes the attached changes to Section 1.0 " Definitions", of ,

the Pilgrim Nuclear Power Station Technical Specifications ir, accordance with 10CFR50.90. The proposed change replaces the existing definition of

" Surveillance Frequency" with a definition allowing the extension of specified surveillance intervals by 25% without limiting such extension to 3.25 times the specified interval for 3 consecutive intervals. This proposed change is an NRC recommended line-item improvement and is made in accordance with the guidance of NRC Generic Letter 89-14 of August 21, 1989.

Attachment A to this letter provides details of the propoi,ed change and the i Safety Evaluation and Determination of No Significant Hazards. Attachment B l provides the amended Technical Specification pages, and Attachment C shows the l proposed changes on marked-up pages from the current Technical Specification.

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. G. ird PMK/jcp/3734 l Attachments 1 Signed Original and 37 Copies cc: See next page l Commonwealth of Massachusetts)

County of Plymouth l

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Then personally appeared before me, Ralph G. Bird, 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 i 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: OMS. ZfW KIM DATE

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. BOSTON EDISON COMPANY.

• December .7,1989 U S. Nuclear Regulatory CommissiCn

• Page'2 cc: Mr. D. Mcdonald, Project Manager Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Mail Stop: 1401 U. S. Nuclear Regulatory Commission 1 White Flint North 11555 Rockville Pike Rockville, MD 02852 U. S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Senior NRC Resident Inspector Pilgrim Nuclear Power Station 1

Mr. Robert M. Hallisey, Director Radiation Control Program Massachusetts Department of Public Health 150 Tremont Street, 2nd Floor Bosta", MA 02111 i L

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F ATTACHMENT A Proposed Changjt This proposed change replaces Pilgrim Nuclear Power Station's existing Definition "U", Surveillance Frequency, with a new definition conforming to the NRC guidance of Generic Letter 89-14 (GL 89-14).

The proposed change also moves the definition of an operating cycle interval 1 from Definition "U" to Definition "V", Surveillance Interval. This definition movement is made to place a specific interval under its proper heading and to add to the clarity of Definition "U". '

Because of the added words in definition "U" it is necessary to move definition "Z" to the next page.

Reason for Chanae Pilgrim's existing definition of Surveillance Frequency allows the extension of a surveillance interval by 25% with the total maximum combined interval time for any three consecutive surveillances not to exceed 3.25 times the specified interval.

Pilgrim and industry experience shows a safety benefit can be realized by applying the 25% to surveillance intervals without the limitation imposed by the 3 consecutive interval requirement. The safety benefit results when a surveillance interval is extended during plant conditions unsuitable for performing the surveillance or maintenance activities. Examples of unsuitable plant conditions include transient plant operating conditions or conditions involving safety systems being out of service for surveillance or maintenance activities.

Removing the 3 consecutive surveillance limit also reduces the administrative burden of tracking the use of the 25% extension to ensure compliance with the 3.25 limit.

Safety Evaluation and Determination of No Sionificant Hazards Consideration The Code of Federal Regulations (10CFR50.91) requires licensees requesting an i 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 replacing the existing Pilgrim definition " Surveillance Frequency" with a new definition conforming to the guidance of GL 89-14.  ;

1. The operation of Pilgrim Station in accordance with the proposed amendment l will not involve a significant increase in the probability or consequences of an accident previously evaluated. ,

Experience shows the extension of surveillance intervals enhances safety by removing the need to perform a surveillance during plant conditions unsuitable to its performance, such as during transient plant conditions or when safety systems are out of service because of ongoing surveillance or maintenance activities. Limiting the maximum combined interval to 3.25 i times the interval for three consecutive intervals does not increase '

safety because extending surveillances 25% presents a small risk in 1 of 2 d

m g centrast to the alternative of a forced shutdown or performance during unsuitable plant conditions. This position on the safety impact of removing the 3.25 limit is supported by industry experience and documented in GL 89-14. Since the risk posed by this change is less than the risk associated with the existing limit, operating Pilgrim in accordance with the proposed change does not involve a significant increase in the probability or consequences of any accident previously analyzed.

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.

1 Removing the 3.25 limit on increasing surveillance intervals 25% reduces the possibility of a surveillance interval forcing a shutdown, or forcing  :

the performance of a surveillance during unsuitable plant conditions. Its removal thereby reduces the risk associated with either alternative. It does not change plant equipment configuration or operation, and is i administrative in nature. Hence, the change does not create the possibility of a new or different kind of accident from any 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.

Removing the 3.25 limit on increasing surveillance intervals 25% has been shown by industry experience, as documented in GL 89-14, to decrease risk when contrasted with the alternative actions potentially compelled by allowing it to remain in effect. Because risk is reduced by this proposed change, it does not involve a significant reduction in the margin of i safety.  ;

i 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 change will be implemented within 30 days following BECo's receipt of its approval by the Commission. ,

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