ML20136F563

Application to Amend License DPR-35,consisting of Proposed Change 85-12,deleting Surveillance Requirement 4.7.A.2.g Re Continuous Monitoring of Primary Containment for Gross Leakage.Fee Paid

ML20136F563
Person / Time
Site:	Pilgrim
Issue date:	11/15/1985
From:	Harrington W BOSTON EDISON CO.
To:	Vassallo D Office of Nuclear Reactor Regulation
Shared Package
ML20136F568	List: BECO-85-204, Application to Amend License DPR-35,consisting of Proposed Change 85-12,deleting Surveillance Requirement 4.7.A.2.g Re Continuous Monitoring of Primary Containment for Gross Leakage.Fee Paid ML20136F577
References
BECO-85-204, NUDOCS 8511220146
Download: ML20136F563 (4)

Text

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EONTON EDISON COMPANY 500 EnvLaTDM 37sEET WasTON. MASSACHUSETTS 02199

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... November 15, 1985 m u=.

BECo 85-204 Proposed Change 85-12 Mr. Domenic B. Vassallo, Chief Operating Reactors Branch #2 Olvision of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D. C. 20555 License DPR-35 Docket 50-293 l Pilgrim Station Proposed Technical Specification Change -

l Ccntinuous Leak Rate Monttor 1

Dear Sir:

Pursuant to 10 CFR 50.90, Boston Edison Company hereby proposes modifications to Facility Operating License No. OPR-35 as described in the Attachment to this letter. In accordance with 10 CFR 170 a check in the amount of $150.00 is enclosed with this submittal.

Should you have any questions concerning this submittal, please do not hesitate to contact us.

Very truly yours, 1

kg ment Commonwealth of Massachusetts)

[)g v0 County of Suffolk )

pll W & K $1se+0 4 931810 Then personally appeared before me W. D. Harrington, who, being duly sworn, did state that he is Senior Vice President - Nuclear of the Boston Edison Company, the applicant herein, and that he is duly authorized to execute and file the submittal contained herein in the name and on behalf of the Boston Edison Company and that the statements in said submittal are true to the best of his knowledge and belief. .

My Commission expires: MML&U '

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//[/f/k') v' Nota y Public cc; See next page

BOSTON EDISON COMPANY November 15, 1985 Page 2 cc: Mr. Robert M. Hallisey, Director Radiation Control Program Mass. Dept. of Public Health 150 Tremont Street F-7 Boston, MA 02111

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Attachment l Continuous Leak Rate Monitor Proposed Technical _ Specification Change l

l Proposed Change l

! This proposed Technical Specification change deletes survelliance requirement 4.7.A.2.g. Surveillance requirement 4.7.A.2.g requires the primary l containment to be continuously monitored for gross leakage by review of the inerting system makeup requirements. Deletion of this requirement will result in the removal of the monitoring system from service.

A revised Technical Specification page showing this proposed change is enclosed. Specific instructions are to remove existing page 155 and insert revised page 155.

It should be noted that.this section is also affected by a previous proposed technical specification change which is presently undergoing review by your staff. Refer to Boston Edison Company letter (W. D. Harrington) to NRC (D. B.

Vassallo) dated June 21, 1985. See page 155b, section 4.7.A.2.c.

Reason for Change There are no regulatory or technical bases for the existence of surveillance requirement 4.7.A.2.g. There are no appilcable regulatory requirements reflected in section 4.7.A.2.g or the Technical Specification Bases. Other Pligrim Station operations procedures provide equivalent and more conservative methods for continuously monitoring the primary containment for gross leakage.

Safety Considerations This change does not present an unreviewed safety question as defined in 10 CFR 50.59. It has been reviewed and approved by the Operations Review Committee and reviewed by the Nuclear Safety Review and Audit Committee.

Significant Hazards Considerations We have determined that this amendment request does not involve a significant hazards consideration. The amendment request does not involve a significant increase in the probability or consequences of a previously evaluated accident because only the requirement to perform a surveillance is deleted. There will be no change in the way the 9rimary containment is operated. There will be no change in the configuration of the primary containment. The possibility of a new or different kind of accident from any accident previously evaluated is not created because the need for the subject surveillance requirement is not necessary in view of other existing methods for continuously monitoring the primary containment for gross leakage. There is not a significant reduction in a margin of safety because a comprehensive search for documentation that would provide a regulatory or technical basis for the necessity of this surveillance requirement indicates that the survelliance requirement is not needed.

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• There are no applicable regulations or other NRC requirements reflected in the subject surveillance. A technical design specification for primary containment atmospheric control does contain a requirement to continuously monitor the primary containment for gross leakage by review of the inerting gas makeup needs. However, there is no accompanying basis for this requirement.

A review of nuclear operations procedures shows that there are other equivalent and more conservative methods for continuously monitoring the primary containment for gross leakage. One method utilizes differential pressure indication between the o."ywell and suppression chamber. Oxygen concentration in the primary containment is also monitored as a means for detecting gross leakage.

For the reasons given above we believe that sufficient bases exist to allow NRC to make a no significant hazards determination.

Schedule of Change This change will be put into effect in 30 days upon receipt of approval from NRC.

N.

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