ML20111B412

Application for Amend to License DPR-35,revising TS to Reflect Implementation of 10CFR50 App J,Option B

ML20111B412
Person / Time
Site:	Pilgrim
Issue date:	05/01/1996
From:	Boulette E BOSTON EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20111B415	List: ML20111B412 ML20111B420
References
2.96-044, 2.96-44, NUDOCS 9605140407
Download: ML20111B412 (8)

Text

. . .

_ _ ~

l l l 10CFR50.90

]

i Boston Edison Pilgrirn Nuclear Power station Rocky Hdi Road

' Plymouth, Massachusetts 02360 1

o l E. T. Boulette, PhD Ma , 1996 Senior Vice President - Nuclear U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 License No. DPR-35 Docket No. 50-293 Proposed Technical Specification Changes to Primary Containment Intearity

- Boston Edison Company (BECo) hereby proposes the attached modification to Appendix A of i Operating License No. DPR.35 in accordance with 10CFR50.90. The proposed changes will reflect impmentation of 10CFR50 Appendix J, Option B at Pilgrim Station. This submittal  ;

includes the request to revise the TS and the implementation plan as required by Option B.

The requested changes are described in Attachment A. The implementation plan required by I 10CFR50 Appendix J, Option B, V.B.2 is included in Attachment B. The revised Technical ,

Specification pages are provided in Attachment C. Attachment D provides the existing pages  !

marked-up to show the proposed changes. l D

E. T. Boulette, PhD ETBWITUbr\ rap 96\appj Commonwealth of Massachusetts)

County of Plymouth )

Then personally appeared before me, E. T. Boulette, 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 statements in said submittal are true to the best of his knowledge and belief. O My commission expires: / M e/999 wM "w. l

c. ."......! f,$ .

DATE INOTARY PUBLIC U ,,  ;

?sl' >.D -

14010, '

?! ~

..~

9605140407 960501 PDR ADOCK 05000293

'.4,

, . , , oJ f'

p PDR og

,' BOSTON EDISON COMPANY U.S. Nuclea'r Regulatory Commission Page 2 -

-Attachments: (A) Description of Proposed Change (B) Implementation Plan (C) Amended Technical Specification Pages (D) Marked up Pages from Current Technical Specifications j1 signed original and 37 copies cc: ' Mr. Alan B. Wan0, Project Manager Project Directorate 1-1 Mail Stop: 1482 U. S. Nuclear Regulatory Commission 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 .

Pilgrim Nuclear Power Station Mr. Robert M. Hallisey, Director Radiation Control Program Massachusetts Department of Public Health 305 South Street Jamaica Plain, MA 02130 1

l ,

f '

BOSTON EDISON Co. _

Proposed Technical Spedfication ,

. ATTACHMENT A

) . DESCRIPTION OF PROPOSED CHANGE Backaround

~

lL The primary containment leakage rate testing program required by 10CFR50 Appendix J, j includes performance of an Integrated Leakage Rate Test (ILRT) or Type A test, and Local

Leakage Rate Tests (LLRTs) or Type B and C tests. The Type A test measures the overall

leakage rate of the primary containment. The Type B test detects leakage paths and

] measures leakage for certain primary containment penetrations. The Type C te'st measures containment isolation valve leakage rates.

) Appendix J testing requirements ensure leakage through the primary containment,' as well as j . systems and components penetrating primary containment, does not exceed the allowable ileakage rate values specified in the Technical Specifications (TS) or the associated Bases.

i Compliance with Appendix J testing requirements ensures the primary containment

. configuration is structurally sound and capable of limiting leakage to the rates assumed in the l j safety analysis. These requirements also ensure an adequate primary containment boundary '

f is maintained during and after an accident by minimizing potential leakage paths to the

environment, thereby assuring the primary containment function assumed in the safety

~

. analysis is maintained.

On February 4,1992, the NRC published Federal Register Notice 57FR4166, presenting the initial planned actions to institute a continuing effort to eliminate prescriptive requirements that are marginal to safety while imposing significant regulatory burdens on licensees. The NRC concluded that decreasing the prescriptiveness of some regulations may improve the l

regulations' effectiveness by providing licensees the flexibility to implement cost-effective .

, safety measuren. The NRC determined the detailed and prescriptive technical requirements contained in some regulations could be improved and replaced with performance-based  !

requirements and supporting regulatory guides.

{

s in accordance with the above conclusions and the prescriptive nature of 10CFR50 Appendix J, the NRC indicated that potential modifications to Appendix J could be considered. To support

' an Appendix J change, the NRC used an analytical approach documented in NUREG-1493,

" Performance-Based Containment Leak Test Program," to determine the impact on safety due

, to extending Appendix J test intervals. Based on the technical findings discussed in NUREG-1493, the NRC concluded:

l . Testing' intervals for Type A, B and C tests can be increased with only a marginal impact on c safety and should produce significant savings in future industry testing costs.

^ >

C Testing intervals for Type B and C LLRTs can be established based on the experience history of each component.

. Based upon these findings, the NRC revised Appendix J by adding Option B (60FR49495) and issued Regulatory Guide 1.163, " Performance-Based Containment Leak-Test Program" to l- provide a performance-based implementation plan for Appendix J, Option B.

.The proposed changes incorporate 10CFR50 Appendix J, Option B, requirements into the

- Pilgrim Station TS.

A-1'

. _ . . . . _ _ . . . _ _ - . . . _ . . _ _ _ ._ ._ . . ~ .. _ _ __..

t

- BOSTON EDISON Co.

Proposed Technical Specification

~

ATTACHMENT A DESCRIPTION OF PROPOSED CHANGE -

t Proposed Chanae i

The proposed change to Surveillance Requirement 4.7.A.2.a adds " Option B" to 10CFR50_ i Appendix J and adds a reference to Regulatory Guide 1.163 dated September 1995. A note,

, denoted by an asterisk, has been added stating that the Definition 1.U is not applicable to leak <

rate tests. The remainder of surveillance 4.7.A.2.a has P. replace 45 psig or "x".

Finally, the originalleakage rate performance criteria in Surveillance 4.7.A.2.a has been 7 replaced with leakage rate acceptance criteria.

3 The Bases have been enhanced to provide more detail of the leak rate test program that will be performed using Option B. ,

Reason for Chanae j As discussed in the Background section above, performance-based leak rate testing intervals can be increased with only a marginal impact on safety and should produce significant savings in future testing costs. This change will allow Pilgrim Station to implement this performance based testing.

10CFR50 Appendix J, Option B, V.B.3 states "The Regulatory Guide...must be included, by general reference, in the plant technical specifications." The addition of " Option B and  :

Regulatory Guide 1.163 dated September 1995" meets this requirement of the rule. t The note " Definition 1.U is not applicable to Leak Rate Tests" has been added to Surveillance 4.7.A.2.a because the implementing guidance document NEl 94-01 (referenced in the regulatory guide) contains a 25% schedule allowance. This is an administrative change to assure that an additional 25% is not added due to the definition.

P. represents the calculated peak containment intemal pressure and is replacing 45 psig or "x" in surveillance 4.7.A.2.a for consistency with 10CFR50 Appendix J. This is an administrative change. i The performance criteria in Surveillance 4.7.A.2.a has been replaced with acceptance criteria to be consistent with the NEl 94-01 and ANSI /ANS-56.8-1995 requirements. The Containment Leakage Rate Test Program will contain the performance criteria.

The Bases associated with containment testing has been modified to include a summary ,

description of the containment testing program. l l

A-2

BOSTON EDISON Co.

Proposed Technical Specification ATTACHMENT A DESCRIPTION OF PROPOSED CHANGE Safetv Evaluation and Determination of No Sianificant Hazards Considerations The Code of Federal Regulations (10CFR50.91) requires licensees 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.

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.

The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed changes do not involve any physical or operational changes to structures, systems or components. The proposed changes provide a mechanism within the TS for implementing a performance-based leakage rate test program which was promulgated by the revision to 10CFR50 to incorporate Option B into Appendix J. The TS Limiting Conditions for Operation (LCO) remain unaffected by these changes. Thus, the safety design basis for the accident mitigation functions of the primary containment is maintained.

Therefore, these changes will not increase the probability or consequences of an accident previously evaluated,

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.

Revising surveillance requirement acceptance criteria and frequencies does not physically modify the plant and does not modify the operation of any existing equipment. Further, the TS LCOs remain unaffected by these changes.

3. The operation of Pilgrim Station in accordance with the proposed amendment will not involve a significant reduction in a margin of safety.

The proposed changes do not involve a significant reduction in the margin of safety, nor do they affect a safety limit, an LCO, or the manner in which plant equipment is operated. The NRC letter dated November 2,1995, recognizes that changes similar to the proposed changes are required to implement Option B of 10CFR50, Appendix J. In NUREG-1493, " Performance-Based Containment Leak-Test Program," which forms the basis for the Appendix J revision, the NRC concludes that adoption of performance-based test intervals for Appendix J testing will not significantly reduce the margin of safety. )

The proposed change has been reviewed and recommended for approval by the Operations Review Committee and reviewed by the Nuclear Safety Review and Audit Committee. I A-3 l

)

1

I

~

BOSTON EDISON Co.

Proposed Technical Specification ATTACHMENT A DESCRIPTION OF PROPOSED CHANGE l Schedule of Chanae i

This change will become effective 30 days following BECo's receipt of the Commission's  !

approval and will be implemented prior to the start of RFO 11, currently scheduled for February ,

1997.

Procedure changes necessary for an integrated leak rate test will be revised prior to the next integrated leak rate test..

t

]

4 1

A-4

+

BOSTON EDISON Co.

Proposed Technical Specification ATTACHMENTB 10CFR50. Appendix J. Option B. Implementation Plan Boston Edison Co. (BECo) intends to implement the requirements of 10CFR50 Appendix J, Option B for use in RFO 11, scheduled in 1997.10CFR50 Appendix J, Option B, states: ,

" Specific guidance conceming a performance based leakage-rate test program, acceptable leakage-rate test methods, procedures, and analyses that may be used to implement these requirements and crit 6ria are provided in Regulatory Guide 1.163."

I Regulatory Guide 1.163 references NEl 94-01 and ANSI /ANS-56.8-1994. Pilgrim's leakage i rate testing program will be in compliance with 10CFR50 Appendix J, Option B; the proposed

+

3 TS; and Regulatory Guide 1.163, prior to implementation of the TS amendments.

1

- Relative to implementation of the performance-based program, the following clarifications j  ; relative to the timing of procedure revisions and information stated in ANSI /ANS-56.8 and

NEl 94-01 are provided.

I

Procedure Revisions Procedures associated with the conduct of the Type A Integrated Leak Rate Test (ILRT) will be

revised to incorporate the methodologies specified in ANSt/ANS-56.8-1994 prior to the next

ILRT.

! Interval Extensions l

, if data justifying the extension of a Type B or C test interval have not been evaluated, the test interval of 30 months as discussed in NEl 94-01 shall apply. Any Type B and C tests

!- conducted after amendment implementation will utilize ANSl/ANS-56.8-1994 methodology, j Pilgrim Station's inservice Testing Program, may reference the use of Appendix J testing requirements to meet ASME B&PV Code,Section XI and/or ASME Operations and Maintenance (OM) Code test requirements. This is to confirm that the test interval in these cases will be determined by ASME B&PV Code,Section XI and/or OM Code criteria and not

{ the Option B interval extension criteria, unless allowed under published NRC endorsement or

! NRC approved IST program relief request (s).

4 NEl Recommended Practices

! Sections 8.0 and 10.2 of NEl 94-01 recommend that the combined as-found leakage rates for i

Type B and C tests, determined on a Minimurn Pathway Leakage Rate (MNPLR) basis, be

<0.60 L. when containment integrity is required. The TS requirement is that the overall leakage rate be SL. when primary containment integrity is required in accordance with TS j 4

3.7.A.2.a. The TS acceptance criteria is a reflection of the safety analysis assumptions. We l- will maintain a running total of the as-found leakage rates (Type B and C tests) determined on an MNPLR basis for all applicable penetrations. However, BECo considers 0.60 L to be a performance indication, not a TS Operability Limit. If 0.60 L. is exceeded, we will implement corrective measures to ensure the overall containment leakage remains 51.0 L..

B-1

i BOSTON EDISON Co.

Proposed Technical Specification ATTACHMENT B 10CFR50. Appendix J. Option B. Implementation Plan

- NEl 94-01 and ANSI /ANS-56.8-1994 indicate that for a two barrier pathway, the Maximum Pethway Leakage Rate (MXPLR) is the measured leakage through the worst of the two isolation valves. If a penetration is isolated by use of one closed and deactivated automatic valve, closed manual valve, or blind fiange, BECo considers the MXPLR of the isolated penetration to be the measured leakage through the closed isolation device for purposes of satisfying the as-left leakage acceptance criteria.

4 3

p T

I B-2