ML20080C745
| ML20080C745 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/22/1983 |
| From: | Bauer E, Bradley E, Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20080C744 | List: |
| References | |
| NUDOCS 8308290248 | |
| Download: ML20080C745 (11) | |
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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMFIT 98 TON In the Matter of Docket Nos. 50-277 50-278 PilILADELPHT A ELECTRIC COMPANY AMENDMENT TO APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 & DPR-56 Edward G.
Bauer, Jr.
Eugene J.
Bradley 2301 Market Street Philadelphia, Pennsylvania 19101 Attorneys for Philadelphia Electric Company l
8308290248 830824 DR ADOCK 05000277 PDR I
l BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-277 50-279 PHILADELPHT A ELECTRIC COMPANY AMENDMENT TO APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 & DPR-56 On February 11, 1982, Philadelphia Electric Company, Licensee under Facility Operating License DPR-44 and DPR-56 for Peach Rottom Units 2 and 3,
filed an Application for Amendment of
' the T.icenses which requested that the Technical Specifications contained in Appendix A of the Operating Licenses be amended by incorporating operability and surveillance requirements for new control and instrumentation systems.
Installation of these k
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systems wan required by NUREG-0737, " Clarification of TMI Action Plan Requirements", issued to all licensees on October 31, 1980.
On April 26, 1983, in a telephone conversation with the NRC project manager, Licensee was requested to consider the standard technical specifications for NUREG-0737 items, enclosed with Generic Letter No. 83-02, to revise its February 11, 1982, Application to conform to the guidance of the standard technical specifications and to explain any nonconformance with the standard technical specifications.
Generic Letter 83-02 and the ntandard technical specifications were received by Licensee on April 28, 1983.
To conform its earlier Application to the standard technical specifications to the extent applicable, Licensee hereby amends its Application of February 11, 1982, by adding:
(1) personnel overtime work requirements, (2) reporting re quirements for the primary coolant system safety relief valves, (3) a npecification that the Reactor Core Isolation Cooling (RCIC) system actuation test include the automatic restart on low water level signal and (4) additional surveillance requirements for the RCIC suction transfer feature.
The revisions are indicated by a vertical bar in the margin of the attached paces 69, 72, 81a, 130, 254a, and 256; and by the addition of nee pages 256a, 265 and 266.
Revised pages 254b and 255 are submitted to accommodate a redistribution of material.
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A point-by-point discussion of Licensee's responso to the guidance provideo in Enclosure 1 of the Generic Letter No.
83-02 follows:
(1)
STA Training (I.A.l.1.3)
As stated in Generic Letter 83-02, a response is not required at this time.
(2)
Limit Overtime (I.A.l.3)
New pages 265 and 266, proposed in this Application, provide an overtime specification and bases, that reflect the NRC Policy Statement on working hours (Generic Letter No. 82-12).
The proposal deviates from the NRC criteria to the extent necessary to provide specificity and clarification in the requirement.
Approval of deviations by the employing officer is proposed in lieu of~the Plant Superintendent since selection of maintenance and I&C personnel is under the administration of other divisions.
The specification explicitly identifies the personnel for whom the overtime limits are applicable in the interest of ensuring compliance and avoiding confusion in its interpretation.
I The current Pecch Bottom overtimo policy regarding shift operating personnel and health physics-chemistry technicians complies with the four overtime guidelines specified in the most recent NRC criteria (Generic Letter 82-12, dated June 15, 1982).
In correspondence dated March 31, 1981 (S. L. Daltroff, PECo, to D. G.
Eisenhut, NRC), Licensee proposed a modified version of the NRC overtime policy for key maintenance personnel.
The NRC approved this proposal in correspondence dated February 16, 1982 (J. F. Stolz, NRC, to E. G. Bauer, PEco).
This Application proposes a revision in the Peach Bottom overtime policy for key maintenance personnel to establish consistency with the four overtime guidelines specified in Generic Letter 82-12.
Licensee proposes that the overtime provision take effect six months from the issuance date of the License Amendment to provide sufficient time for the development of the necessary administrative controls and procedures.
(3)
Dedicated Hydrogen Penetration (II.E.4.1)
Additional containment isolation valves on the radioactive gas sampler line and the instrument nitrogen compressor suction ?ine were installed to comply with the dedicated hydrogen penetration' requirements (NUREG 0737, Item II.E.4.1).
An application to incorporate l
those valvas into tha technical spscification testing program was filed on July 16, 1980, and approved September 30, 1980 as Amendment Nos. 73 and 72 to the Peach Bottom Operating Licenses for Units 2 and 3, respectively.
(4)
Containment Pressure Setpoint (II.E.4.2.5) t By correspondence dated December 15, 1981, the NRC agreed with the. licensees justification for not changing the containment isolation setpoint.
(5)
Containment Purge Valves (II.E.4.2.6)
As stated in Generic Letter 83-02, a model technical specification will be provided by separate correspondence.
(6)
Radiation Signal on' Purge Valves (II.E.4.2.7)
As stated in Generic Letter 83-02, Technical Specifications for this item will be established after the technical resolution of this issue is completed.
l (7)
Reporting Safety Valve and Relief Valve Failures and Challenges (II. K. 3. 3 )
9 Additional reporting requirements are proposed on pages 254a and 256 of the Application.
The proposed prompt reporting specification deviates from the Standard Technical Specifications provided in Generic Letter No.
83-02 in order to conform with the NRC's reporting requirement specified in correspondence dated May 7, 1980, "Five Additional TMI-2 Related Requirements to Operating Reactors".
(8)
RCIC Restart and RCIC Suction (II.K. 3.13 and II. K. 3. 22) a.
RCIC Automatic Restart The proposed revision to page 130 stipulates that the RCIC automatic actuation test shall include a test of the automatic restart feature, and therefore agrees with Generic Letter No. 83-02.
b.
RCIC Suction Transfer The calibr.ation frequency for the RCIC suction transfer feature, as proposed in the February 11, 1982, Application, agrees with Generic Letter No.
83-02.
Licensee proposes revising page 72, and amending page 69 ac submitted with the Application of February 11, 1982, to require a Limiting Condition of Operation for the condensate storage tank low level trip instrumentation that conforms l
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to the Stendard Technical Spacification.
Additionally, Licensee proposes amending new page 81a as submitted with the Application of February l
11, 1982, to require a daily instrument check of the condensate storage tank low level transfer trip.
A " daily instrument check" rather than a "once per twelve hour instrument check", as shown in the Standard Technical Specifications (STS); as well as a functional test frequency of "once per three months" rather than " monthly", as shown in the STS, are proposed based on (1) the design of the level instrumentaion (analog transmitters), and I
(2) the limited design role the RCIC system would perform during a loss of coolant accident.
(9)
Isolation of HPCI and RCIC Modification (III.K.3.15)
The proposed changes on pages 70 and 81 of the February 11, 1982, Application are consistent with the guidance i
in Generic Letter No. 83-02.
(10)
Interlock on Recirculation Pump Loops (II.K.3.19)
The requirement applies to non-jet pump plants only and is, therefore, not applicable to the Peach Bottom i
design.
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(11)
Common Reference Laval (II.K.3.27)
The Standard Technical Specification applies to Technical Specifications with a figure defining reactor vessel water levels.
At Peach Bottom, all level instruments have been referenced to the same elevation; however, the Peach nottom Technical Specifications do not contain a figure defining reactor vessel water levels.
(12)
Manual Depressurization (II.K.3.45)
As stated in Generic Letter No. 83-02, no changes to Technical Specifications will be required.
Safety Evaluation This Application, as amended, does not reduce the requirements of the current Technical Specifications.
All of the proposed changes constitute additional Limiting Conditions of Operation, surveillance requirements, and administrative controls not presently included in the Technical Specifications, and are in the interest of enhancing safe operations and complying with the requirements of NUREG-0737.
Consequently, Licensee has concluded, in accordance with NRC Guidance (48 F.R.
14870) and the provisions of Section 50.92 of the Commission's regulations, h '
that thoco chengas do not involva c significant hazards consideration.
I The Plant Operating Review Committee and the Operation and Safety Review Committee have reviewed these proposed changes to the Technical Specifications, and have concluded that they do not involve an unreviewed safety question or a significant hazards consideration; and will not endanger the health and safety of the public.
Respectfully submitted, PHILADELPHIA ELECTRIC COMPANY
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By
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~Vic( President COMMONWEALTH OF PENNSYTNANI A as.
COUNTY OF PHILADELPHIA S.
T,. Dal trof f, being fi rst dul y sworn, deposes and says:
That he in Vice President of Philadelphia Electric Company, the Applicant herein; that he han read the foregoing Amendment to Application for Amendment of Facility Operatinq Licenses and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
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ll Subscribed and sworn to before me this 2 day of ama4 A Notary Public PATRICIA D. SCif0LL' Notary Putic. PhdadelpMa, PNtadelpMa Co.
My Commission E9tes february 10.1986
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