ML20093G013
| ML20093G013 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/05/1984 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20093F989 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.1, TASK-2.B.3, TASK-2.D.3, TASK-2.F.1, TASK-2.K.3.13, TASK-2.K.3.22, TASK-TM GL-83-36, NUDOCS 8410150306 | |
| Download: ML20093G013 (23) | |
Text
l BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 l
SECOND AMENDMENT TO FEBRUARY 11, 1982 APPLICATION FOR AMENDMEHT 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 i
t 8410150306 841009 PDR ADOCK 05000 e
l BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 SECOND AMENDMENT TO FEBRUARY 11, 1982 APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 & DPR-56
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On February 11, 1982, Philadelphia Electric Company, Licensee under Facility Operating License DPR-44 and DPR-56 for Peach Bottom Units 2 and 3, filed an Application for Amendment of the Licenses 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 1
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systems was required by NUREG-0737, " Clarification of TMI Action Plan Requirements", issued to all licenses on October 31, 1980.
On April 26, 1982, in a telephone conversation with the NRC project manager, Licensee was requested to consider the Standard Technical Specifications enclosed with Generic Letter l
No. 83-02 for several NUREG-0737 items.
Consequently, to conform its earlier Application to the Standard Technical Specifications i
to the extent applicable, Licensee, on August 24, 1983, amended J
its Application of February 11, 1982, by adding:
(1) personnel overtime work requirements, (2) reporting requirements for the primary coolant system safety relief valves, (3) a specification that 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 l
transfer feature.
4 4-In Generic Letter No. 83-36, dated November 1, 1983, the NRC provided Standard Technical Specifications for NUREG-0737 items not addressed in the_ previous guidance (Generic Letter No.
83-02).
A review of the technical specifications proposed in our February 11, 1982 Amendment Application indicates several inconsistencies with the most recent NRC guidance.
Accordingly, Licensee hereby further amends its Application of February 11, 1982 by (1) deleting the proposed revised Technical Specification pages 77, 77a, 86a, 93, 209a, and 209b referred to in the February 11, 1982 Application; (2) substituting therefor updated 2
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pages lii, 77, 77a, 78, 86a, 93, 93a, 172, 173, 194, 233, and 233a; and (3) adding new pages 78a, 268 and 269, The revisions are indicated by a vertical bar.
Changes to the existing Technical Specifications, which were proposed on pages 69, Bla, and 86 of the February 11, 1982 Application, remain unchanged by this Amendment to the Application.
A point-by point discussion of Licensee's response to the guidance in Generic Letter No. 83-36 follows:
(1)
Reactor Coolant System Vents (II. B.1) f The Peach Bottom BWR-4 design does not have an isolation condenser, and therefore no changes in the Technical Specifications are required for this NUREG-0737 Action Plan item.
(2)
Postaccident Sampling (II.B. 3 )
Proposed Specification 6.19 on page 268 conforms with the Standard Technical Specifications (Generic Letter No. 83-36, Enclosure 3, page 5) establishing administrative controls for the operation, maintenance, and training associated with the postaccident sampling system.
(3)
Noble Gas Effluent Monitors (II.F.1.1)
The proposed operability and surveillance requirements for the high range noble gas effluent radiation 3
monitors as shown on proposed Technical Specification pages 77a, 78, and 86a conform to the Standard Technical Specifications. (Generic Letter No. 83-36, Enclosure 3, pages 7, 8, and 9).
(4)- Sampling and Analysis of Plant Effluents (II.F.1. 2)
Proposed Specification 6.19 on page 268 conforms with the Standard Technical Specifications (Gene ric. Le tte r No. 83-36, Enclosure 3, page 5). establishing administrative controls for the operation, maintenance, and training associated with the radioactive iodine and particulate sampling systems.
(5)
Containment High-Range Radiation Monitor (II.F.1. 3)
The proposed operability and surveillance requirements for the high range drywell radiation monitors as shown on proposed Technical Specification pages 77a, 78, and 86a conform to the Standard Technical Specifications s
(Generic Letter No. 83-36, Enclosure 3, pages 7, 8, and 9).
(6)
Containment Pressure Monitor (II.F.1. 4 )
Drywell pressure is monitored by two instrument channels with a range of 0 to 70 psig, and two channels with a range of 0 to 225 psig.
The STS addresses only the wide range (0-225 psig) 'drywell pressure instrument.
Currently, the Peach Bottom Technical Specifications (page 77) address r
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only the pressure instrument with a 70 psi range.
Licensee proposes to leave the specification for the 70 psi i
instrument in the Technics 1 Specif cations and add specifications for the wide range instruments, with an action statement for inoperability that is a modified version of the guidance in the STS (Generic Letter No. 83-36,- Enclosure 3, page 8).
The proposed action statement (page 78a) would conform to the STS, unless both 70 psi drywell pressure instruments are operable, in which case 4
additional outage time for the 225 psi instrument would be permissible.
The bases for the proposed action statement associated with inoperability of the 225 psi-range drywell pressure instrument are as follows:
1.
The proposed action statement recognizes the 1
presence of two operable 70 psi range pressure instruments that are under the control of the Technical Spe.cifications.
2.
The 70 psi range pressure instruments monitor the full pressure transient spectrum associated with the design basis accidents.
The existence of pressures above 70 psig are beyond the design basis of the plant and represent an extremely low probability event.
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t 3.
The STS proposes an instrument check frequency of once per month.
When combined with the STS 4
allowable outage periods of 7 days and 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (one and two inoperable instruments, respectively),
the potential maximum outage would be 37 days for one inoperable wide range instrument, and 32 days for two. inoperable wide range instruments.
The proposed specification for Peach Bottom would specify a daily surveillance check (page 86 in the February 11, 1982 Application), and allowable outage periods of 30 days and 7 days for one and two inoperable instruments, respectively.
This would result-in a potential maximum outage of 31 days for one inoperable instrument, and 8 days for two inoperable instruments.
Consequently, the proposed specification would result in a shorter potential period of instrument inoperability.
The same action statement is proposed for the F
subatmospheric drywell pressure instrument for the i
reasons presented above for the 225 psi instrument.
The following table summarizes the proposed changes:
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o LCO SHUTDOWN COMPARISON Drywell Pressure One Inoperable Both Inoperable Instrument Current Proposal Current Proposal Drywell Pressure 30 days 30 days 7 days 7 days (0-70 psig)
Drywell Pressure _
Shutdown 30 days if Shutdown 7 days if (wide range)
Not Required
-both 0-70 Not Required both 0-70 psig operable.
psig operable 7 days if a 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> if 0-70 psig a 0-70 psig inoperable inoperable Drywell Pressure Shutdown Same as Shutdown Same as j.
(subatmospheric)
Not Required wide range Not Required wide range I
(7)
Containment Water Level Monitor (II.F.1. 5)
Containment water level is monitored in the suppression chamber by two instrument channels with a range of 1 to 21 feet from the bottom of the chamber and two channels with a range of 2 feet centered around the normal 2jj water level.
The STS addyesses only the wide range (1-21 ft.) level instrument.
Currently, the Peach Bottom Technical Specifications (page 77) addresses only the narrow range level instrument.
Licensee proposes to leave a specification for both narrow range level instruments in the Technical Specification and add specifications for the wide range level instruments, with an action statement for inoperability that is a modified version of the guidance in the STS (Generic Letter No. 83-36, Enclosure 3, page 8).
The proposed action statement (page 78a) would conform to the STS, unless both narrow ran'ge level instruments are I
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operable, in which case additional outage time for the wide range level instrument would be permissible.
The bases for the proposed action statement associated with inoperability of the wide range containment water level monitor are as follows:
-1.
.The proposed action statement recognizes the presence of two operable narrow range suppression chamber water level instruments that are under the control of the Technical Specifications.
2.
The STS proposes an instrument check frequency of l
once per month.
When combined with the STS I
allowable outage periods of 7 days and 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (one and two inoperable instruments, respectively),
the potential maximum outage would be 37 days for one inoperable wide range instrument, and 32 days for two inoperable wide range instruments.
The proposed specification for Peach Bottom would specify a daily surveillance check (page 86 in the February 11, 1982 Application), and allowable outage periods of 30 days and 7 days for one and two inoperable instruments, respectively.
This would result in a potential maximum outage of 31 2
days for one inoperable instrument, and 8 days for two inoperable instruments.
Consequently, the 8
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proposed specification would result in a shorter potential period of instrument inoperability.
Additionally, Licensee proposes a revision in the action statement for the narrow range suppression chamber e
water level instruments.
Currently,-if both channels of the narrow range instrument are inoperable, a plant shutdown shall be initiated within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
The proposed revision would permit both instruments to be inoperable for 7 days.
The bases for the proposed revision are as follows:
1.
Unlike the wide range suppression chamber water level instruments, the narrow range instruments are not safety-related equipment due to their limited range.
P-2.
The proposed revision would establish uniformity with action statements for other surveillance instrumentation, and therefore improved clarity and i
reduces the potential for misinterpretation of the l
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3.
The proposed action statement recognizes the l-i presence of the wide range instruments that are l
under the control of the Technical Specifications.
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The following table summarizes the proposed changes:
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LCO SHUTDOWN COMPARISON Suppression Chamber One Inoperable Both Inoperable Water Level Instrument Current Proposal Current Proposal Narrow Range 30 days 30 days 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 7 days (0-2 f t.)
Wide Range Shutdown 30 days if Shutdown 7 days if (1-21 f t. )
Not both narrow Not both narrow Required range Required range operable.
7 days if 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> a narrow if a narrow range range inoperable, inoperable.
(8)
Containment Hydrogen Monitor (II. F.1. 6 )
The proposed operability and surveillance requirements for the drywell hydrogen concentration analyzer and monitor, as shown on proposed Technical Specification pages 77a and 86a, conform to the Standard Technical Specifications (Generic Letter No. 83-36, Enclosure 3, pages 7, 8 and 9).
Further, Licensee requests that the current specifications regarding this instrument be deleted from Technical Specification pages 172, 173 and 194, since these specifications are superseded by the proposed specifications on pages 77a and 86a.
Additionally, Licensee requests that an obsolete surveillance provision on the bottom of page 172 (identified by an asterisk) be deleted.
As established in Amendments 24 and 23 for Peach Bottom Units 2 and 3, respectively, f
specification 4.7.A.6.c, marked with an asterisk, will apply 10 L
. prior to the end of the first refueling outage of each unit.
After the end of the first refueling outage for each unit, only that portion of specification 4.7.A.6.c marked with a double asterisk would apply.
The amendment was written in this manner to accommodate the installation of the Containment Atmosphere Dilution System during the first refueling outage.
The double asterisk applied to the current surveillance requirement on page 173.
Amendments 69 and 68 for Peach Bottom Units 2 and 3, respectively, removed the obsolete footnotes from pages 173 and 174.
Amendments 71 and 69 for Peach Bottom Units 2 and 3, respectively, removed the double asterisk from the current surveillance specification on page 173.
The request to delete the provision identified by a single asterisk on page 172 will complete the removal of these obsolete specifications.
f (9)
Control Room Habitability Requirements (III. D. 3. 4)
The NRC guidance in Generic Letter No. 83-36 requests that if the results of the utility's analysis of a postulated accidental release of toxic gases indicated a need for installing the toxic gas detection system, it should be included in the Technical Specifications.
Licensee's analysis pursuant to NUREG-0737, Item III.D.3.4 concluded that the only hazard to control room habitability was the storage of ghlorine gas on site associated with the river water chlorination system.
Subsequently, in r
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accordance with Licensee's commitment in correspondence dated April.2, 1981 (J. W. Gallagher, PECo, to D. G.
Eisenhut), a sodium hypochlorite system has been installed and the chlorine gas removed from the site.
Consequently, a toxic gas detection system is not required to ensute control room habitability.
The modification to the chlorination system was the only design change deemed to be necessary to comply with Item III.D.3.4.
Licensee's actions on this issue-were approved by correspondence dated June 7, 1982 (J.
F. Stolz, ERC, to E. G. Bauer, Jr., PECo).
Further, the NRC guidance specified that two independent control room emergency air filtration systems should comply with the operability requirements in the Standard Technical Specifications.
Licensee was previously requested to modify its license to conform with an earlier version of the STS in regards to the operability requirements of the control room emergency air filtration systems.
Consequently, Amendments 9 and 7 to the Peach Bottom Operating License, Units 2 and 3, respectively, were issued on June 25, 1975.
Apparently, the STS has since been revised, and the Generic Letter has the effect of requiring a second revision to the Operating License regarding the specifications for this system.
Accordingly, Licensee proposes revisions to the Limiting Conditions For Operation as shown on pages 233and 233a for the control room emergency 12
1 air filtration that conform to the operability requirements of.the Standard Technical Specifications.
The changes requested would:
a.
Require suspension of core alterations, handling of irradiated fuel in the secondary containment, and operations with a potential for draining the reactor vessel if the operability requirements cannot be met.
The current Peach Bottom Technical Specifications requires only suspension of fuel handling operations.
b.
Require hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and cold shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if the operability requirements cannot be met.
The current Peach Bottom Technical Specifications requires cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Proposed Revision In Reference to Generic Letter 83-02 In Generic Letter No. 83-02, dated January 10, 1983, the NRC provided Standard Technical Specifications for several NUREG-0737 items, including the new automatic control' features for RCIC as required by NUREG-0737, Items II.K 3.13 and II.K.3.22.
By Amendment Application dated August 24, 1983, Licensee proposed changes that addressed this STS.
Subsequently, 13
the NRC staff reviewing the Application informed the licensee, by telephone, of the need to revise the Application to conform with the STS provided with Generic Letter No. 83-02.
Accordingly, Licensee hereby amends its Application of August 24, 1983 Application, and substituting therefor updated page 130.
The revision adds a surveillance requirement to verify the automatic transfer feature of the Reactor Core Isolation Cooling System suction.
Additionally, the temporary amendment change issued December 15, 1978 for Peach Bottom Unit 3 regarding continued power operation with an inoperable RCIC is now obsolete and is therefore deleted from proposed page 130.
Additional Amendment Requests 1.
Reactor Water Level Instrumentation The action statement for the zero to sixty-inch range reactor water level instrument on page 77 of the current Technical Specifications requires a plant shutdown within 7 I
days if one channel is inoperable and shutdown within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> if both channels are inoperable.
Licensee proposes an increase in the LCO shutdown provision to 30 days for one inoperable channel, and 7 days for two inoperable channels.
The bases for this revision are (1) the 0-60 inch reactor level instruments are not safety-related equipment, (2) the availability of safety-related reactor level instruments j
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(wide and fuel range), and (3) the compensatory measures provided by the proposal to strengthen the LCO action statements for the wide and fuel range level instruments.
By Application dated February 11, 1982, Licensee proposed the addition of the wide and fuel range reactor water level recorders.
The proposed action statement associated with these instruments would require a plant shutdown within 30 days if both channels were inoperable.
Since these instruments are safety-related and installed to meet the requirements of NUREG-0737, Item II.F.2, Licensee proposes to strengthen the LCO action statement as proposed in the following table:
LCO SHUTDOWN COMPARISON Reactor Water One Inoperable Both Inoperable Level Instrument Current Proposal Current Proposal Narrow Range 7 days 30 days 2 days 7 days (0-60 inches Wide Range Shutdown 30 days if 30 Days 7 days if
(-165 to Not Required both narrow (2-11-82 both narrow
+ 50 inches) range operable. application) operable.
7 days if a 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> if narrow range a narrow rang inoperable, inoperable.
Fuel Zone Shutdown 30 days if 30 day 7 days if
(-325 to Not Required both narrow (2-11-82 both narrow 0 inches) range application) range operab1(
48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> 7 days if if a narrow a narrow range range inoperable.
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1 2.
Reactor Pressure Recorder - Safety Parameter Display System j
J By correspondence dated April 15, 1984, Licensee
. committed to the addition of two reactor pressure recorders to the Safety Parameter Display Panel in the control room.
This modification is necessary to meet the requJrements of NUREG-0737, Supplement 1, and is supported by a safety analysis submitted September 28, 1983 (J. W. Gallagher, Philadelphia Electric Company, to D. G. Eisenhut, NRC).
Accordingly, Licensee proposes to incorporate the new reactor pressure recorders into Table 3.2.F (page 77) of the
-Technical Specifications.
The proposed action statement.
(page 78a) conforms to the STS, unless both of the other reactor pressure instruments are operable, in which case additional outage time for these instruments would be permitted.
1 3.
Effective Date of Amendment Licensee proposes that the once per-operating cycle surveillance requirements become effective during the first refueling outage, commencing four months after approval of this amendment application, and all other provisions of this application become effective four months after approval of this amendment application so as to accommodate the writing and approval of the appropriate procedures.
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The following table summarizes the revisions proposed by this application.
Tech Spec NUREG-0737 Page Requirement Specification 77 Reactor Water Level LCO 77 Reactor Pressure LCO 77 Drywell Pressure LCO 77 Suppression Chamber Water Level LCO
-77a
-Drywell Radiation Monitors LCO 77a Effluent Release Monitors LCO 77a Hydrogen Concentration Monitors LCO.
78 Surveillance Instrumentation Action Statements
.78a Surveillance Instrumentation Action Statements 86a Drywell Radiation Monitors Surveillance 86a Effluent Release Monitors Surveillance 86a Hydrogen Concentration Monitors Surveillance 93 Surveillance Instrumentation Bases 93a Surveillance Instrumentation Bases 130 RCIC Suction Transfer Surveillance 172 (Remove obsolete material) 173 (Remove obsolete material) 194 (Remove obsolete material) 233 Control Room Emergency Ventilation LCO 17 i-1
233a Control Room Emergency Ventilation LCO 268 Post Accident Sampling Administrative Controls 269 Post Accident Sampling Bases Since the February 11, 1982 amendment application submittal, pages 77,-77a, 78, 78a, 93a, and 130 have been revised by amendments 93, 97, and 100 for Unit 2, and amendments
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95, 99, and 102 for Unit 3.
The proposed pages submitted with this application reflect these approved revisions.
i Significant Hazards Consideration Determination 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, and surveillance requirements not presently included in the Technical Specifications, and are in the interest of enhancing safe operations and complying with the requirements of NUREG-0737.
The Commission has provided guidance concerning the application of the standards for determining whether license amendments involve no significant hazards considerations by providing certain examples. (48 FR 14870).
Two of the examples (11 and vii) of actions involving no significant hazards consideration ares (1) a change.that constitutes an additional limitation, restriction, or control not presently included in the 18 4
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technical specifications,'and (2) a change to make a license i
9 conform to changes in the regulations where the license change results in very minor changes to facility operations clearly in keeping with the regulations.
The changes proposed by t'. '.s application fit both of these examples of an action not involving a significant hazards consideration.
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, that these changes do not constitute a significant hazards consideration since they do not:
(1) involve a significant increase in the probability or consequences of an accident previously evaluated, or (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.-
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The Plant Operating Review Committee and the Nuclear Review Board (of f-site 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 hazard consideration and will not endanger the health and safety of the public.
Respectfully submitted, PHILADELPHIA ELECT C COMPANY
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l Vich President
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COMMONWEALTH OF PENNSYLVANIA :
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COUNTY OF PHILADELPHIA S. L. Daltroff, being first duly' sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company; that he has read the foregoing Application for Amendment of Facility Operating 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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Subscribed and sworn to til before me this 67ay bd \\T64 of bad u G.to o ;
Nota y'Publi PATRICIA A. JONES Notary Public, Phita., Phila. Co.
W Commteston Esp 6tes Oct.13,1986
CERTIFICATE OF SERVICE I certify tnat service of the foregoing Second Amendment was made upon the Commonwealth of Pennsylvania, by mailing a copy thereof, via first-class mail, to 'Ihomas R. Gerusky, Director, Bureau cf Radiological Protection, P. O.
Box 2063, Harrisburg, PA 17120; all this9th day of October, 1984.
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Euge[e X Bradley Attorney for Philadelphia Electric Company i
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