ML19332D104

Application for Amends to Licenses DPR-44 & DPR-56, Consisting of Tech Spec Change Request 89-15,incorporating Surveillance Requirement for Safety Grade Pnuematic Supply Sys Which Supplies Containment Purge/Vent Valve Seals

ML19332D104
Person / Time
Site:	Peach Bottom
Issue date:	11/22/1989
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19332D105	List: ML19332D104 ML19332D107
References
NUDOCS 8911300017
Download: ML19332D104 (13)

Text

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10.CPR 50.90 3 "Ij ' 4i

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PH'lLADELPH'IA ELECTRIC COM PANY- '

NUCLEAR GROUP HEADQUARTERS ~ -

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955-65 CHESTERBROOK BLVD. -

WAYNE, PA 19087 5691 .

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I November 22,'1989 ,

Docket Nos. 50-277 '

• ' 50-278-  ;

License Nos. DPR-44 DPR-56 l s

U.S.. Nuclear Regulatory Commission l

ATTN: Document Control Desk '

Washington, D. C. 20555 -

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SUBJECT:

' Peach Bottom' Atomic Power-Station, Units 2 and 3 H

Technical Specifications Change Request '

Dear Sir:

x Philadelphia Electric Company hereby submits Technical  ;

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-Specifications Change Request No.'89-15, in accordance with 10 CPR 50.90,.-requesting an amendment to the Technical Specifications (Appendix A)=of Operating License Nos. DPR-44 and DPR-56.

. Information supporting'this-Change Request is-contained in 1: Attachment 1 to this letter, and the proposed replacement pages are contained in Attachment 2.

~ This submittal' requests changes to the Technical-Specifications to incorporate a-Surveillance Requirement for the safety grade pneumatic supply system which supplies the containment purge / vent valve inflatable seals.

If you have any questions regarding this matter,.please 3 contact us.

Very trul yours, G. A. Hunger, Jr.

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Director Licensing Section 9911300017 PDR ADOCK $000 77 Nuclear Services Department 1

POC P

Attachments cc:- W. T. Russell, Administrator, Region I, USNRC 00N i

J. J. Lyash, USNRC Senior Resident Inspector * '

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G. Y. Suh, Project Manager, USNRC se ww- e e w fYa= w* Ww 71- p 3 =ge vp1* b Dv -m Se3-r 1rI- W- T F T 7 8*-e-e i7g- --7p v 9-w$77-Tr P FW"T"W

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COMMONWEALTH OF PENNSYLVANIA : .

as. . .

COUNTY OF CHESTER  :

LD.~R. Helwig, being first duly sworn, deposes and says: f t

That he is Vice'-President of Philadelphia Electric Company;

~that he has read Technical Specifications Change Request No. 89-15, i 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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Vice President

' Subscribed and sworn to

.before me thisal #day

-of'kWod1989. t do.d D Ah.

Notary-Public NOTARIAL SEAL -

CATHERINE A. MENDEZ. Notary Public Tredvffnn Two. Chester County My Comrrieston Excites Sect. 4.1993 -

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ATTACHMENT 1 ,

4 PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND'3 ..

Docket-Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 I i

TECHNICAL' SPECIFICATIONS CHANGE REQUEST NO. 89-15

" Incorporate'a Surveillance Requirement for the Safety

Grade-Pneumatic Supply System which Supplies the Containment Purge / Vent Valve Inflatable Seals" I

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• DockOt No2.=50-277

.. 50-278 't License Nos. DPR-44 ,

DPR-56 '

Philadelphia Electric Company (PECo), Licensee under

-Facility Operating Licenses DPR-44 and DPR-56 for Peach Bottom I

Atomic PowerLStation,: Units 2-and 3, hereby requests thatLthe Technical Specifications contained in Appendix A to the License be amended as indicated by a vertical bar in the margin of the pages in Attachment 2 and'11sted here:-172, 175, and 178a.

Description of Changes-Licensee proposes to incorporate into the Technical

' Specifications a surveillance requirement for the safety-grade pneumatic supply to the containment purge / vent valve inflatable- 1 seals.

In a l'etteridated November 21, 1984 concerning containment

_ purge and vent valves, the NRC stated its position that a Technical Specification.is required to demonstrate the. leak tight integrity of '

the-safety grade seal air supply system.  ;

Philadelphia Electric Company responded to this issue in a letter dated November 6, 1985 in which we proposed that in lieu of leakage testing requirements for the safety-grade seal air supply system which would rely on backup bottled nitrogen supplies, PECO

.would modify the system to connect the seal air supply system for the Containment Atmospheric Dilution System (CADS) and Containment E

Atmospheric Control System (CACS) valves to the existing CADS 6000 i  !

v.: 3 s

, Docket No2.c50-277 i

-' 50-278 License Nos. DPR-44 DPR-56  !

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>; gallon;11guld nitrogen storage tank.- This hard-piped safety grade pneumatic supply would beEinstalled to each of the valves and would .

1 replace: the individual bottle supplies. Additionally, we proposed that a surveillance requirement which-demonstrates. operability of .

the safety grade pneumatic supply be incorporated into the Technical .

-Specifications.

7,n Technical Specification Amendment No. 144 and 146 dated May 8, 1989, which incorporated specifications for large primary ~ t containment purge / vent isolation valves, the NRC staff found the- ,

. proposed. modification for the safety grade pneumatic supply as <

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discussed in the November 6, 1.985 letter acceptable and requested that PEco submit to the NRC a proposed Technical Specification which addresses the surveillance requirement. .:

This Technical Specification Change Request satisfies the request of-the May 8, 1989 letter. The additional surveillance-requirement originally proposed by PECo'in the November 15, 1985 letter has been modified in this change request to more clearly specify the surveillance to be performed. A change to an existing surveillance requirement is also requested as a result of the l

safety grade pneumatic supply modification.

Also included in the May 8, 1989 Amendment was a typographical error in which the word "or" was missing from l Surveillance Requirement 4.7.B.2.b of the Unit 3 Technical a

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.-Specifications... Correction of this error is being requested by this' l-

• Technical Specification Change Request. ,

List'of Proposed Page Changes: .

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Page (Unit) Change =

i Page'178a.'(Unit 2 and 3) -Add proposed-Surveillance-

, Requirement:4.7.E.3 which- [

states: "The valve operator-and inflatable seal safety-

, grade backup pneumatic: supply -

system shall'be demonstrated operable for the isolation L.

valves with backup nitrogen supply from the Containment i3 Atmospheric Dilution System i y (CADS) nitrogen storage tank  ;

-by:

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a. Verifying at least once per day that the CADS nitrogen storage tank L contains a minimum of 2500 gallons.

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Dockst No2. 50-277

, 50-278 l License Nos. DPR-44

• Jk DPR-56

b. Once per operating cycle, conduct a functional test that. demonstrates the operability of the backup (CADS _ tank) nitrogen supply ~

system upon loss of the normal supply. system."

Page 172-(Units 2 and 3) Change the minimum liquid Specification 3.7.A.6.b nitrogen requirement for ,

the post-LOCA Containment Atmosphere Dilution System from 2000-gallons-to

, 2500 gallons.

Specification-4.7.A.6.b Revise the surveillance requirement for recording the level in the liquid nitrogen storage tank on a weekly basis to refer to the proposed specification 4.7.E.3.a which requires daily verification of the nitrogen storage tank volume.

f The revised specification

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' Dockot Nos. 50-277- '

3', 50-278-License:Nos. DPR-44 DPR-56 will read "The level in the' s

liquid nitrogen storage tank shall be verified'in' accordance with Specification j

4.7.E.3.a."  !

Page-175 (Unit 3)- Add the word-"or" such

,': Surveillaace Requirement 4.7.B.2.b that the statement : reads .

" Cold DOP testing shall be performed -'

after each complete or partial replacement of the HEPA filter bank or after any structural .

maintenance on the system housing."-

Safety Assessment:

The proposed Technical Specification incorporates a

' surveillance requirement which will demonstrate the operability of the safety-grade pneumatic supply system for the containment purge / vent inflatable seals. The acceptability of this new system

'is discussed in Technical Specification Amendment Nos. 144 and 146, dated May 8, 1989. In the May 8, 1989 letter, the NRC requested PECo'to submit a proposed Technical Specification that addresses the '

surveillance requirement.

, Docket No2. 50-277

' 50-278 j License Nos. DPR-44 -

DPR-56 -

p During accident; conditions,-the air supply to the CADS and ,

CACS. valve inflatable seals is maintained by either the normal

, instrument air system or the_new safety grade backup CADS supply.

• All but minor leaks would be evident by observation or loss of' CADS

nitrogen inventory.- Minor leaks are not a safety concern during ,

accident conditions since the storage tank is accessible and can be recharged.from liquid nitrogen tanker delivery trucks. The surveillance requirement proposed in this amendment ensures that the-nitrogen: supply is monitored on a daily basis and that a once per operating cycle functional test which demonstrates operability of

'the new system ir performed. . The proposed minimum CADS tank liquid nitrogen inventory of 2500 gallons for Technical Specifications

• 3.7.A.6.b and 4.7.E.3 is based upon the following.

1)' 2000 gallons - The total volume of liquid nitrogen required for combustible gas dilution in containment for the first eight (8) days following a Loss of Coolant Accident (LOCA), .

and

2) 500' gallons - The total volume of liquid nitrogen required to account for the safety grade pneumatic supply system leakage during a four (4) hour failure of the pressure control valve, the volume required for the safety grade pneumatic supply system operation for a seven day accident period, and an additional twenty-five (25) percent safety margin.

, Docket Nos. 50-277

, 50-278 Lice'nse Nos. DPR-44 DPR-56 The proposed change.to Technical Specification 4.7.A.6.b, which currently requires weekly verification of the nitrogen storage tank. level,.is to refer to the new proposed Technical Specification _.

' 4.7.E.3.a which requires daily' surveillance of the tank inventory. J

' This change would eliminate a redundant surveillance and reduce the opportunity for misinterpretation of a surveillance requirement.

The. proposed change to a more frequent surveillance is more restrictive than the current requirement and therefore does not decrease safe operation of~the plant.

The change to Surveillance Requirement 4.7.B.2.b regarding testing _of the Standby Gas Treatment System was approved as requested in Amendment No. 144 for Unit 2. The word "or", however, was'omitted from the Unit 3 Surveillance Requirement which was issued on the same date in' Amendment No. 146. Inclusion of the word "or" in Surveillance Requirement 4.7.B.2.b which has been previously approved by the NRC is an administrative correction of an error and l

will not affect safe operation of the nuclear unit.

Information Supporting a Finding of No l

Significant Bazards Consideration l

The Commission has provided guidance concerning the

l. application of the standards for determining whether license

[ amendments involve significant hazards considerations by providing l-certain examples (51 FR 7751). One of the examples of amendments I

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' Dockst Nos. 50-277.

, 50-278-License Nos. DPR-44

DPR .

that are considered not likely to involve significant hazards consideration is "(11) a change that constitutes an additional limitation, restriction or control not presently included in the  !

technical specifications, e.g., a more stringent surveillance requirement." The proposed changes to the Technical Specifications 3.7.A.6.b, 4.7.A.6.b, and 4.7.E.3 impose additional control not presently included'in the_ Technical Specifications. Another example

'(Example i) of a change that involves no significant hazards $

considerations is a " purely administrative change to technical specifications:-for example, a change-to achieve consistency throughout the technical specifications, correction of an error, or-

- a. change in nomenclature". The proposed change to Technical Specification 4.7.B.2.b to add the word "or" is a purely

. administrative change to correct an error.as discussed'in the Safety e Assessment.

The proposed changes to the Peach Bottom operating licenses -

E do not constitute a significant hazards consideration in that they

.do not: '

l i) Involve a significant increase in the probability or I-consequences of an accident previously evaluated.

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The proposed Technical Specification changes provide L additional means of ensuring operability of the new safety

[ grade pneumatic supply system and correct an administrative L

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, Dockot-Nos.1 50-277

' 278- l License Nos. DPR '

DPR-56

. error. .These changes serve to enhance plant safety and would not involve a significant increase in the probability or consequences of an accident as previously evaluated in Chapter 14 of the PBAPS Updated Final Safety Analysis Report.

, . 11) Create the possibility of a new or different kind of accident from any accident'previously evaluated.

The implementation of the new safety grade pneumatic supply 1 1

system was reviewed and accepted by the NRC. 2

-Implementation of-a surveillance requirement to demonstrate an adequatefsupply of liquid nitrogen and operability.of  ;

P the system will not create the possibility of a new or.

different kind of accident from any previously evaluated.

The correction of an administrative error will not' create the possibility of a new or different kind of accident from any previously evaluated.

l iii) Involve a significant reduction in a margin of safety.

} The proposed surveillance provides additional assurance i-

e. that the new safety grade pneumatic supply system will l-1:

function as designed; thus, there is no reduction in a margin of safety. The correction of an administrative error does not reduce a margin of safety.

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Docket Nos. 50-277

,_ 50-278 License Nos. DPR-44 DPR-56 i

Information Supporting an Environmental Impact Assessment:

An environmental impact assessment is not required for the

. changes proposed by this Application because the changes conform to ,

the criteria for " actions eligible for categorical exclusion" as ,

specified in 10 CPR 51.22(c)(9). The Application involves no significant hazards consideration as demonstrated in the preceding section. The Application involves no significant change in the

. types or significant increase in the amounts of any effluents that may be released offsite, and there is no significant increase in.

I individual or cumulative occupational ~ radiation exposure.

Conclusion The Peach Bottom Plant Operations Review Committee and the Nuclear Review Board have reviewed the proposed changes to the Technical Specifications-and have concluded that they do not involve an unreviewed safety question and will not endanger the health'and ,

safety of the public.

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