ML20012B573
| ML20012B573 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/08/1990 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20012B574 | List: |
| References | |
| GL-88-16, NUDOCS 9003150344 | |
| Download: ML20012B573 (20) | |
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PHILADELPHIA ELECTRIC COMPANY NUCLEAR GROUP HEADQUARTERS 955 65 CHESTERBROOK BLVD.
WAYNE, PA 19087 5691 (at s) sao-sooo March 8, 1990 Docket Nos. 50-277 50-278 License Nos. OPR-44 DPR-56 U.S. Nuclear Regulatory Commission AT'IN: Document Control Desk Washington, D. C. 20555
SUBJECT:
Peach Botton Atomic Power Station, Units 2 and 3 Technical Specifications Change Request
Dear Sir:
Philadelphia Electric Company hereby submits Technical Specifications Change-Request No. 89-21, in accordance with 10 CFR 50.90, requesting an amendment to the Technical Specifications (Appendix A) of Facility Operating License Nos. DPR-44 and DPR-56 for Peach Botton Units 2 and 3, respectively.
Information supporting this Change Request is contained in Attachment 1 to_this letter, and the proposed replacement pages are contained in Attachment 2.
A copy of this letter and each attachment has been mailed to T. M. Gerusky of the Pennsylvania Department of Environmental Resources in accordance with 10 CFR 50.91(b)(1).
These changes _ involve removal of cycle-specific parameter limits from the Technical-Specifications in accordance with the guidance provided in Generic Letter 88-16. The Company respectfully requests that the NRC complete its review of this
- application by May.15, 1990. This will make possible significant savings in fuel costs.for the Company.
If you have any questions regarding this matter, please do not hesitate to contact Mr. Frank Lear of my staff at (215) 640-6786.
Very truly yours, 90031 % $ h ooo277b G. A. Hunger f
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Ur.
PDR PNV ;
Director-Licensing Section P
Nuclear Services Department
Enclosure:
Affidavit Attachments 1, 2 cc:
'W. T. Russell, Administrator, Region I, USNRC l
J. J. Lyash, USNRC Senior Resident Inspector G. Y.: Suh, PBAPS USNRC Project Manager t
' - CiAWONWEALTH OF PENNSYLVANIA :
ss.
, COUNTY OF CHESTER D. R. Helwig, being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company; the Applicant herein; that he has read the Technical Specifications Change Request No. 89-21 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.
i t
Vice Presid t i'
Subscribed and sworn to M
before me this8 day of h hl1990.
0&klahlw 2 0 h>ltni Notary Public NOTARIAL SEAL CATHERINE A. MENDEZ. Notary Public j
Trecyffnn Twp.. Ches:er County i
My Commisson Exoires sect 4.1993
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ATTACHMENT 1 PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3
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Docket Nos. 50-277 e
50-278 4
r License Nos. DPR-44 DPR-56 TECHNICAL SPECIFICATIONS CHANGE REQUEST No. 89-21
" Removal of Cycle-Specific Parameter Limits Pursuant to
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Dock:t Nos. 50-277 50-278 s '
License Nos. DPR-44 DPR-56
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Introduction:==
The NRC issued Generic > Letter 88-16,-" Removal of Cycle-
-Specific Parameter Limits from Technical Specifications",
encouraging licensees to propose Technical-Specifications changes to eliminate the need for license amendments which are typically required prior to each core reload.
The NRC characterized these amendments as unnecessary since they merely change cycle-specific parameter limits which have been determined in_accordance with methodology previously approved by the NRC.
Philadelphia Electric Company (PECo) agrees with the NRC's position, as stated in Generic Letter 88-16,_that such amendments pose an unnecessary burden on licensees and the NRC.
Therefore, PECo hereby proposes that cycle-specific parameter limits be relocated from the Peach Bottom Technical Specifications to a PECo-controlled document, " Core Operating" Limits Report" (COLR), and that the Administrative Controls Section and Definitions Section of the Technical
. Specifications be augmented to address the COLR.
Accordingly, PECo also proposes that the appropriate Specifications be revised to replace the cycle-specific parameter limits with' references to the i
COLR.
This application conforms with-the guidance of Generic Letter 88-16:and,.ence approved, will eliminate the need for reload license amendments solely to update cycle-specific parameter limits.
PECo also proposes administrative changes to correct errors, achieve consistency and add references to new reports.
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-Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 4
Description ~of Changes:
.The1following proposed changes are common to the Unit 2 and Unit 3 Technical Specifications.
Page vi:
Replace the title of Tables 3.5.K.2 and 3.5.K.3 with the word " DELETED" and replace the page number for Table 3.5.K.3 with the number 133d.
Page 1:.
Add a new term, Core Operating Limits Report (COLR), to the Definitions Sect. ion with a corresponding definition consistent with Generic. Letter (GL) 88-m..
16.
Rather than using the term " reload' cycle" in the definition: as reconnended by GL 88-16, we have chosen to use the term " Operating Cycle" because it has the same meaning and is defined in the Technical Specifications Definitions, Section.
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Page.10, lla and 40:
Replace cycle-specific values of Maximum-Fraction of Limiting Power Density (MFLPD) with a reference to the COLR.
b-Docket Nos. 50-277 50-278
= License Nos. DPR-44 DPR-56 Page 73:
APRM Upscale (Flow Biased) Trip Level Setting: Move the notation for Note 2,
"(2)",
from the Trip Level Setting column to the left hand column so that it cannot i
be confused as being part of the Trip Level Setting equation.
Capitalize the "w"
in this equation for consistency.
Rod Block Monitor (Flow Biased) Trip Level Setting: Move the notation for Note 2,
"(2)",
from the Trip Level Setting column to the left hand column so that it-cannot be confused as being part of-the-Trip Level Setting equation.
Replace the cycle-specific maximum limit of 107% for this setting with a new
- variable, "N", which will be defined in the COLR.
This necessitates changing the quantity 41 in this equation to "(N-66)".
Add the notation "(11)" for this setting in the left hand column.
A'new Note 11 will be added to page 74a addressing the new variable N.
Page.74:
Replace the cycle-specific values of MFLPD with a reference to the COLR.
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L Docket-Nos. 50-277
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50-278 t
y License Nos. DPR-44 DPR-56 Page 74a Add new Note 11 stating that N on Table 3.2.C (page 73) is specified in the COLR.
T age 133a:
In the first sentence of Section 3.5.I P
replace the phrase "APLHGR limit values which have been approved" with the phrase "APLHGR limit values which have been I
determined by approved methodology."
This is consistent with GL 88-16 since i
the actual values will no longer be approved by the NRC.
In Section 3.5.I, replace reference to-Techn!. cal Specifications Average Planar Linear Heat Generation Rate (APLHGR)
-Figures and replace the cycle-specific values of reduction-factors with references to the COLR.
In Section 3.5.J, replace the cycle-specific values for Design LHGR with a reference to the COLR.
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Page-133b:
Replace the reference to Technical Specifications Figure for the Kg factor with a reference to the COLR.
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Docket Nos. 50-277-t.,.
50-278-License Nos. DPR-44 DPR-56
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Pages 133d and 133e:
Replace Table 3.5 K.2 on page 133d with a.
reference to the COLR and a statement that-the associated information from pages 133d and 133e has been relocated to the COLR.
Delete.Page 133e, which contains Table 3.5.K.3.
Page 140:
Correct typographical error in heading of Section 3.5.H as follows:
replace
" Engineering" with " Engineered".
Add reference to COLR pertaining to APLHGR Limits in Section 3.5.1.
Delete phrase "and least limiting" from third paragraph of Section 3.5.7 because.
the least limiting APLHGR curves will not be included in the COLR even-though they are currently included on the Figures being deleted from the Technical Specifications (Figures 3.5.1.M, 3.5.1.N and 3.5.1.0).
All of the APLHGR. values are loaded into the Process Computer and the-values of the-least limiting APLHGRs are of no operational safety concern.
Inclusion of the least limiting curve on the figures creates the possibility of an l
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DockGt No3. 50-277 O'
50-278 License Nos.-DPR-44 DPR-56 incorrect value being used at times when l
Technical Specification 3.5.1 requires the most limiting values to be applied to i
each lattice.
l Delete the word " approved" from the f
h phrase " lattice-specific, approved APLHGR M
limits" in the third paragraph of Section L
3.5.I.
The actual limits will no longer be approved by the NRC; the methodology i
for determining the limits will be approved.
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1PageJJ0a, Delete the "I"
from the heading "3.5.1 n
Bases (Cont'd)".
This is an editorial l
correction.
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In Section 3.5.K add reference to t
L Reference 10.
v Page.140c:
Add a new Reference (No. 10) which is a 4
PECo report that, once approved.by the s
NRC, will be applicable to Peach Bottom e
reloads.
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The following changes to the Unit 2 4echnical
. Specifications are proposed. !
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-c Dock 0t No3. 50-277 g.
50-278
-l License Nos. DPR-44 1
DPR-56 Page ivs-Replace the title of Figures 3.5.K.1-1, j
l-i 3.5.1.E and 3.5.1.H with the word l
" DELETED".
Replace the title of Figures 3.5.K.1-2, 3.5.K.1-3, 3.5.K.2-1, 3.5.K.2-2, 3.5.K.2-3 with the word " DELETED" and h
j replace the page number for each of these figures with the number 142.
Add Figure i
3.5.K.2 with " DELETED" in the title l
L column and the number 142 in the page column.
This figure exists in'the l
J Technical Specifications but is not on 1
i the list.
Even though the figure is l
being deleted, it should be shown on the p
-list for consistency.
Page ivat Replace the title of Figures 3.5.1.1,.
3.5.1.J, 3.5.1.K, 3.5.1.L, 3.5.1.M, 3.5.1.N and 3.5.1.0 with the word r
" DELETED" and replace the page number for f.
each of these Figures with the number
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L 1429 Page 17:
Replace "NEDE-24011-P-A (as amended)"
m with " References 2 and 3."
NEDE-24011-P-A is being placed on page 24 as Reference 2 and Reference 3 is a new PECo report. ;
DockOt No3. 50-277 I
,. m 50-278 L
. License Nos. DPR-44 L:
DPR-56 Page 24:
Add References 2 and 3.
Reference 2 is i
i merely being relocated from page 17 and j
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Reference 3 is a recently developed PECo t
F report which, once approved by the NRC,
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i will be applicable-to Peach Bottom t
reloads.
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Page 133c:
In Sections 3.5.K.2 and 3.5.K.3, replace references to Technical Specifications Tables and Figures for Minimum Critical t-Power Ratio (MCPR) Operating Limits with references to the COLR.
Correct typographical error in Section 4.5.K.2.c as follows: change "Ni" to "N1" in the numerator of the 1 B equation and in the definition of terms for the 15 B equation.
This error was introduced inadvertently by Amendment-Number 86.
Page 140b Add reference to Reference 10, a new PECo:
report.
Correct typographical error in first paragraph of Section 3.5.L as follows:
add hyphen after " Traversing In-Core Probe."
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- p1h, DockGt No3, 50-277 o
t-50-278 Licence Nos. DPR-44 DPR-56 t
'I Page 141a and 141b Add reference to the COLR in third paragraph of Section 4.5.L (page 141a)
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and last paragraph of Section 4.5.L (page i
141b).
The text on page 141b has been relocated N
onto page 141a; therefore, page 141b can l
be deleted.
i Pages 142, 142a and 142a-1 through-142a-5:
Replace Figure 3.5.K.1-1 on page 142 with a reference to the COLR and a statement that the associated information from this page, page 142a and pages 142a-1 l
through 142a-5 has been relocated
-f to the COLR.
Delete pages 142a h
and 142a-1'through 142a-5, which contain Figures 3.5.K.2, 3.5.K.1-2, 3.5.K.1-3 i
3.5.K,2-1, 3.5.K.2-2 and 3.5.K.2-3, respectively.
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i Page'142d Replace Figure 3.5.1.E with a reference to the COLR and a statement that the l
associated information has been relocated to the COLR.
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DockGt No3, 50-277
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50-278 i=
License Nos. DPR-44 DPR-56 i
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Pages 142g through 142n Replace Figure 3.5.1.H on page 142g with a reference to the COLR and a statement that the associated information from 4
pages 1429 through 142n has been L
relocated to the COLR.
Delete pages 142h n
ja through 142n, which contain Figures 3.5.1.I, 3,5.1.J, 3.5.1.K, 3.5.1.L, 3.5.1.M, 3.5.1.N and 3.5.1.0, l
l respectively.
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Pages 256 and 256a1 Add " Unit 2", "PBAPS" and "(Cont'd)" to h
top of page for consistency.
Add new Specification 6.9.1.e, establishing the administrative requirements applicable to'the COLR as
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recommended by GL 88-16.
Rather than using'the term " reload' cycle" as i
recommended by GL 88-16, we have chosen to use the term " Operating Cycle" because it has the same meaning and is defined in i
the Technical Specifications Definitions' Section.
New Specification 6.9.1.e continues onto page 256a which currently is "left blank intentionally".
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DockOt No3. 50-277 50-278 License Nos. DPR-44 DPR-56 The following changes to the Unit 3 Technical specifications are proposed.
t Page iv Replace the title of Figure 3.5.K.1 with the word " DELETED".
Replace the title of Figures 3.5.K.2, 3.5.1.E, 3.5.1.F.
3.5.1.G, 3.5.1.H, 3.5.1.1, 3.5.1.J and 3.5.1.K with the word " DELETED" and replace the page number for each of these figures with the number 142.
Page 17:
Replace "NEDE-24011-P-A (as amended)"
with " References 4 and 5."
NEDE-240ll-P-A is being placed on page 24 as Reference 4 and Reference 5 is a new PECo report.
Page 24:
Add References 4 and 5.
Reference 4 is merely being relocated from pago 17 and Reference 5 is a recently developed PECo report which, once approved by the NRC, will be applicable to Peach Bottom reloads.
Page-133c:
In Sections 3.5.K 2 and 3.5.K.3, replace references to Technical Specifications Tables and Figures for MCPR Operating Limits with references to the COLR.
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50-278 i
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License Nos. DPR-44 DPR-56 Page 140b Add reference to Reference 10, a new PECo report.
P, age 341a and 141b:
Add reference to the COLR in third paragraph of Section 4.5.L (page 141a) and the last paragraph of Section 4.5.L (page 141b).
Correct misspelling of the word point ("poing") in the fourth paragraph of Section 4.5.L (page 141b).
The text on page 141b has been relocated onto page 141a; therefore, page 141b can t
be deleted.
Page 142, 142a and Replace Figure-3.5.K.1 on page 142 142d through 1423:
with a reference to the COLR and a statement that the associated information from this page, page 142a and pages 142d through 142j has been relocated-to the COLR.
Delete pages 142a and 142d through 142j, which contain Figures 3.5.K.2, 3.5.1.E, 3.5.1.F, 3.5.1.G, 3.5.1.H, 3.5.1.I, 3.5.1.J and 3.5.1.K, respectively.
Pages.256 and 256a:
Add " Unit 3", "PBAPS" and "(Cont'd)" to top for page of consistency.
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o DockOt No3. 50-277 o
50-278 License Nos. DPR-44 DPR-56 l
l Add new Specification 6.9.1.e, identical to that proposed for Unit 2.
New-Specification 6.9.1.e continues onto page 256a which currently is "left blank intentionally."
i Safety Assessment:
I The proposed Technical Specification changes will not l
Impact safety because the Technical Specifications will still require that the reactor be operated within limits established using NRC-approved methodology and consistent with applicable limits of the Updated Final Safety Analysis Report (UFSAR).
PECo has conformed to the guidance of GL 88-16 in preparing this application.
As GL 88-16 recommends, PEco has proposed the following changes to the Technical Specifications:
(1) the addition of the definition of a named formal report that includes the values of cycle-specific parameter limits that have been established using an NRC-approved methodology and consistent with all applicable limits of the safety analysis, (2) the addition of an administrative reporting requirement to submit the formal report on cycle-specific parameter limits to the Commission for information, and (3) the modification of individual Technical Specifications to note that cycle-specific parameters shall be maintained within the limits provided in the l
defined formal report.
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Dockot Nos. 50-277 50-278 i
License Nos. DPR-44 DPR-56 i
The proposed changes are administrative in nature since the limits within which the reactor is operated are not being changed the actual values of the limits are merely being relocated to a different document. 'The establishment of these limits in accordance with NRC-approved methodology and the incorporation of these limits p
into the COLR will ensure that the proper steps have been taken to i-establish the values of these limits.
Furthermore, the submittal of the COLR will allow the NRC staff to continue to trend the values of these limits without the need for prior staff review and approval of these limits and without the introduction of an unreviewed safety.
question.
The removal of the requirement to have the fuel bundle and lattice specific APLHGR limit values previously approved by the NRC staff (page 133a) is in keeping with the desire to limit the processing burden on the licensee and NRC because the limits are-determined using NRC approved methodology and, thus, is consistent with GL 88-16.
The addition of. references to PECo methodology reports will allow a smooth transition from GE analysis methods to PECo analysis methods without the need for another license amendment.
Before the limits determined by the PEco methods may be used, the methods must be approved by the NRC.
Other miscellaneous administrative changes are minor and have no impact on plant equipment or operations.
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L DockGt Nos. 50-277 o.
50-278 License Nos. DPR-44 DPR-56 Significant Hazards Consideration Determination:
i PECo proposes that the changes requested herein do not involve significant hazards considerations for the following reasons:
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The proposed revisions do not involve a significant increase in the probability or consequences of an accident i.
previously evaluated because these changes do not alter the requirement that the plant be operated within the limits for the cycle-specific parameters, nor do they alter the required immediate actions that must be taken when these limits are not met.
These changes will have no effect on plant operations or equipment reliability.
No hardware changes are required to any system.
Since the parameter limits will still be calculated by NRC-approved methodology, this change is administrative and all accidents will still be bounded by the analyses described in the UFSAR.
11)
The proposed revisions do not create the possibility of a new or different kind of accident from any accident previously evaluated because no hardware modifications are required to implement this change.
The plant will still be operated within limits established using NRC-approved methodology and the plant remains bounded by the assumptions of the UPSAR.
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DockCt Noo. 50-277 o
c0-278 I
License Nos. DPR-44 DPR-56 lii) The proposed revisions do not involve a significant reduction in a margin of safety.
The margin of safety relative to each cycle-specific parameter limit is determined by the method of analyses for establishing each limit.
These methods are previously approved by the NRC to l
ensure that the bases for each specification will be met by the analysis.
This change requires that the methodology used for these limits be previously approved by the NRC and that the methods are listed in the Administrative Section of the Technical Specifications.
Since the methodology will maintain the limits within the margin of safety required by the Technical Specification Bases, this change will have no effect on any margin of safety as analyzed in the UFSAR or as defined in the Technical Specification
' Bases.
Environmental Considerations:
An environmental assessment is not required for the changes requested by this Application because the requested changes conform to the criteria for " actions eligible for categorical exclusion" as specified in 10 CFR 51.22(c)(9).
The requested changes have been shown by this Application not to adversely affect the systems and equipment that prevent the uncontrolled release of radioactive material to the environment.
The Application involves no significant hazards consideration as determined in the preceding DockGt No3. 50-277 50-278 License Nos. DPR-44 DPR-56 p
section..The Application involves no significant change in the type j;
or significant. increase in the amount of any effluents that may be released offsite, and there will be no significant increase in
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- individual or cumulative occupational: radiation exposure.
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Conclusion t
The Plant Operations Review Committee'and the Nuclear Review Board have reviewed these. proposed changes to the Technical H
Specifications and determined that they do not' involve an Unreviewed.
Safety Question and will not endanger the health and safety of the public.
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