ML20065H998

Proposed Tech Specs for Incorporation of EOC MCPR RPT Sys & Replacement of motor-generator Sets W/Adjustable Speed Drives

ML20065H998
Person / Time
Site:	Peach Bottom
Issue date:	04/06/1994
From:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML19304B974	List: ML20065H992 ML20065H998
References
NUDOCS 9404150246
Download: ML20065H998 (15)

Text

.

ATTACHMENT 2 PEACH BOTTOM ATOMIC POWER STATION UNIT 2 Docket No. 50-277 License No. DPR-44 TECHNICAL SPECIFICATION CHANGES List of Attached Pages Unit 2 60a 93b 141a e 213 240k 240m  ;

240n 2400 .;

240r l

9404150246 940406 PDR ADOCK 05000277 1 p-PDR i

Unit 2 PBAPS LIMITED CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS H. Minimum Critical Power Ratio (MCPR) H. Minimum Critical Power Ratio (MCPR)

Recirculation Pump Trio (RPT) Recirculation Pump Trio (RPT)

Instrumentation Instrumentation

1. When Thermal Power is > 30% of 1. When a MCPR-RPT channel is placed Rated Thermal Power, in an incperable status solely for performance of required

a. two channels per trip system Surveillances, entry into for each MCPR-RPT Specification 3.2.H.2 may be instrumentation function listed delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> below shall be operable: provided the associated function maintains MCPR-RPT trip

1) Turbine-Stop Valve (TSV) capability.

Closure with trip level setting s 10% closed; and 2. Each MCPR-RPT Instrumentation Channel shall be demonstrated

2) Turbine Control Valve (TCV) operable by:

Fast Closure trip level setting 500<P<850 psig. a. Performing a Channel Functional Test once per 92

b. or, if one or more required days; MCPR-RPT channels are inoperable, restore the channel b. Performing a Channel to operable status within 72 Calibration once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or place the channel in months; trip.*

c. Performing a Logic System a

c. or, if one or more functions functional test including are inoperable with MCPR-RPT breaker and Adjustable Speed trip capability not maintained, Drive (ASD) stop circuit then restore the MCPR-RPT trip actuation once per 24 months; capability within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />,

d. Verifying TSV Closure and TCV

d. or, apply the MCPR limit for Fast Closure functions are inoperable MCPR-RPT as not bypassed when Thermal specified in the COLR within 2 Power' is > 30% Rated Thermal hours. Power once per 24 months;

2. If the requirements of Specification 3.2.H.1 cannot be met, then remove the associated recirculation pump from service within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or reduce Thermal Power to < 30% of Rated Thermal Power within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

o The action of placing the channel in trip is not applicable if the inoperable channel is the result of an ,

inoperable breaker or Adjustable Speed l Drive (ASD). j

-60a-

. Unit 2 PBAPS 3.2 BASES (Cont.) -

The MCPR-RPT instrumentation initiates a recirculation pump trip (RPT) to reduce the peak reactor pressure and power resulting from turbine trip or generator load rejection transients to provide additional margin to the core thermal MCPR safety limit. The MCPR-RPT instrumentation consists of two

~

functions. These two functions are the Turbine Stop Valve (TSV) Closure and Turbine Control Valve (TCV) Fast Closure valve functions. The TSV Closure and the TCV Fast Closure functions are designed to trip the recirculation pumps in the event of a turbine trip or generator load rejection to mitigate the neutron flux, heat flux, and pressure transients, and to increase the margin to the MCPR safety limit.

Each MCPR-RPT trip' system is a two-out-of-two logic for each function; thus, either two TSV-Closure or two TCV Fast Closure signals are required for a trip system to actuate. If either trip system actuates, both recirculation pumps will trip. There is one ASD and RPT breaker in series per recirculation pump.

One trip system trips the ASD of each recirculation pump, and the second trip system trips the RPT breaker for each recirculation pump.

A function is considered to be maintaining MCPR-RPT trip capability when sufficient channels are Operable or in trip, such that the MCPR-RPT System (consisting of two trip systems) will generate a trip signal from the given function on a valid signal so that both recirculation pumps can be tripped.

This requires two channels of the function in the same trip system to be  ;

Operable or in trip, and the associated MCPR-RPT breakers or Adjusteole Speed 1 Drives (ASDs) to be Operable or in trip. Trip Systems Operability includes the associated MCPR-RPT breakers or ASDs. A channel is considered to be an arrangement of a sensor and associated components which provide an input to 1 the associated function. The function provides an input'to the trip system to trip either the ASDs or the RPT breakers. In summary, the intent of 3.2.H.1.c is to ensure that sufficient channels exist in either trip system such that a TSV Closure will result in a trip of both recirculation pumps, and a TCV Fast Closure will result in a trip of both recirculation pumps.

Limiting Condition for Operation 3.2.H.I.d is intended to ensure that appropriate actions are taken if multiple, inoperable, untripped channels within the same function result in the function not maintaining MCPR-RPT trip capability.

1 To mitigate pressurization transient effects, the MCPR-RPT must trip the recirculation pumps after initiation of closure movement of either the TSVs or the TCVs. The combined effects of this trip and a scram reduce fuel bundle power more rapidly than a scram alone, resulting in an increased margin to the MCPR safety limit. The MCPR-RPT function is automatically disabled when turbine first stage pressure is < 30% Rated Thermal Power.

The MCPR-RPT protection is required whenever Thermal Power is > 30% Rated Thermal Power. Below 30% Rated Thermal Power, the High Reactor Pressure and the APRM High Flux functions of the RPS are adequate to maintain the necessary safety margins.

Surveillance Requirements have been added to ensure instrument functioning.

-93b-

. Unit 2 PBAPS 4.5.K Minimum Critical Power Ratio (MCPR) - Surveillance Reauirement At core thermal power levels less than or equal to 25%, the reactor will be operating at minimum recirculation pump speed and the moderator void content will be very small. For all designated control rod patterns which may be employed at this point, operating plant experience indicated that the resulting MCPR value is in excess of requirements by a considerable margin. With this low void content, any inadvertent core flow increase would only place operation in a more conservative mode relative to MCPR. During initial start-up testing of the plant, a MCPR evaluation will be made at 25% thermat power level with minimum recirculation pump speed. The MCPR margin will thus be demonstrated such that future MCPR evaluation below this power level will be shown to be unnecessary.

The daily requirement for calculating MCPR above 25% rated thermal power is suf-ficient since power distribution shifts are very slow when there have not been significant power or control rod changes. The requirement for calculating MCPR when a limiting control rod pattern is approached ensures that MCPR will be known following a change in power or power shape (regardless of magnitude) that could place operation at a thermal limit.

4.5.L MCPR Limits for Core Flows Other Than Rated The purpose of the K, factor is to define operating limits at other than rated flow conditions. At less than 100% flow the required MCPR is the product of the operating limit MCPR and the K, factor. Specifically, the K, factor provides the required thermal margin to protect against a flow increase transient. The .

most limiting transient initiated from less than rated flow conditions is the i recirculation pump speed up caused by an Adjustable Speed Drive (ASD) speed control failure.

For operation in the automatic flow control made, the K, factors assure that the operating limit MCPR will not be violated should the most limiting transient occur at less than rated flow. In the manual flow control mode, the K, factors assure that the Safety Limit MCPR will not be violated for the same postulated transient event.

The K, factor curves in the CORE OPERATING LIMITS REPORT were developed generically and are applicable to all BWR/2, BWR/3, and BWR/4 reactors. The K, factors were derived using the flow control line corresponding to rated thermal c power at rated core flow.

For the manual flow control mode, the K, factors were calculated such that at the maximum flow rate and the corresponding core power (along the rated flow control line), the limiting bundle's relative power was adjusted n.til the MCPR was slightly above the Safety Limit. Using this relative bundle power, the MCPR's were calculated at different points along the rated flow control line corresponding to different core flows. The ratio of the MCPR calculated at a given point of the core flow, divided by the operating limit MCPR determines the K,.

For operation in the automatic flow control mode, the same procedure was employed except the ini',ial power distribution was established such that the MCPR was equal to the operating limit MCPR at rated power and flow.

-141a-

Unit 2 PBAPS-LIMITING CONDITIONS FOR OPS.tATION SURVEILLANCE REQUIREMENTS

a. Gases from the Steam month in accordance Jet Air Ejector Dis- with the methodology charge shall be and parameters in processed through the the ODCM.

recombiner, holdup pipe, off-gas filter, and Sb. The appropriate gaseous off-gas stack. radioactive waste system equipment as described

b. Gases from the Mechanical in Specification 3.8.C.5 Vacuum Pump and Gland Steam shall be demonstrated Exhauste'r discharge operable every quarter, shall be processed unless utilized to through the off-gas process gaseous waste stack. during the previous-13 weeks, by analyzing

c. Reactor, turbine, the gaseous waste radwaste, and recombiner processed through the building atmospheres -appropriate equipment shall be processed to determine that it through permanently meets the requirements of or temporarily installed Specification 3.8.C.l.

equipment in the appropriate building, ventilation system Sc. An air sample'shall be and the Reactor Building obtained and-analyzed Ventilation' Exhaust Stack, from all building areas with the exception of the with an unmonitored .

t following unmonitored exhaust once per month.

exhausts: ,

1. ASD and Reactor Building ,

l Cooling Water equipment rooms.

2. Control room utility and toilet rooms.

3. Cable spread room.

4. Emergency switchgear rooms.

5. 125/250 VDC Battery rooms and the 250 VDC Battery rooms.

6. Administration Building maintenance decontam-ination area.

With gaseous waste being discharged without treatment as required above, prepare and submit to the Commission within 21 working days.

213

. Unit 2 a

TABLE 3.14.C.1 FIRE DETECTORS Detector Type / Minimum Detectors Location Designation (1) Operable Unit 2

-Primary Containment (2) (3) S1, S2, S8 3 CRD Area (135') Rms. 208, 209, 212 S7A, S8A, S9A, S10A 13 SllA, S12A, S13A, S14A S15A, S16A, S17A, SIBA S19A, S20A Isol. Valve Compt. (135') Rm. 204 S21A 1 Operating Area (165') Rm. 402,403 S31A, S32A, S33A, S34A 12-S35A, S36A, 537A, S38A S39A, S40A, S41A, S42A S43A Laydown Area (195') Rm. 501, 502 S45A, S46A, S47A, S48A 7 508 S49A, S50A, S51A, S52A Vent. Equip. Area (195') Rm. 506 S53A, S54A 2 Vent Stack Rad. Mon.-Refuel c5bA, S59A 2 Floor (234')

HPCI Room S78 1 H5, H6, H7 (See 3.14.B.1.c)

RCIC Room S45, S46 2.

Reactor Bldg. Sump Area S79 1 Core Spray Pump Rooms S41, S42, S43, S44 4 Vac. Breaker Area-Rm. 107, 108 S91, S92, S93 3 RHR Rooms Room 101 S30, S31, S32 3 Room 102 S33, S34, S35 3 Room 103 S36, S37, S38 3 Room 104 S39, S40 2 Torus Area S83, S84, S85, S86 7 S87, S88, S89, S90

-RBCCW Rm (Rm 105) S94, S95, S96, S97, S98- 4

-240m-

~

F

. Unit 2 TABLE 3.14.C.1 FIRE DETECTORS Detector Type / Minimum Detectors location Designation (1) Operable

~~

ASD Room S15, S16, S17 5 S18, S19, S20 Emerg. Switchgear Rooms Sll, S12, S13, S14 4 Battery Rooms ~

Room 218 S70, S71 2 Room 225 S68, S69 2 13KV Switchgear Area (116') S72, S73, S74 3 HPSW Pump Room S390 1 UNIT 3 Primary Containment (2)(3) S103, S104, S106 3 CRD' Area (135') Rms. 250 S166, S167, S168, S169 13 252, 257 S170, S171, S172, S173 S174, S175, S176, S177 S178, S179 Isol. Valve compt. S181 1 (135') Rm 249 Operating Area (165') S182, S183, S184, S185 12 Rm. 443, 444 S186, S187, S188, S189 S190, S191, S192, S193 ,

S194 Laydown Area (195') S196, S197, S198, S199 7 q Rm. 517, 518, 523 S103A, S104A, S105A, S106A '

Vent. Equip Area (195') S107A, S108A 2 Rm. 520 l Vent Stack Rad. Hon.-Refuel S109A, S110A 2 floor (234')

HPCI Room S148 1 H115, Hil6, H117 (See 3.14.B.1.c) .l RCIC Room S131, S132 2 Reactor Bldg. Sump Area S149 1 1

1

-240n-l

. Unit 2 PBAPS-Detector Type / Minimum Detectors location Designation (1) Operable Core Spray Pump Rooms S133, S134, S135, S136 4 Vac. Breaker Area - S158, S159, S160 3 Room 160, 161

~

RHR Rooms Room 156 S120, S121 2 Room 157 S122, S123, S124 3 Room 158 S125, S126, S127 3 Room 159 ,

S128, S129, S130 3 Torus Area S150,'S151, S152, S153 7 S154, S155, S156, S157 RBCCW Room S161, S162, S163 4 (Rm 162) S164, S165 ASD Room Sill, Sil2, S113 5 S114, Sil6, Sil7 Emerg. Switchgear Rooms S107, S108, S109 4 S110 Battery Rooms Room 266 S147, S148 2 Room 268 -S145, 5146 2 13KV_Switchgear Area (116') S75, S76, S77 3 HPSW Pump Room S391 1 l COMMON Control Room S21, S22, S23, S24 4 Centrol Room Offices S137, S138, S139 6 S140, S141, S142 l Cable Spreading Room S4, S7, S9, S10 23 '

l S47 through S67 (total: 25) j Computer Room S5, S6 2 Diesel Generator Rooms H550A, B thru H557A, B (See 3.14.B.3.c) and H796A, B thru H819A, B (16 in each room)

D-G Bldg. Cardox Room S540, S541, S542 3

-2400- ,

f n

Unit 2 PBAPS LIMITING CONDITIONS FOR OPERATION SURVEILIANCE REQUIREMENTS 3.14.E. Water Suenression Systems 4.14.E. Water Suppression Systems

1. The ASD room water suppression 1. The ASD room water suppression systems shall be operable system testing shall be whenever the unit is in reactor performed as follows:

power operation.

a. Simulated actuation of

2. If the requirements of 3.14.E.1 the automatic valve (s) cannot be met, and system alarms every refueling cycle.

a. establish a continuous fire watch with portable b. Functional test of fire suppression equipment system integrity alarm within one hour. (low pipe N, pressure) every refueling cycle,

b. restore the system to an operable status within 14 days, or in  ;

lieu of any other report required by Specification 6.9.2, submit a Special Report to the Commission pursuant to .

Specification 6.9.3 within ,

31 days outlining the cause of the malfunction and ,

the plans for restoring the system to an operable status. Reactor startup and/or continued reactor operation is permissible.

-240k-

Unit 2 PBAPS In the event that a portion of the fire detection instrumentation is inoperable, the establishment of fire patrols in the accessible affected areas is required to provide detection a capability until the inoperable instrumentation is returned to service.

D. Fire Barrier Penetrations The functional integrity of the fire barrier penetration seal ensures that fires will be confined or adequately retarded from spreading to adjacent portions of the facility. This design-feature minimizes the possibility of a single fire rapidly involving several areas of the facility prior.to detection and extinguishment. The fire barrier penetration seals are a passive element in the facility fire protection program and are subject '

to periodic inspections.

During periods of time when the seals are not functional, a continuous fire watch is required to be maintained in the vicinity of the affected seal until the seal is restored to functional status.

E. Water Suppression System r Water suppression systems located in the ASD room are provided to protect the ASD and safe shutdown components for possible fire in the fire area. The suppression system is a pre-action type using smoke detectors to charge the sprinkler headers with fire water and sprinkler actuation on high temperature. Both fire water flow (high pipe pressure switch) and smoke detector actuation annunciates in the control room. The sprinkler header is normally pressurized with N 2 , with a low pressure annunciator to monitor header and sprinkler integrity, j i

F. Batterv Room Ventilation Flow Detector i I

Loss of the battery room exhaust ventilation flow will result in j a buildup of combustible gases and a potential fire hazard to i safety-related cables. A flow detector will annunciate an alarm  !

in the control room upon poor ventilation conditions. ,

-240r-

-]

I i

i

(

3 L

J}

ATTACHMENT 3

.i t

General Electric Affidavit and General Electric Analysis  !

i I

+

t h

t 6

i E

General Electric Company AFFIDAVIT I, Robert C. Mitchell, being duly sworn, depose and state as follows:

(1) I am Project Managor, Safety Evaluations Programs, General Electric Company ("GE")

and hav.: been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in the GE proprietary report NEDC-32165P, "End-of-Cycle Recirculation Pump Trip Analysis For Peach Bottom Atomic Power Station Units 2 and 3," Revision 2, Class III (GE Company Proprietary Information), datul February 1994. The proprietary information is delineated by bars marked in the margin adjacent to the specific material.

(3) In making this application for withholding of proprietary information of which it is the owner, GE relies 6pon the exemption from disclosure set forth in the Freedom of Inforn ation Act ("FOIA"),5 USC Sec. 552(b)(4), and the Trade Secrets Act,18 USC Sec.1905, and NRC regulations 10 CFR 9.17(a)(4),2.790(a)(4), and 2.790(d)(1) for .

" trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all " confidential commercial information", and some portions also qualify under the narrower definition of " trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Enctgy_Emje.qt v. Nuclear Regulatory Commission. 975F2d871 (DC Cir.1992), and Eublic Citizen Health Research Group v. FDA,704F2dl280 (DC Cir.1983).

(4) Some examples of categories of information which fit into the definition of proprietary information are:

I

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention ofits use by General Electric's competitors without .

I licease from General Electric constitutes a competitive economic advantage over other j compames, 1 i

I Affidavit Page I  ;

l l

b. Information which, if used by a competitor, would reduce his expenditure of  ;

resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;

c. Information which reveals cost or price information, production capacities, budget ,

levels, or commercial strategies of General Electric, its customers, or its suppliers;

d. -Information which reveals aspects of past, present, or future General Electric ,

customer-funded development plans and programs, of potential commercial value to General Electric; ,

e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for the reasons set forth in both paragraphs (4)a. and {4)b., above.  ;

(5) The information sought to be withheld is being submitted to NRC in confidence. The .i information is of a sort customarily held in confidence by GE, and is in fact so held.  ;

The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GE, no public disclosure has been made, and it  ;

is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps  :

taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the [

originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within GE is limited on a ."need to know" basis. >

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by Anklavit Page 2 i

i

the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GE are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2), above, is classified as proprietary because it contains detailed results of analytical models, methods and processes, including '

computer codes, which GE has developed, obtained NRC approval of, and applied to perform evaluations of the loss-of-coolant accident for the BWR.

The development and approval of the BWR technology and computer codes used in this.

analysis was achieved at a significant cost, on the order of several million dollars, to GE.

The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes 4 a major GE asset.

(9) Public disclosure of the information sought to be withheld is likely to' cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GE's comprehensive BWR safety and .

technology base, and its commercial value extends beyond the original development cost.

The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GE.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.  ;

GE's competitive advantage will be lost if its competitors are able to use the results of the GE experience to normalize or verify their own process or if they are able to clairn Afridavit Page 3

c an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GE would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of' resources would unfairly provide competitors with a windfall, and deprive GE of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing r

these very valuable analytical tools.

STATE OF CALIFORNIA ) ,

) ss:

COUNTY OF SANTA CLARA )

Robert C. Mitchell, being duly sworn, deposes and says:

That he has read the foregoing affidavit and the matters stated therein are true and correct to the best of his knowledge, information, and belief.

Executed at San Jose, California, this 2 3 day of FlA E 8 199)./

1

. 1 W C.. W i Robert C. Mitchell )

General Electric Company j l

Subscribed and sworn before me this $5 ' day of MML 199/.

i skeat

~

<U Notary Pubiic, State of California ,

y, ----x --x x x xs l MARY L KEt4DALL

- COMM. # 987%1 2 h ,7, . Notcry Public - CoWornia b y SAICA CLARA COUNTY r Affidavit Page 4 .

j My Comm. Expires MAR 26.1??7 g

,v ,, , , M w e ,r , , , , ,

-