ML20066C045

Application for Amends to Licenses DPR-44 & DPR-56, Consisting of Tech Spec Change Request 86-08 Revising Structural Integrity Portion of Specs,Per Generic Ltr 88-01

ML20066C045
Person / Time
Site:	Peach Bottom
Issue date:	12/31/1990
From:	Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20066C047	List: ML20066C045 ML20066C049
References
GL-88-01, GL-88-1, NUDOCS 9101090156
Download: ML20066C045 (8)

Text

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10 CFR'50.90-

,,,e . e PHILADELPHIA ELECTRIC COMPANY NUCLEAR GROUP HEADQUARTERS 955-65 CHESTERBROOK BLVD.

WAYNE PA 19087 5691 tais) eso sooo December 31, 1990 Docket Nos. 50-277 50-27B License Nos. DPR-44' DPR-56 U.S. Nuclear Regulatory Commission i Attn Document Control Desk Washington, DC 20555

SUBJECT:

Peach Bottom Atomic Power Station, Unita 2 and 3-Technical Specifications Change Request

REFERENCE:

Letter from D. R. Helwig-(PECo) to U.S. Nuclear Regulatory Commission dated.

June 4, 1990

Dear Sir:

Philadelphia Electric Company (PECo) hereby submits Technical Specifications Change Request (TSCR) No. 86-08, in accordance with 10 CFR 50.90,-requesting a-change to Appendix A of the Peach Bottom Facility Operating Licenses. .The proposed changes-concern the structural integrity portion of the Technical Speci fic a tious , and include a statement _ recommended by NRC Generic Letter (GL) 88-01. In the above referenced letter, PEco committed-to provide an appropriate TSCR related to GL 88-01 by December 31, 1990.

Attachment 1 to this letter describes the proposed changes, and provides justification for the changes. Attachment 2 contains the revised Technical Specification pages.

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

Very truly yours. t

/ L G. J. Beck.-Manager Licensing Section Nuclear Engineering & Services

Enclosures:

Affidavit, Attachment 1 Attachment 2 h p-t cc _ T. T. Martin, Administrator, Region I, USNRC J. J. Lyash, USNRC Senior Resident Inspector,.PB' g\=

T..M. Gerusky, Commonwealth of Pennsylvania {

' P101090156 901231 08G'(

" PDR P

ADOCM 05000277 PDR __ _ - . .-. ---

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COMMONWEALTH OF PENNSYLVANIA:

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. COUNTY OF CHESTER  :

D. R. Helwig, being first duly sworn, deposes and says:

l That he is Vice President of Philadelphia Electric

! Company; the Applicant herein; that he has read attached Technical Specifications Change Request (Number 86-08) for l

changes to Peach Bottom Facility Operating Licenses DPR-44 and DPR-56, 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, b .

- 55; T Vice Presid t Subscribed and sworn to before me this A'7 day of lOjegpalg1990.

lid!.ua. c- LG1da 3, Notary Public NOTAR!AL SEAL CATHEq:NE A MENOEI Netaa/ Puthe Trothe Two, CNs* Ccucty j

My Commi11Cnjcres M::t 11993

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' ATTACHMENT 1 l-4 PEACH BOTTOM ATOMIC POWER STATION +

UNITS 2 AND.-3 i

Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 TECHNICAL SPECIFICATION CHANGE REQUEST.

86 " Revisions to Inservice Inspection Requir.ements" Supporting'Information for Changes 6 pages l

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Docket Non. 50-277 50-278 License Nos. DPR-44 DPR-56 Philadelphia Electric Company (PECo), Licensee under Facility Operating Licenses DPR-44 and DPR-56 for the Peach Bottom Atomic Power Station (PBAPS) Unit No.-2 and Unit No. 3, l respectively, requests that the Technical Specifications contained in Appendix A to the Operating Licenses be amended.

Proposed changes to the Technical Specifications are indicated by vertical bars in the margins of the pages contained in Attachment 2 and listed here: vi, 149b, 150, 161, 162 and 163.

s The proposed changes concern the Surveillance Requirements (4.6.G) and the associated Bases for the Structural Integrity portion of the Technical Specifications. Included in these proposed changes is the addition of a statement recommended by Item 3 of NRC Generic Letter 88-01 "NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping."

Licensee proposes that there changes be effective as of the issuance date of the license amendment.

Description of Changes Licensee proposes the following changes:

(1) Delete existing Surveillance Requirement 4.6.G on page 149b.

(2) Delete existing Table 4.6.1 entitled "In-service Inspection Program'for Peach Bottom Units 2 and 3" on page 150.

(3) Insert proposed Surveillance Requirement 4.6.G.1 on page 149b which states:

" Inservice inspection of ASME Code Class 1, 2 and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by_10 CPR Part 50, Section 50.55a(g), except where relief has i 6

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Docket No2. 50-277

', 50-278' License'Nos. DPR-44 DPR-56 been granted by the Commission pursuant.to 10 CPR Part 50, Section 50.55a(g)(6)(1) and (a)(3)."

(4) Insert proposed Surveillonce Requirement 4.6,0.2'on page 149b which states:

"The Augmented Inservice Inspection (ISI) Program for.pipingishall be performed =in accordance with the staff positions on schadule, methods, personnel and sample expansion as provided by NRC Generic Letter 88-01 or in accordance with alternate measures approved by-the NRC staff."

(5) Insert proposed Surveillance Requirement 4.6.G.3 on page.149b which' states:

"Nothing in the ASME Boiler and Pressure Vessel

-Code shell be construed to supercede the requirements offany Technical-Specification."

(6) Delete the existing Bases for 3.6.G and 4.6.G'on pages 161,-162'and 163'and-reolace them with a discussion which reflects the proposed- ,

specifications.

i (7) Revise Table of Contents page.vi to reflect deletion of Table 4.6.1.

l Safety Discussion

-Change Requests (1) and (2)'are proposedEto delete obsolete provisions in the Technical Specifications. -These provisions refer to the ISI Program which was in effect prior.to l the development of a.10-year ISI Program pursuant to 10 CFR

, 50.55a(g). Deletion of the existing provisions will enhance safety by-eliminating confusion in interpreting.the specifications.

Change Request (3) l's proposed to incorporate the ISI portion of Surveillance Requirement 4.0.5.a (page 3/4 0-2) of the- 1

-Standard-Technical Specifications (STS)-for General Electric:

Boiling Water Reactors, NUREG-0123,: Revision-3. ~Section XI of 1

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Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 the-ASME Boiler and Pressure Vessel Code is already a requirement for licensees because it is incorporated by reference in 10 CPR 50.55a.

Change Request (4) is proposed to comply with the guidance provided by the NRC in Generic Letter 88-01.- The staff positions described in the Generic Letter were developed as a result of extensive research into intergranular stress-corrosion cracking (ICSCC) problems. The staff states in the Generic Letter that if the staff positions are implemented, adequate-levels of piping integrity and reliability can be achieved.

Change Request (5) is proposed to incorporate Surveillance Requirement 4.0.5.e (page 3/4 0-2) of.the STS.

Inclusion of this statement ensures that any discrepancies between the ASME Code requirements and the Technical Specifications are appropriately resolved.

Change Request (6) is proposed to make th'e Bases consistent with Limiting Condition ur Operation 3.6.G and proposed Surveillance Requirement 4.5,G. Consistency between the Bases and=the specifications to which they refer enhances safety by ensuring proper understanding and interpretation of the specifications.

The Bases proposed were modeled after those of the STS found on Page B 3/4 4-5.

Change Request (7) is a purely administrative change which affects the Table of Contents only. This request is proposed to delete Table 4.6.1 from the List of Tables. This iequest has no impact on safety.

No Significant Hazards Consideration Two examples provided by the Commission of a change involving no significant hazards consideration, as stated in 51 FR 7751 are: Example 11, "A change that constitutes an additional limitation, included in the technical restriction or control not presently specifications, e.g., a more stringent-surveillance requirement"; and Example vil, "A change to conform a license to changes in the regulations, where the' license change results in-very keeping with theminor changes to facility operations clearly in regulations." j

- The change requests proposed in this Application conform to these examples and do not constitute j a significant hazards consideration in that:

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Dock 3t No2. 50-277 50-278 License Nos. DPR-44 DPR-56

1) The proposed changes do not' involve a significant increase in the probability or consequences of an accident previously evaluated.

These proposed changes delete obsolete provisions in the Technical Specifications and' replace them with provisions of the Standard Technical Specifications (STS) for General Electric Boiling Water Reactors, NUREG-0123, Revision 3. This will enhance safety by eliminating any potential confusion associated with the obsolete provisions.

These proposed changes also incorporate requirements to adhere to the NRC staff positions.

on schedule, methods, persoaoel, and sample expansion as provided by NRC Generic Letter 88-01, "NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping." Implementation of this-requirement will increase the inspection frequency of various welds susceptible to intergranular stress corrosion cracking (IGSCC). This increased inspection j

frequency will allow early identification of any potential structural-integrity hazards,-thereby

' reducing the probability of any accidents previously evaluated, specifically, accidents associated with pipe breaks.

These proposed changes do not affect the initial conditions or precursors-assumed in any Updated Final Safety' Analysis.Reporn Section=14 accident.

analyses. Furthar, these proposed changes do not decrease the effectiveness of equipment relied upon to mitigate the previouslyfeveluated accidents.

11) The proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

These proposed changes will enhance the reliability of components contributing to the structural integrity of the plant. Implementation of these proposed changes will not-affect the design function or configuration of any component or introduce any new operating scenarios or. failure

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• Dockot Wos.l50-277 I 50-278 I

License Nos. DP& A4  ;

DPR-56 i i 1 l

modes. Therefore, these proposed changes do muc- ,

create the possibility of a new or different kind i of-accident.

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! 111) The proposed changes'do not involve a significant i

{ reduction in_a margin of safety. 4 p

j These proposed changes impose additional -l restrictions.which have_already been approved-byL '

the NRC through issuance cf the Standard Technical Specifications and: Generic Letter 88-01.. These-proposed changes do not adversely affect the assumptions or sequence'of events used in any accident analysis and consequently do r.ot reduce any margin of safety. ~>

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Environmental Impact Assessmenty An environmental impactiassessment is not regulred;for: '

' the changos proposed by this Application _because'the changes 3, conform to the criteria-for " actions eligible for categorical' '

exclusion" as specified in 10 CFR 51.22(c)(9). The proposed

• l changes do not involve any systems that have: a direct j relationship with-the environment. The changes involve the _. __

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structural integrity of ASME Code C1cas 1, 2.and 3 components.

1 The Application involves no_significant hazards consideration as  !

demonstrated in the preceding:section. The' Application involves  :

i no significant change in the types-or~significant-increase-in the 1' amounts of any effluents'that may be: released offsite and there i

will be no significant increase in individual or cumulative occupational radiation exposure. ,

i i- Conclusion I t

The Plcnt Operations' Review' Committee'and'the Nuclear-Review Board have reviewed these proposed changes and have j

concluded that they do not involve'an unreviewed safety question and are not.a threat to.the health and safetynof the public.

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