ML20070N455
| ML20070N455 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 04/27/1994 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20070N457 | List: |
| References | |
| NUDOCS 9405060226 | |
| Download: ML20070N455 (12) | |
Text
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Station Support Department 10 CFR 50.90
- s-PECO ENERGY
- a*l33"ne,,
j 965 Cbeatmtum Boulewd I
Wayne, PA 19087 5691 April 27,1994 Docket Nos. 50-277 50-278 Ucense Nos. DPR-44 DPR 56
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U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
Peach Bottom Atomic Power Station, Units 2 and 3 Technical Specifications Change Request
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Dear Sir:
PECO Energy Company hereby submits Technical Specifications Change Request (TSCR) No. 9214 in accordanet, with 10 CFR 50.90, requesting j
l changes to Appendix A of the Peach Bottom Atomic Power Station, Units 2 and i
3 Facility Operating Ucense. These changes are being proposed to support the implementation of proposed Modification 5274 which is intended to replace the
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PBAPS, Unit 2 Containment Atmospheric Dilution (CAD) System and Containment Atmospheric Control (CAC) System analyzers. This modification was performed on PBAPS, Unit 3 during the previous PBAPS, Unit 3 outage l
(Amendment Nos.177 and 180).
- to this letter describes the proposed changes, and provides justification for the changes. Attachment 2 contains the revised Technical Specification pages.
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April 27,1994 Page 2 4
If you have any questions concerning this matter, please do not hesitate to contact us.
Very truly yours, W. c. Way ]v G. A. Hunger, Jr., Director Ucensing
Enclosures:
Affidavit, Attachment 1, Attachment 2 cc:
T. T. Martin, Administrator, Region I, USNRC W. L Schmidt, USNRC Senior Resident inspector, PBAPS R. R. Janati, Commonwealth of Pennsylvania
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1 COMMONWEALTH OF PENNSYLVANIA l
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COUNTY OF CHESTER W. H. Smith, Ill, being first duly sworn, deposes and says:
That he is Vice President of PECO Energy Company; the Applicant herein; that he has read the attached Technical Specifications Change Request (Number 92-14) for Peach Bottom Facility Operating Ucenses 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.
M Vice President Subscribed and sworn to before me thi O day p
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[1994.
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Notary Public F.As A.Sanm PdAc W
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PEACH BOTTOM ATOMIC POWER STATION UNITS 2 and 3 Docket Nos. 50-277 50-278 Ucense Nos. DPR-44 DPR 56 TECHNICAL SPECIFICATION CHANGE REQUEST No. 92-14
" Containment Atmospheric Dilution (CAD)
System / Containment Atmospheric Control (CAC)
System Analyzer Replacement" Supporting Information for Changes: 8 Pages l
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Docket Nos. 50-277 50-278 Ucense Nos. DPR 44 DPR 56 Introduction PECO Energy Company, Ucensee under Facility Operating Ucenses DPR-44 and DPR 56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, respectively, requests i
that the Technical Specifications (TS) contained in Appendix A to the Operating Ucense be amended. This amendment is necessary to reflect the replacement and redesign of the analyzers and supporting components (herein defined as the containment monitoring 4
system) ut!!ized to monitor hydrogen and oxygen in support of the PBAPS, Unit 2 Containment Atmosphere Dilution (CAD) System and Containment Atmospheric Control (CAC) System. This amendment also incorporates additional clarifications to the CAD portion of the PBAPS, Unit 3 TS which incorporated this modification in the previous PBAPS, Unit 3 outage. Proposed changes to the Technical Specifications are shown in
- . The proposed change pages for PBAPS, Units 2 and 3 are: 77a,78a, 86a,93, and 194. Proposed changes for PBAPS, Unit 2 are: 172 and 173.
We request that the proposed changes be issued on or before September 1,1994 for PBAPS, Units 2 and 3, and that the changes become effective prior to the restart from the PBAPS, Unit 2 refueling outage 2R10 currently scheduled to begin September,1994.
Discussion it is the Intent of Modification 5274 to replace the existing CAC System oxygen analyzer and the four CAD System hydrogen / oxygen analyzers with a reconfigured containment monitoring system composed of two new analyzers. The current arrangement of five analyzers was installed as a part of the originallicensing of the plant. The two new containment monitoring system analyzers will perform both the CAC and CAD analysis
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functions from the original design sample points. This is accomplished by routing the existing sample points to one or the other analyzers and providing sample point selection j
capability for each analyzer. The points are organized so that independence and
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l redundancy are maintained. In addition, Modification 5274 replaces the existing four CAD analyzer recorders located in the control room with two new recorders. Each recorder is dedicated to one analyzer.
Associated with this modification is the reconfiguring of the process piping and electrical wiring and components necessary to support the operation of the two new analyzers.
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Docket Nos. 50-277 50 278 l
Ucense Nos. DPR 44 I
DPR 56 4
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Descriotion of the Procosed Changes j
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CAD system oxygen analyzer senting the drywell and one CAD system oxygen i
i analyzer serving the suppression chamber on that reactor. If this specification cannot j
be met, the unit shall be in Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />." Ucensee proposes to delete these words for the PBAPS, Unit 2 TS and replace them with operability requirements for the two new analyzers. These operability requirements are based on the operability of the analyzer and the operability of the process lines that connect to the analyzers. The shutdown requirements are based on the guidance provided by the model Technical Specifications provided in Generic Letter 83-36, "NUREG-0737 Technical Specifications," dated November 1,1983.
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- 2. A new TS LCO 3.7.A.6.d will be added to the PBAPS, Unit 2 TS to provide a convenient cross reference to Tables 3.2.F and 4.2.F for the hydrogen requirements.
- 3. The current Unit 2 TS LCO 3.7.A.6.d will be renumbered to 3.7.A.6.e.
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- 4. The current Unit 2 SR 4.7.A.6.c states that "The CAD system oxygen analyzers shall be tested for operability using standard bottled oxygen once per month and shall be i
calibrated once per 6 months." The reference to the operability test using " standard 1
bottled oxygen"is being deleted and replaced with updated terminology which refers to the analyzers being channel checked using bottled gas. Additionally, the calibration frequency is being increased from once per 6 months to once per 3 months which conforms with the vendor recommended calibration frequency for oxygen sensors and is consistent with the calibration frequency for the hydrogen 4
sensors (e.g., once per 3 months) provided in Generic Letter 83-36.
- 5. The current Unit 2 SR 4.7.A.6.c requires an increased frequency in operability testing
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if one of the two dedicated CAD oxygen analyzers serving either the drywell or the j
torus becomes inoperable. Additionally, this SR does not have a time limit for return j
to service of the inoperable CAD oxygen analyzer. This increased frequency in l
operability testing is being replaced with LCO 3.7.A.6.c. LCO 3.7.A.6.c provides an l
operability limit that will not exceed 7 days with inoperable channels.
- 6. The current Unit 2 3.7.A & 4.7.A Bases are being revised, and the current Unit 3 3.7.A
& 4.7.A Bases are being further clarified, to reflect the design and operation of the CAD analyzers.
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Docket Nos. 50-277 50 278 License Nos. DPR-44 1
DPR 56 i
- 7. The current Table 3.2.F for PBAPS, Units 2 and 3, " Surveillance Instrumentation,"
contains the minimum number of operable instrument channels and the associated actions for the Drywell Hydrogen Concentration Analyzer and Monitor. Table 3.2.F, its associated notes, and the corresponding 3.2 Bases are being revised as follows:
i a) delete the current three actions for the Drywell Hydrogen Concentration Analyzer and Monitor (ltem 18) and replace them with a new action 13 that provides-channel operability actions that are based on the guidance of model Technical Specifications provided in Generic Letter 83 36, "NUREG-0737 Technical Specifications," dated November 1,1983; b) revise the instrument numbers for item 18; I
c) revise the instrument range for item 18 to reflect the range provided by the new i
analyzers; d) add a new parameter (Item 19)," Suppression Chamber Hydrogen Concentration Analyzer and Monitor," with the same channel operability actions (note 13),
instrument numbers, and range as the Drywell Concentration Analyzer and Monitor to reflect the operation of the analyzers in the post LOCA CAD operation in which one analyzer will normally be dedicated to monitoring the suppression chamber and one analyzer will normally be monitoring the drywell, and; e) revise the 3.2 Bases to reference the incorporation of the Suppression Chamber Hydrogen Concentration Analyzer and Monitor.
- 8. Item 21 of the current Units 2 and 3 Table 4.2.F, " Minimum Test and Calibration Frequency for Surveillance Instrumentation," will be revised to include the calibration frequency and instrument check frequency for the Suppression Chamber Hydrogen Concentration Analyzer and Monitor.
Safety Assessment As discussed in the PBAPS UFSAR, the Containment Atmospheric Control (CAC) System oxygen analyzer supports the operation of CAC System in two functions. First, the CAC System oxygen analyzer calculates the content of oxygen in the primary containment so that during each startup the primary containment is purged of air with pure nitrogen until the atmosphere contains less than four percent oxygen. Second, the CAC System oxygen analyzer continuously monitors the primary containment for oxygen..
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i Docket Nos. 50 277 50 278 Ucense Nos. DPR 44 DPR 56 l
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As also discussed in the PBAPS UFSAR, the four Containment Atmospheric Dilution 1
(CAD) System hydrogen / oxygen analyzers support the operation of the CAD System by I
ensuring that following a Loss of Coolant Accident (LOCA), the primary containment is j
monitored so that the concentration of hydrogen and oxygen can be maintained within acceptable ranges. Following a LOCA, the CAD System is used instead of the normal nitrogen inerting system to maintain the oxygen concentration within the containment at or less than five percent.
The Safety Design Bases of the CAC and CAD System, as discussed in the PBAPS
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UFSAR, will not be altered as a result of Modification 5274 which incorporates a new J
design for the containment monitoring system that consists of the new hydrogen / oxygen j
analyzers, associated piping and circuitry, and two new recorders.
T The two new hydrogen / oxygen analyzers were manufactured by the Whittaker Corporation. These units are designed as Class 1E equipment and are environmentally j
qualified for 1E safety related service in accordance with IEEE 323-1974, "lEEE Standard i
for Qualifying Class 1E Equipment for Nuclear Power Generating Stations," and j
Regulatory Guide 1.89, " Environmental Qualification of Certain Electrical Equipment 1
Important to Safety for Nuclear Power Plants," and are seismically qualified in accordance with IEEE Standard 344-1975, "lEEE Recommended Practices for Seismic Qualification of j
Class 1E Equipment for Nuclear Power Generating Stations."
1 The existing CAC and CAD sampling points in the drywell and torus, and the associated i
process lines up to and including the two primary containment isolation valves that are utilized by the hydrogon/ oxygen analyzers to withdraw samples, will not be altered as a j
result of this modification.
j Independence between the CAC and CAD System process lines will be maintained. As identified in the revised Technical Specification (TS) Umiting Condition for Operation 3
(LCO) 3.7.A.6, provisions have been established to define the operability of the analyzers through the use of functional channels, which in the case of the CAC and CAD System, j
includes process lines that connect to sampling points in the drywell and torus, j
The replacement containment monitoring system design contains sufficient redundancy to ensure its reliability. A single failure in either analyzer or its associated hardware and circuitry would render only that portion of the system unavailable with the redundant analyzer and its associated hardware and circuitry fully capable of performing the j
required function of monitoring oxygen and hydrogen.
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Docket Nos. 50 277 i
50 278 License Nos. DPR 44 l
DPR 56 t
During normal operation, one analyzer can be in operation with the redundant unit in standby. In the post LOCA condition, one analyzer will normally monitor the drywell and 4
l one analyzer will normally monitor the torus. Each analyzer can monitor either the drywell or the suppression chamber via sample point selection.
in the unlikely event that one of the analyzers or its associated components would be rendered inoperable such that the analyzer could no longer provide the capability to l
monitor hydrogen or oxygen in the post LOCA condition, the operator can reestablish the monitoring function of both the drywell and torus with one analyzer through the use of a keypad on the analyzer remote control unit in the Control Room.
l To operate the system in the post LOCA condition, the operator must open the four containment isolation valves to each analyzer and restart / start the analyzers from the i
Control Room. This number of operator actions is not anticipated to reduce the margin j
of safety considering that the analyzers would not be needed for a time period of one 1
day following a LOCA. As discussed in the PBAPS UFSAR, the earliest time for nitrogen j
addition to begin is approximately one day, i
in our Technical Specification Change Request (TSCR) No. 9213 (dated February 25, i
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1993) concerning the replacement of the PBAPS, Unit 3 CAC and CAD analyzers, we stated that in the post LOCA condition the operator must open the two inlet containment j
isolation valves to each analyzer and restart / start the analyzers. Due to redesign of the j
system, an additional two isolation valves on the exhaust line of each analyzer will also be opened so that the post LOCA sample gas will be returned to the containment rather
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than the Standby Gas Treatment System.
j With the current analyzers, warmup time following startup of the analyzers is approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. With the new analyzers, warmup time is approximately 15 i
minutes which will enhance the availability and usefulness of the analyzers to monitor 1
post LOCA hydrogen and oxygen, i
j The Technical Specifications for hydrogen are being revised to reflect the enhanced i
monitoring range of the two new analyzers. Currently, Technical Specification Table 3.2.F l
identifies that the range of hydrogen monitored is 0 20% volume. This range will be j
increased to 0-30% volume. This range is in accordance with Regulatory Guide 1.97, i
" Instrumentation for Ught Water Cooled Nuclear Power Plants to Assess Plant and j
Environs Conditions During and Fol!owing an Accident "
j in the case of oxygen, the monitoring range will remain the same. The monitoring i
function provides a dual range of 010% and 0-30% volume. These ranges are also in accordance with Regulatory Guide 1.97.
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i Docket Nos. 50 277 50 278 j
License Nos. DPR 44 l
DPR 56 i
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These ranges will ensure the operators ability to assess the concentration of hydrogen j
and oxygen in the containment.
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The analyzers are tested once per month to verify the operability of the hydrogen and oxygen sensor instrumentation within the analyzer. The method of testing and the l
frequency will not change. Additionally, the analyzers will be calibrated once per 3 i
months instead of the current 6 months. The 3 month frequency conforms to the i
surveillance frequency specified in Generic Letter 83-36 for drywell hydrogen analyzers.
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1 This system is designed to operate under post LOCA conditions and has been provided j
with eppropriate boundaries that ensure the leak tight integrity of the system. As stated i
previously, the existing primary containment Isolation valves will not be altered as a result i
of this modification. The process tubing to the analyzers is designed with redundant j
valves at the interface with the non safety related CAC process lines and at the interface j
with the non-safety related radioactive gas sampler, i
j Leak testing of the analyzers and their associated process piping will be performed as a functional test once per refueling cycle in Technical Specification Change Request 1
(TSCR) No. 92-13 (dated February 25,1993) concerning the replacement of the PBAPS, l
Unit 3 CAC and CAD analyzers, PECO Energy committed to leak testing of the analyzers and their associated process piping as a part of the 10 CFR 50, Appendix J, Type A leak
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test. This commitment is being revised such that the PBAPS, Unit 3 analyzers and their associated piping, will be tested as a functional test once per refueling cycle. This issue 4
was discussed with Nuclear Regulatory Commission Project Manager (J, Shea) in an October 1,1993 telephone conversation.
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All tubing, fittings, and valves associated with the analyzers is designed, fabricated,
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inspected, and tested in accordance with ANSI B31.11973 Edition with addenda through
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Summer 1973.
l The system design complies with the PECO Energy Fire Protection Program and the requirements for Class 1E circuit separation criteria, i
l The instrumentation for this design has been upgraded such that the new design meets j
the requirements of Regulatory Guide 1.97.
j The containment monitoring system is capable of operating continuously for a minimum for 101 days following a LOCA in accordance with ANSI /ANS-4.51980, " Criteria for Accident i
Monitoring Functions in Light Water Cooled Reactors."
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l Docket Nos. 50 277 I
50 278 Licence Nos. DPR 44 DPR 56 i
information Supporting a Findina of No Significant Hazards ConsideratioD We have concluded that the proposed changes to the PBAPS, Units 2 and 3 TS do not constitute a significant t azards consideration. In support of this determination, an evaluation of each of the three standards set forth in 10 CFR 50.92 is provided below.
(1) The orocosed changes do not involve a significant increase in the orobability or consecuences of an accident oreviously evaluated.
The design function and operation of the CAC and CAD Systems, which are supported by the operation of the containment monitoring system, have not been altered as a result of these changes. The CAC System monitors the content of oxygen during startup and normal operation and the CAD System is utilized to monitor the content of hydrogen and oxygen during post LOCA operation. The monitoring of these variables will continue to mitigate the consequences of accidents previously evaluated. Additionally, no accident precursors will be impacted by these changes.
The new system meets or exceeds the design standards of the original system.
Additional ly, the decrease in warmup time will increase the availability and usefulness of the analyzers to mitighte the consequences of an accident. Therefore, the proposed changes will not involve a significant increase in the probability or consequences of an accident previously evaluated.
(2) Create the oossibility of a new or different tvoe of accident from any accident oreviously evaluated: or, The proposed TS changes do not involve the introduction of any new accident initiators. The new containment monitoring system will enhance the ability of CAD system to mitigate the consequences of an accident and prevent the introduction of a new or different type of accident previously evaluated. The new system meets or exceeds existing design standards and will be tested to ensure its reliability. The i
new containment monitoring system is a monitoring system and will not introduce new accident initiators. Therefore, the proposed changes will not create the possibility of a new or different type of accident from any accident previously evaluated.
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Docket Nos. 50-27/
50 278 Ucense Nos. DPR-44 DPR 56 (3) Involve a significant reduction in a margin of safety.
Although the number of analyzers is being reduced, the proposed modification and TS changes will enhance the ability of the containment monitoring system to support the operation of the CAC and CAD Systems though the use of improved equipment that meets or exceeds the design standards of the original system. Therefore, the l
proposed changes will not reduce the margin of safety.
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Information Supporting An Environmental Assessment An environmental impact assessment is not required for the changes proposed by this change request because the changes conform to the criteria for " actions eligible for categorical exclusion," as specified in 10 CFR 51.22(c)(9). The change request involves no significant hazards as demonstrated in the preceding sections. This change request involves no significant change in the types or significant increase in the amount of any
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effluents that may be released offsite and there is no significant increase in individual or cumulative occupational radiation exposure.
Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes and have concluded that they do not involve an unreviewed safety question and will not endanger the health and safety of the public.