ML20073B553
| ML20073B553 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/16/1994 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20073B542 | List: |
| References | |
| NUDOCS 9409220095 | |
| Download: ML20073B553 (5) | |
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NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D.C. 20555-0001 s
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION i
RELATED TO AMENDMENT NOS. 195 AND 199 TO FACILITY OPERATING LICENSE N05. DPR-44 and DPR-56 PHILADELPHIA ELECTRIC COMPANY PUBLIC SERVICE ELECTRIC AND GAS COMPANY DELMARVA POWER AND LIGHT COMPANY ATLANTIC CITY ELECTRIC COMPANY PEACH BOTTOM ATOMIC POWER STATION. UNIT NOS. 2 AND 3 DOCKET NOS. 50-277 AND 50-278 I
1.0 INTRODUCTION
l By letter dated May 10, 1994, and supplemented by letters dated August 19, 1994 and September 13, 1994, the Philadelphia Electric Companty (the licensee) i submitted a request for changes to the Peach Bottom Atomic Power Station, Unit Nos. 2 and 3, Technical Specifications (TS).
The requested changes would revise the minimum low pressure cooling availability requirements. The August 19, 1994 and September 13, 1994, letters provided clarifying information that did not change the initial proposed no significant hazards consideration determination.
2.0 EVALUATION The licensee proposed changes to the minimum low pressure cooling and emergency core cooling system (ECCS) operability requirements during cold shutdown conditions as described below.
2.1 Minimum ECCS In.iection Reouirements i
Existing TS 3.5.F.3 and 3.5.F.4 provide the requirements for ECCS operability when the reactor is in a cold shutdown condition and provides specific ECCS requirements for refueling outage conditions. The licensee proposed to i
implement new requirements that conform to those specified-in NUREG-1433,
" Standard Technical Specifications General Electric Plants, BWR/4" with one exception.
The exception, which is described in Section 2.2 below, adds conservatism to the NUREG-1433 requirements and maintains existing requirements.
Existing TS 3.5.F.3 specifies that when irradiated fuel.is in the vessel and the reactor is in cold shutdown, all core spray (CS), low pressure coolant' injection (LPCI) and containment cooling systems may be inoperable provided no work is underway which has the potential to drain the reactor vessel.
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Existing TS 3.5.F.4 specifies that during refueling activities, both CS systems anj;[ the LPCI system must be operable or the reactor vessel head must be removed, the reactor vessel flooded and connected to the spent fuel pool and no work be performed which has the potential to drain the reactor vessel.
The LPCI system requirements in TS 3.5.F.3 and 3.5.F.4 are currently interpreted to mean all LPCI pumps in both subsystems (total of four pumps).
The proposed implementation of the NUREG-1433 requirements provides the licensee with additional maintenance flexibility while maintaining adequate core flooding capability during shutdown conditions.
Proposed TS 3.5.F.1 changes the required type and number of operable ECCS subsystems.
The proposed requirement is two operable CS subsystems (two CS pumps per subsystem) or one operable CS subsystem and one operable LPCI subsystem (one LPCI pump per LPCI subsystem) when irradiated fuel is in the vessel and the reactor is in cold shutdown.
In the May 10, 1994 application, the licensee stated that only one low pressure ECCS subsystem is necessary to maintain peak cladding temperatures below allowable limits on a long-term basis.
The licensee proposed to add TS 3.5.F.2 and TS 3.5.F.3 which provide action requirements in the event that one of the required susbystems become inoperable.
For instances when one of the required subsystems is inoperable, the. action requirements include restoration of the inoperable subsystem to operable status within four hours or immediate suspension of operations with the potential to drain the vessel.
In instances when both of the required susbsystems are inoperable, the action requirements include immediate suspension of activities with the potential to drain the vessel, restoration of one required subsystem within four hours or immediate initiation of action to establish secondary containment integrity.
The staff concluded that the proposed TS requirements provide assurance that a minimum injection capability will be maintained or appropriate compensatory actions taken and are in conformance with the standards provided'in NUREG-1433 and are therefore acceptable.
2.2 Minimum Vessel Inventory Reouirements Existing TS 3.5.F.4.b allows refueling activities (in which it is implicit that irradiated fuel is in the vessel and the reactor is in cold shutdown) with no ECCS injection subsystems operable provided that sufficient water inventory is available.
The existing TS specifies the water inventory requirements as: 1) the cavity (reactor cavity) is flooded, 2) the spent fuel pool gates are removed, 3) the water level is maintained at least 21 feet over the top of the irradiated fuel and 4) no work is being performed which has the potential for draining the reactor vessel.
i The TS proposed in the licensee's May 10, 1994 application had a similar provision for allowing all injection subsystems to be inoperable provided certain water inventory requirements were met.
However, the proposed water 1
inventory requirements differed from the existing TS in that the requirement to ensure the suspension of all work which had the potential to drain the vessel was deleted.
By telecon on September 12, 1994, the staff informed the licensee that the proposed requirements on vessel inventory were unacceptable l
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based on the deletion of the reference to potential draining activities.
By letter dated September 13, 1994, the licensee revised their May 10, 1994 application to restore the requirement to suspend all work with the potential for draining the reactor vessel.
The proposed revision adds conservatism to the proposed NUREG-1433 based requirements, maintains the vessel inventory requirements of the existing TS, provides margin against uncovering the fuel when the injection systems are inoperable and therefore, is acceptable.
The licensee provided a justification for the proposed plant-specific value of 458 inches above reactor pressure level zero reference which is 20 feet 11 inches above the reactor pressure vessel flange and is equivalent to the existing standard of 21 feet above the top of the irradiated fuel.
The licensee's proposal to use 458 inches in their TS is equivalent to their current TS value and is therefore an acceptable plant-specific value.
2.3 Containment Coolina Reouirements Existing TS 3.5.F.3 states that the containment cooling subsystems may be inoperable when irradiated fuel is in the vessel and the reactor is in cold shutdown provided no work is being done which has the potential for draining the reactor vessel.
The TS requirements of NUREG-1433 proposed by the licensee do not impose requirements for containment cooling during cold shutdown conditions.
The licensee stated in the May 10, 1994 application that, because of the temperature and pressure limitations associated with the cold shutdown condition, primary containment is not required and containment cooling systems are not required to maintain the containment within design limits. The staff finds this assessment and the deletion of requirements on containment cooling system operability during cold shutdown acceptable.
2.4 Surveillance Reouirements The licensee does not currently have any minimum low pressure cooling availability surveillance requirements.
The licensee proposed to adopt the surveillance requirements of NUREG-1433 for minimum low pressure cooling.
The new surveillance tests include requirements to 1) verify adequate suppression pool water level for LPCI pumps every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (proposed TS 4.5.F.1), 2) verify adequate suppression pool and condensate storage tank (CST) level for CS pumps every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (proposed TS 4.5.F.2), 3) verify CS and LPCI subsystem discharge piping is filled at least once per month (proposed TS 4.5.F.3) and
The licensee's proposed plant-specific requirement for 11.0 feet of water in the suppression pool is based on the minimum water level necessary for (1) net positive suction head for the core spray and LPCI pumps, (2) recirculation volume, and (3) vortex prevention.
The licensee's proposed plant-specific value of 17.3 feet for the CST minimum water level is based on the water inventory necessary to allow the core spray system to supply at least 50,000 gallons of makeup water to the reactor pressure vessel.
..,e t The staff concludes that the proposed surveillance requirements add conservatism to the existing TS, are in conformance with those requirements described in NUREG-1433 and are, therefore, acceptable.
The licensee proposed to add surveillance requirements 4.5.F.5 and 4.5.F.6.
Proposed TS 4.5.F.5 provides for periodic system flow testing for both the CS and LPCI subsystems.
The proposed TS is redundant to existing TS 4.5.A.I.d and 4.5.A.3.d, however, it is proposed to maintain consistency with NUREG-1433 format and is therefore, acceptable.
Similarly, proposed TS 4.5.F.6 provides for surveillance testing of the automatic actuation capability of the CS and LPCI subsystems at least once per operating cycle.
It is redundant to existing TS 4.5.A.l.a and 4.5.A.3.a but was proposed to maintain consistency with the NUREG-1433 format and is therefore acceptable.
2.5 Administrative and Bases Chanaes The licensee proposed to revise the TS Table of Contents, cross references in existing TS 3.5.A.1, 3.5.A 3, 3.5.B.1 and 3.7.A.1 and Bases Section 3.5.A, 3.5.F and 4.5 to refl'ect the substantive changes described in sections 2.1-2.4 l
above. The staff finds these changes maintain consistency in the TS and do l
not themselves change any requirements and are therefore, acceptable.
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Pennsylvania State officia'l was notified of the proposed issuance of the amendments.
The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20, and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no l
significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative l
occupational radiation exposure.
The Commission has previously issued a J
proposed finding that the amendments involve no significant. hazards consideration, and there has been no public comment on such finding (59 FR j
37079). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments, i
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5.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
J. Shea Date:
September 16, 1994 b
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