ML20079C937
| ML20079C937 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/12/1991 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20079C935 | List: |
| References | |
| NUDOCS 9106260365 | |
| Download: ML20079C937 (4) | |
Text
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1.0 INTRODUCTION
By letter dated January 30, 1990, as supplemented by letter dated April 9, 1991, the Philadelphia Electric Company (PECo or licensee) submitted a request for changes to the Peach Bottom Atomic Power Station, Units 2 and 3, Technical Specifications (TS). The requested changes would revise the testing requirements for other systems or subsystems of the Emergency Core Cooling Systems (ECCS), Reactor Core Isolation Cooling (RCIC) system, and High Pressure Service Water (HPSW) system when one system or subsystem is inoperable; revise the operebility requirements of several ECCS and RCIC systems and incorporate some administrative changes. The April 9, 1991, letter provided clarifying information that did not change the initial proposed no significant hazards consideration determination.
2.0 E_ VALUATION Present Peach Bottom Atomic Power Station, Units 2 and 3 Technical l
Specification surveillance requirements for ECCS, RCIC, and HPSW systems provide for demonstrating the operability of redundant systems or subsystems j
when one system or subsystem is inoperable. The Emergency Core Cooling l
Systems are comprised of the Core Spray, Low Pressure Coolant Injection, High l
Pressure Coolant Injection, and Automatic Depressurization subsystems. These testing requirements are as follows:
(1) One Core Spray suasystem inoperable - demonstrate operability within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the operable core spray subsystem and the Low Pressure Coolant Injection (LPCI) subsystems.
Demonstrate operability of the same every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> thereafter.
(2) One LPCI pump or subsystem inoperable - demonstrate operability within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the operable LPCI pumps / subsystem and core spray sub sy s tems. Demonstrate operability of the sam.e every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> thereafter.
(3) Two HPSW pumps inoperable - demonstrate operability immediately of the operable HPSW pumps. Denonstrate operability of the same weekly thereafter.
9106260365 910612 PDR ADOCk 05000277 P
- (4) Three HPSW pumps inoperable - den'onstrate operability immediately of the operable HPSW pump and its diesel generator. Demonstrate operability of the operable HPSW pump weekly thereaf ter.
(5) One torus cooling loop inoperable - den.onstrate operability inrediately of the operable torus cooling loop and its diesel generators.
(6) One drywell spray loop inoperable - demonstrate operability inmediately of the operable drywell spray loop and its diesel generators.
(7) One torus spray loop inoperable - demonstrate operability immediately of the operable torus spray loop and-its diesel generators.
(8) High Pressure Coolant Injection (HPCI) system inoperable - demonstrate operability immediately of the RCIC system and operable subsystems of the ECCS. Demonstrate operability of the RCIC system and ADS actuation logic daily thereafter.
(9) RCIC system inoperable - demonstrate operability immediately of the HPCI subsystem.
Demonstrate operability of the HPCI subsystem weekly th erea'. i.er.
(10) One Automatic Depressurization System (ADS) valve inoperable -
demonstrate op., ability immediately of the HPCI subsystem and ADS actuation logic for operable ADS valves.
Demonstrate operability of the same weekly thereafter.
The licensee proposed to remove the redundant system testing requirements from the ECCS, RCIC, and HPSW systems sections of the Technical Specifications (Section 4.5) while maintaining adequate assurance of system operability needed for accident mitigation.
The requirement for demonstrating operability of the redundant systems identified above for Peach Bottom Atomic Power Station, Units 2 and 3 was originally chosen because there was a lack of plant operating history and a lack-of sufficient equipment failure data.
Since that time, plant operating experience has demonstrated that testing of the redundant ECCS, RCIC, and HPSW systems when one system or subsystem is inoperable is not necessary to provide adequate assurance of system operability.
In fact, taking the redundant
-system out of service for testing creates the potential of an operator error that would keep the "edundant system out of service due to this system being erroneously lef t in the testing mode. Operability of these systems can be verified by administratively checking equipment status relative to operability requirements.
The current Standard Technical Specifications (STS) and, more specifically, technical specifications approved for recently licensed BWR's accept the philosophy of system operability based on satisfactory performance of monthly, quarterly, operating cycle interval, post maintenance or other e
1 e
. i specified performance tests without requirir,g additicnal testing when another j
53 stem is ir. operable (except for testing in response to an inoperable diesel generator or inoperable offsite circuit).
The staff reviewed PECO's Jan m y 30, 1990 submittal to confirm that the testing requirements for the redundant systems or subsystems contained in the existing Technical Specifications, as modified by the proposed an.endrents, were equivalent with the requirements contained in the Standard Technical Specifications.
In Table 10 of PEco's January 30, 1990 submittal, a conparison between the peach Ecttom Technical Specifications and the Standard Technical Specifications was pravided.
The staff has reviewed this submittal and determined the proposed Technical Specifications requirenents for Peach Cottom are equivalent with those of the Standard Technical Specifications and those of recently licensed BWR's with regard to the testing requirenents for redundant systcms for the ECCS, CCIC, and FPSW systems.
On this basis, the fact that testing of the redundant system creates the risk of the second system failing, and past operational experience, the staff has determined that the revised testing requirements for the ECCS, RCIC, and HPSW systems are acceptable.
In PEco's safety assessment supporting the subject application anti in the
-proposed 4.5 Bases on page 141, the licensee stated that when one train becomes inoperable (1) the redundant trair. will be verified to be operable by administrative 1y checking equipment status reletive to operability requirements and (2) the nature of and cause for each condition for inoperability should be individually evaluated to identify generic-implications, if any, and to determine whether testing of other systems is warranted.
By letter dated January 24, 1991, we requested that the licensee describe on n
the record what specific actions will be performed to verify operability and how the proposed actions will be implemented.
In our letter, we also noted that the. proposed wording for the 3.5.A Bases on page 135 could possibly be misconstrued.
The licensee re:,ponded by letter dated April 9, 1991, expounding on what specific actions would be taken to check equipment status and their process for assessing potential generic implications. Although not i
requested to do so, the licensee resised the Bases on pages 135 and 141 for both the Unit 2 and 3 TS$ to elaborate on what actions would be taken to verify operability and to clarify the Bases for the seven day LCO period when one LPCI subsystem is not available. These two new pages only revised the
- Bases;- there were no changes to the LCOs or Surveillance Requirements in the TSs. The supplemental letter of April 9, 1991 provided clarification but in no way changed the substance of the initial application and did not ptovide
.any information that would change or affect tie staff's "No Significant Hazards Consideraticn" as published in the Federal Register on December 26, 1990 (55 FR 53074).
in addition, miscellaneous changes to the Technical Specifications have been proposed which are administrative in nature. The-staff has reviewed the proposed changes and determined that the changes achieve consistency throughout
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the technical specification:., provide clarificatioto, or correct errors, and thus are acceptable.
The proposed ct at:ge to the operability requirenents for HPC1, FClC, and ADS to titcify that the systen s shall be operable whenever there is irradiated fuel in the reactor vessel and reactor steera pressure it.
gr eater than 105 psig provides clarification to the current Technical Specificatier s and is consistent with the function of these systens as described in the Technical Specifications bases and the facility's updated final tafety enelysis report.
On this basis, the proposed change is ecceptable.
3.0 ST ATE C ONSJLL,1 AT),0N in accordance with the Coneission's regulations, the Pennsylvania State official was notified of the proposcd issuance of the arnendn;ent. The State of ficial had no comr,ents.
4.0 ENVIR0tmEllTAL CONSIDERAT10f4S These artendn,ents involve a change to a requiren,ent with respect to the installation or use of a facility corporient located within the restricted area as defined in 10 CFR Part 20 and changes to the surveillance requirenents.
The NRC staff has determined that the an,endrnents involve no significant increase in the an,ounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.
The Cornission has prcviously issued a proposed findir.g that the arnendntents involve no sienificant hazards consideration and there has been no public convent on such finding, Accordingly, the anendments nieet the eligibility criteria for categorical exclusion set foith in 10 CFR 51.PF(c)(9).
Pursuant to 10 CFR 51.TT(b), no environr. ental inpact staterent nor environmental assessment need be prepared in connection with the issuance of the amendments.
5.0 CONCLUSION
The Consission 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, (T) such activities will be conducted in compliance with the Conmission's regulations, and (3) the issuance of the amendnents will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
G. Y. Suh, R. Clark Date:
June 1?, 1991 1
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