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Application for Amends to Licenses DPR-44 & DPR-56 Re Requirements for SRMs While in Refueling Condition
	ML20081H126
Person / Time
Site:	Peach Bottom
Issue date:	03/16/1995
From:	Hunger G; PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20081H128	List: ML20081H126; ML20081H138;
References
	NUDOCS 9503240101
	Download: ML20081H126 (7)
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Station Support DeptrtmInt

' 10 CFR 50.90

. .. d PECO ENERGY if Mr3="L,

- 965 Chesterbrook Doulevard Wayne, PA 19087-5691 March 16,1995 Docket Nos. 50-277 50-278 ,

License Nos. DPR-44 DPR-56 !

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.l U. S. Nuclear Regulatory Commission !'

Attn: Document Control Desk Washington, DC 20555 l

&W Peach Bottom Atomic Power Station, Units 2 and 3 Technical Specifications Change Request 94-18

Dear Sir:

PECO Energy Company hereby submits Technical Specifications Change Request (l'SCR) No. ,

94-18, in accordance with 10 CFR 50.90, requesting a change to Appendix A.of the Peach i Bottom Atomic Power Station, Units 2 and 3 Factity Opera;ing Liconess The proposed changes !

involve the requirements for the Source Range Monitors (SRMs) whBe in the refueling condition. l The proposed changes are based on the improved Technical Specifications (ITS) contained in !

NUREG-1433, " Standard Technical Specifications General Electric Plants, BWR/4." Byletter i dated September 29,1994, PECO Energy submitted TSCR No. 93-16 requesting an overaR j

, conversion to the ITS. The SRM changes contained in this TSCR are consistent with our j l September 29,1994 submittal PECO Energy is submitting TSCR No. 94-18 so that the ;

l enhancements to the SRM requirements can be implemented in advance of the overaR !

conversion, in support of the gei.a PBAPS, w Unit 3 refueling outage scheduled for fan of 1995. Therefore, we request that the proposed changes be issued on or before August 1,1995 for PBAPS, Units 2 and 3, and the changes be made effective immediately. !

Attachment I 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 cere,,iaq this matter, please do not hesitate to contact us. i Very truly yours, G. A. Hunger, Jr.,

Director - Licensing j

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Enclosures:

Affidavit, Attachment 1, Attachment 2 cc: T. T. Martin, Administrator, Region I, USNRC j .- W. L Schmidt, USNRC Senior Resident inspector, PBAPS l R. R. Janati, Commonwealth of Pannsylvania 9503240101 950316 fA D

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COMMONWEALTH OF PENNSYLVANIA :

as.

COUNTY OF YORK :

G. R. Rainey, being first duly swom, deposes and says: ,

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That he is Vice President of PECO Energy Company; the Applicant herein; that he haa read the l attached Technical Specifications Change Request (Number 94-18) for Peach Bottom Faculty Operating l Licenses OPR-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. I i

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i Subscribed and swom to before me this 15th day of March . 1995.

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Notary Public NoterialSeel .

JanetL NotaryPutic Peach WrkCounty hlyCommiselon June 13,1996 Morntw,Pennspania Wof Notense

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l ATTACHMENT 1 .;

i PEACH BOTTOM ATOMIC POWER STATION I I UNITS 2 AND 3 i l 1 l

Docket Nos. 50-277 50-278 Ucense Nos. DPR-44 i DPR-56 TECHNICAL SPECIFICATION CHANGE REQUEST l 94-18 i

" incorporation of improved Technical Specifications

, Source Range Monitor Mode 5 Requirements" l

Supporting Information for Changes 4 Pages l

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1 l DoclC3 Nos. 50-277 I

. 50-278 :

License Nos. DPR-44 '

4 DPR-56 I

Introduction i

PECO Energy Company (PECO Energy), Licensee under Faculty Operating Licenses DPR-44 and DPR-

- 56 for the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, requests that the Technical 1 Specifications (TS) contained in Appendix A of Operating Licenses Nos. DPR-44 and DPR-56 be amended. The proposed changes involve the requirements for the Source Range Monitors (SRMs) in 4 the refuel mode. Proposed changes to the TS are shown in Attachment 2 for PBAPS, Units 2 and 3. ;

. The proposed change pages are: 103,227,228,231 and 232. j l

In order to support the upcoming PBAPS, Unit 3 refueling outage, we request that the proposed j

changes be issued on or before August 1,1995 for PBAPS, Units 2 and 3, and the changes be made '

effective immediately. i This TS change request provides a discussion and description of the proposed TS change, a safety l

, discussion of the proposed TS change, information supporting a finding of No Significant Hazards ,

j Consideration, and information supporting an Environmental Assessment.

I Discussion

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. Current TS SurveR!ance Requirement (SR) 4.10.B.1 requires a daHy neutron response test wh8e

! performing core alterations. Performance of this response test requires the suspension of core alterations for a period of approximately one to one-andone-half hours per day. Core alterations is a critical path activity, and any delay in it results in additional cost due to an extended refueling outage.

1 Radiation exposure is also incurred in the preparation of the neutron response test. In lieu of the daRy 4

neutron response test, PECO Energy proposes to replace the TS requirements for the SRMs, in the 4 l refuel mode, with the requirements of the PBAPS, Units 2 and 3 (Improved Technical Specifications) ITS j

. for the SRMs in the Mode 5 condition. The Mode 5 SRM requirements of the iTS wNI provide an j adequate level of testing and verification to ensure the operabRity of the SRMs in the refuel mode whRe :

avoiding core alteration delays.

The proposed ITS for PBAPS, Units 2 and 3 were submitted to the U. S. Nuclear Regulatory Commission

(USNRC) for approval in a letter from G. A. Hunger, Jr. to USNRC, dated September 29,1994 (Technical Specifications Change Request No. 93-16). This submittal to revise the PBAPS, Units 2 and 3 TS, in their entirety, was based on NUREG-1433, " Standard Technical Specifications General Electric Plants, BWR/4." The conversion to the ITS included both technically justified deviations from the NUREG, and technically justified changes from the PBAPS current TS.

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The changes proposed in this Technical Specitications Change Request (TSCR) are consistent with the September 29,1994 ITS submittal.

i Discussion of the Prooosed Chanaes i

The discussion of changes is as follows:

1. Current TS Limiting Condition for Operations (LCO) 3.3.B.4 and Survellance Requirement (SR) 4.3.B.4 are being revised to remove the refuel mode requirements. These re'uel mode

requirements are being relocated to new TS SR 4.10.B.3. The revised TS SR 4.10.B.3 wHl allow use of the signal-to-noise ratio curve, but requires verification of 3 cps per operable channel. SR 4.10.B.3 is required to be performed prior to entering the refuel mode, and daRy whle in the

! refuel mode, and prior to core alterations, and every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months during core alterations.

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Docket Nos. 50-277

. 50-278

. License Nos. DPR-44

< DPR-56

2. Current TS LCO 3.10.B.1 is being revised such that while in the refueling mode, two SRMs are required to be operable (now TS LCO 3.10.B.1) except as stated in TS LCOs 3.10.B.2,3.10.B.4 and 3.10.B.5. Exceptions identified in the current TS LCO 3.10.B.1 are being revised or deleted.

3. The existing portion of TS LCO 3.10.B.1, which provides the requirements for determining an operable SRM, is being maintained and renumbered 3.10.B.3. A reference to the signal-to-noise ratio of Figure 3.3.1 is being relocated to TS LCO 3.10.B.3.b.

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4. New TS LCO 3.10.B.2 is being added to allow only one SRM channel wh5e performing spiral ofRoad or reload.

5. The SRM count rate requirements of the current TS LCOs 3.10.B.2 and 3.10.B.3 are being relocated to new TS SR 4.10.8.3. The revised TS SR 4.10.B.3 wul continue to allow use of the signal-to-noise ratio curve.

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6. Current TS LCO 3.10.B.2 is being deleted and replaced with spiral unloading requirements of new SR 4.10.B.3.

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i 7. Current TS LCOs 3.10.B.3 and 3,10.B.5 are being replaced with the requirements of new TS SR 4.10.B.3.

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8. New TS LCO 3.10.B.4 is being added to require that if one or more SRMs are inoperable while in the refuel mode: 1) core alterations are to be immediately suspended, except for control rod insertion, and 2) actions are to be immediately initiated to fury insert aH insertable control rods in core cens containing one or more fuel assemblies.

9. Current TS SR 4.10.B.1 requires a functional test and a check for neutron response prior to making any core alterations. Additionally, whle required to be operable, the current TS require that SRMs will be checked daly for response This TS is being deleted and replaced with new TS SR 4.10.B.1 which requires that, prior to entering the refuel mode and every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter whBe in the refuel mode, a channel check shall be performed for each required SRM.

10. Current TS SR 4.10.B.2 is being deleted and replaced with a channel functional test and determination of signal-to-noise ratio every 7 days, prior to, and whIe in the refuel mode (now SR 4.10.B.4) and a channel check every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , prior to, and whue in the refuel mode (now SR 4.10.B.1).

11. New TS SR 4.10.B.2 is being added to replace existing TS LCO 3.10.B.1 and 3.10.B.5 requirements for the location of operable SRMs during core alterations and during core unloading and reloading. This TS wil also add a requirement to verify the location of the operable SRMs prior to performing core alterations, and every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter during core alterations.

12. Two additional testing requirements are being added which include: 1) (now TS SR 4.10.B.4) prior to entering the refuel mode and every seven days thereafter whle in the refuel mode, perform a channel functional test and determination of signal-to-noise ratio, and 2) (now TS SR i 4.10.B.5) prior to entering the refuel mode and every 184 days thereafter whle in the refuel mode, a channel calibration shaR be performed for each required SRM.

13. Current Bases 3.10 and 4.10 are also being revised to reRect the incorporation of the new testing requirements.

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Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 l

l As a part of the comparison between the current PBAPS, Units 2 and 3 TS and the ITS submittal of September 29,1994, definitions have been reviewed. In particular, the definition of Core Alterations and Refueling Mode were reviewed. Also reviewed were the current TS Section 3.0 and the proposed ITS Section 3.0. These were reviewed to ensure that application of the current " motherhood rules" would not result in an interpretation of the proposed changes which is different from that intended by the proposed ITS.

The proposed changes addressed above are consistent with the proposed ITS submittal to the NRC on September 29,1994. Accordingly, they include various deviations from NUREG-1433. These deviations are included in the ITS submittal of September 29,1994, Volume 13, which provides justification for the proposed deviations from NUREG-1433 for ITS Section 3.3.1.2.

Safety Discussion The purpose of the SRMs, which is a subsystem of the neutron monitoring system, is to detect and monitor low flux conditions in the core and provide operator indication on the state of criticality within the reactor.

The SRMs provide neutron flux information during core alterations, the refuel mode, reactor startup, and I low flux operations. The SRMs are capable of generating a trip signal to block control rod withdrawai if I

the count rate exceeds a preset value or if the SRMs are not operating property. There are four SRM channels, each of which includes one detector that can be positioned in the core from the control room.

Any one SRM channel can initiate a rod block. During a reactor startup, the detectors may be withdrawn after neutron flux is indicated on the intermed! ate range monitors.

PECO Energy proposes to replace the current TS requirements for the SRMs, in the refuel mode, with the requirements of the proposed PBAPS, Units 2 and 3 ITS for the SRMs in the Mode 5 condition. The SRM requirements proposed herein will provide an adequate level of testing and verification to ensure the operability of the SRMs in the refuel mode. All other modes will maintain the current TS requirements for the SRMs.

l l The SRMs are not assumed to function during any analyzed UFSAR design basis accident or transient.

l Implementation of the proposed changes will not involve any physical changes to plant structures, I systems, or components. Additionally, this TS change will not alter any safety limits which ensure the integrity of fuel barriers.

Information Succortina a Findina of No Sianificant Hazards Consideration We have concluded that the proposed changes to the PBAPS, Units 2 and 3 TS do not constitute a Significant Hazards Consideration. In support of this determination, an evaluation of each of the three (3) standards set forth in 10 CFR 50.92 is provided below.

1) The crocosed chance does not involve a slanificant increase in the orobability or conseauences of any accident oreviousiv evaluated.

l The proposed changes to the SRM requirements will not increase the probability or i consequences of an accident previously evaluated. The SRMs are not assumed to function I

during any UFSAR design basis accident or transient analysis. This TS change will not alter any safety limits which ensure the integrity of fuel barriers, and will not result In any increase to onsite or offsite dose. Additionally, continued availability of the SRMs in the refuel mode is ensured through additional testing requirements being added by this TS change. The changes to the SRM requirements will not alter the operation of equipment assumed to be available for the mitigation of accidents or transients.

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Docket Nos. 50-277 50-278

. License Nos. DPR-44

. DPR-56 The prapnand changes are based on NUREG-1433, " Standard Technical Specifications General Electric Plares, BWR/4,* and are consistent with the PECO Energy submittal of September 29, 1994, requesting an overal conversion, based on NUREG 1433. The overall conversion to the j ITS included both technically justNied deviations from the NUREG, and technicely justified I changes from the PBAPS current TS. l q

2) The oracomed change does not create the possibilty of a now or different idnd d accident from any oreviousiv evaluated.

The proposed changes to the SRM requirements wIl not create the imMlly of a new or j dligerent type of accident from any previously evaluated. The SRMs are not assumed to function ,

during any analyzed UFSAR design basis accident or transient analysis. Additionsby, the changes wIl not involve any changes to plant systems, structures or components (SCCs) which .

could act as new accident initiators. Implementation of the proposed changes wIl ellect the j manner in which these SSCs are tested; however,-TS requirements that govem routine testing )

and verification of plant components and variables are not assumed to be initiators of any l analyzed event.

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3) The oronosed change does not result Irl a significant reduction in the maroin of asletv. i No margins of safety are reduced as a result of the proposed TS changes. No salsty limits wil ..I be changed as a result of this TS change. The proposed change does not involve a reduction in the margin of safety because SRMs are not credited in any safety analysis. At least one SRM wil remain operable during rod withdrawal during core alterations and rod withdrawal wil not occur if no SRMs are operable Excessive reactivky additions wIl be quicidy identNied and -

mitigated by the Intermediate Range Monitors and associated rod blocks. The Average Power Range Monitor Flux scram, and not any SRM function, is credkod for mitigating a rod withdrawal or reactivity addklon accident.

Use of a spiral offload or reload pattom wul provide assurance that the SRM wIl be in the optimum position for monitoring changes in neutron flux levels during core alterations.

The changes proposed in this TS change do not introduce any hardware changes, and wIl not

, alter the intended operation of plant structures, systems or components utilized in the mitigation

! of accidents or transients. Additionaby, these changes wil not introduce any new falure modes of plant equipment not previously evaluated.

Information Suocorting an Environmental Assessment An environmental assessment is not required for the changes proposed by this TSCR since the l requested changes conform to the crkeria for " actions eliglble for categorical exclusion' as specllied in i 10 CFR 51.22(c)(9). The requested changes wul have no impact on the environment. The proposed I changes do not involve a significant hazards consideration as discussed in the preceding section. The proposed changes do not involve a significant change in the types or significant increase in the amounts of any effluents that may be released offsite. In addklon, the propoemd changes do not involve a significant increase in individual or cumulative occupational radiation exposure. l Conclusion l

, The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes to the PBAPS, Units 2 and 3 TS and have concluded that the changes do not involve an unreviewed safety question and will not endanger the health and safety of the public.

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ML20081H126

Text

Dear Sir:

Enclosures:

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