ML20084D423
| ML20084D423 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/25/1995 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9506010106 | |
| Download: ML20084D423 (6) | |
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PECO Energy Company Nuclear Group Headquarters 965 Chesterbrook Boulevard Wayne.PA 19087-5691 May 25,1995 Decket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 j
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
Peach Bottom Atomic Power Station, Units 2 and 3 Supplement 9 to TSCR 9316 Conversion to improved Technical Specifications
References:
Letter from G. A. Hunger, Jr. (PECO Energy) to USNRC dated September 29, f
1994
Dear Sir:
1 Jn the reference letter PECO Energy Company submitted Technical Specifications Change Request (TSCR) 93-16, requesting changes to Appendices A and B of the Facility Operating Licenses for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. This TSCR proposed an overall conversion of the current PBAP,S Technical Specifications to the improved Technical Specifications (ITS), as contained in NUREG 1433, " Standard Technical Specifications, General Electric Plants, BWR/4."
Enclosed is our response to additional questions regarding ITS Section 3.4, " Reactor Coolant System."
if you have any questions, please contact us.
Very truly yours, d
G. A. Hunger, Jr.,f, A,
Director Licensing JLP/bgr Affidavit, Enclosure cc:
T, T. Martin, Administrator, Region I, USNRC W. L Schmidt, USNRC Senior Resident inspector, PBAPS g
R. R. Janati, Commonwealth of Pennsylvania 9506010106 950525
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COMMONWEALTH OF PENNSYLVANIA ss.
COUNTY OF CHESTER
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l H. Smith, III, being first duly sworn, deposes and says:
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l That he is Vice President of PECO Energy Company; the Applicant herein; that he has read the attached response to l
l questions regarding Technical Specifications change Request (TSCR i
93-16, Supplement 9) for changes to the Peach Bottom Facility l
l 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.
l A o,n V
Vice President l
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Subscribed and sworn to before me this.)f/4 day of 1995.
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PEACH BOTTOM ATOMIC PODER STATION, UNITS 2 AND 3 RESPONSES TO ADDITIONAL NRC QUESTIONS REGARDING IMPROVED TECHNICAL BPECIFICATIONS SECTION 3.4 NRC Question 5:
This change allows for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to comply with the LCO for reasons other than Thermo-hydraulic instability.
The second part of the LCO for operation in single loop requires i
that RPS setpoints be adjusted for the Average Power Range Monitors Flow Blased High Scram.
It would appear that l
Action D.1 would allow up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to reset the APRM Flow Biased High Scram setpoints.
ITS section 3.3.1.1 requires actions which are more restrictive than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to be taken if an instrument is determined to be inoperable.
Provide information on what the time limits will be resetting the APRM Flow Biased High Scram.
PECO Energy Response regarding ITS LCO 3.4.1, DOC L :
1 Required Action D.1 of Specification 3.4.1 allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to satisfy the LCO.
This would allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to recalibrate the APRM Flow Biased High Scram setpoints if the unit was going to stay in single loop operation.
- However, once the LCO is satisfied for either single loop or two loop operation, any subsequent calibration problems associated with the APRM Flow Biased High Scram channels would require entry into the applicable Conditions of Specification 3.3.1.1,
" Reactor Protection System Instrumentation."
A siinilar rationale holds true for the power distribution limits specified in the LCO.
Concern:
1.
This technical specification (3.4.1) allows up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to reset the APRM setpoint to a lower value.
Section 3.3.1.1 only allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for action for an inoperable channel.
2.
CTS section 3.6.F rcquires the single loop requirements to be initiated within 6 hocrc or be in Hot Shutdown within the l
following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
The ITS is less restrictive than CTS in performing these actions.
This discrepancy between Specifications 3.4.1 and 3.3.1.1 has been recognized by the staff and a proposed generic change to NUREGs-1433 and 1434 is being prepared.
That proposed generic change adds an Note to LCO 3.4.1 which reads:
NOTE-------------------------------
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Required limit modifications for single recirculation loop operation may be delayed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after transition l
from two recirculation loop operation to single recirculation loop operation.
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PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 RESPONSES TO ADDITIONAL NRC QUESTIONS REGARDING IMPROVED TECHNICAL SPECIFICATION 8 RECTION 3.4 All four BWR/6's have or will have such a note in their ITS.
The staff believes such a note should be added to ITS LCO 3.4.1 for Peach Bottom to eliminate any confusion brought on by the inconsistency with specification 3.3.1.1 and the need to enter Condition D just to transition from two loop J
operation to single loop operation.
Please provide a i
response to the staff's proposed solution to this concern.
PECO Energy Response to NRC concern regarding ITS LCO 3.4.1, DOC L 3 In order to eliminate any potential confusion brought on by the inconsistency with Specification 3.3.1.1, Reactor i
Protection System, and the need to enter Condition D of
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Specification 3.4.1, Recirculation Loops Operating, just to j
transition from two loop operation to single loop operation, 4
the proposed Note to LCO 3.4.1 will be added to the PBAPS ITS.
NRC Question 7:
CTS 3.6.E.1 requires that "...the reactor shall be in a Cold Shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" and ITS section 3.4.2 a requires "Be in MODE 3" in "12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."
Placing the reactor in Cold Shutdown required temperature to be reduced to less than 212 F if a Jet Pump was inoperable.
MODE 3 requires plant shutdown but does not require reduction in temperature.
Provide documentation that reduction in temperature is no longer required if a jet pump has been determined to be inoperable.
PECO Energy Response In the CTS, the Applicability of the specification 3.6.E,
" Jet Pumps," is whenever the reactor is in the startup or run modes (mode switch position as defined in CTS 1.0).
CTS 3.0.A states action requirements are applicable during the operational conditions of each specification.
As a result, to place the plant in a non-applicable condition in the case of a shutdown required by Specification 3.6.E, the mode switch can be placed in shutdown or refuel without requiring temperature to be reduced to $ 212*F.
Placing the mode switch in shutdown is equivalent to MODE 3 in ITS.
As a result, temperature reduction is not required by the CTS if a jet pump is inoperable.
Concern:
CTS 3.6.E.1 states:
Whenever the reactor is in the startup or run modes, all jet pumps shall be operable.
If it is determined that a jet pump is inoperable, an orderly shutdown shall be initiated and the reactor shall be in a Cold Shutdown within 24 hdurs.
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PEACH BOTTOM ATOMIC POWER CTATICN, UNITJ 2 AND 3 RESPONSE 8 TO ADDITIONAL NRC QUESTIONS REGARDING IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.4 CTS 3.0.A states:
Limiting condition for operation and action are applicable during the operational conditions and other states specified for each specification.
While there is a conflict in requirements between CTS 3.6.E.1 and 3.0.A, the staff believes that the ITS l
represents a less restrictive requirement for an inoperable i
jet pump than the CTS, not a more restrictive requirement, because the ITS Required Action does not require taking the unit to a cold shutdown condition.
Please provide a DOC justifying this change as a less j
restrictive requirement.
PECO Energy Response to NRC concern regarding ITS LCO 3.4.2, DOC M 3 DOC M for ITS 3.4.2 will be deleted and a new DOC i
justifying this change as less restrictive will be provided as follows:
L.
Current Technical Specification (CTS) 3.6.E.1 states that if it is determined that a jet pump is inoperable, an orderly shutdown shall be initiated and the reactor shall be in Cold Shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
ITS 3.4.2, Jet Pumps, for the Condition of an inoperable jet pump, requires the reactor to be placed in MODE 3 (Hot Shutdown) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Since the ITS shutdown action does not require placing the unit in MODE 4 (Cold Shutdown), the change to the shutdown action has been categorized as a less restrictive change.
The change is considered acceptable since the Applicability of CTS 3.6.E, Jet Pumps, is whenever the reactor is in the startup or run modes (mode switch position as defined in CTS 1.0, Definitions).
The Applicability of ITS 3.4.2 is MODES 1 and 2, which are equivalent to the run and startup modes, respectively, of the CTS.
In the event of a failure to comply with requirements of the LCO, the reactor must be placed in a non-applicable MODE or condition.
The ITS change reflects placing the reactor in the first available non-applicable MODE or condition.
This change also achieves consistency with CTS 3.0.A.
CTS 3.0.A states " Limiting Conditions for Operation and action requirements are applicable during the operational conditions and other states specified for each specification."
Since the applicability of the CTS jet pumps limiting condition for operation and action is with the mode switch in startup or run, placing the mode switch in shutdown (MODE 3 in the ITS) results in exiting the jet pump condition of applicability.
As a result, any further reduction in MODE or condition (to Cold Shutdown) is not required per CTS 3.0.A.
In addition, not requiring the reactor to be placed in Cold Shutdown (mode switch in shutdown 3
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PEACH BOTTON ATONIC POWER CTATION, UNITS 2 AND 3 RESPONSES TO ADDITIONAL NRC QUESTIONS REGARDING INPROVED TECHNICAL 8PECIFICATIONS SECTION 3.4 PECO Energy Response to NRC concern regarding ITS LCO 3.4.2, DOC M (continued) i and average reactor coolant temperature 5 212*F) reduces the potential for an unnecessary shutdown transient and the resultant thermal effects on plant equipment.
DOC M for ITS 3.2.1, 3.2.2, and 3.2.3 will also be deleted 3
and a new DOC justifying the changes as less restrictive will be provided as follows:
L CTS 3.5.I (APLHGR), 3.5.J (LHGR), and 3.5.K (MCPR) 2 require that if it is determined that the associated power distribution limit is not restored within the required time period, the reactor shall be in a Cold Shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
ITS 3.2.1 (APLHGR), 3.2.2 (MCPR), and 3.2.3 (LHGR) require that if the associated power distribution limit is not restored within the required Completion Time, reactor thermal power must be reduced to below 25% RTP within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
Since the ITS shutdown action does not require placing the unit in MODE 5 (Cold Shutdown), the change to the shutdown action has been categorized as a less restrictive change.
The change is considered acceptable since the Applicabilities of CTS 3.5.I, 3.5.J, and 3.5.K are during reactor power operation at 2 25% rated thermal power.
The Applicabilities of ITS 3.2.1, 3.2.2, and 3.2.3 are when THERMAL POWER is 2 25% RTP, which are equivalent to the CTS Applicabilities.
In the event of a failure to comply with requirements of the LCO, the reacter must be placed in a non-applicable MODE or condition.
The ITS change reflects placing the reactor in the first available non-applicable MODE or condition.
This change also achieves consistency with CTS 3.0.A.
CTS 3.0.A states " Limiting Conditions for Operation and action requirements are applicable during the operational conditions and other states specified for each specification."
Since the applicability of the limiting condition for operation and actions for the CTS power distribution limits are during reactor power operation at 2 25% rated thermal power, reducing reactor thermal power to below 25% RTP results in exiting the power distribution limits' conditions of applicability.
As a result, any further reduction in MODE or condition (to Cold Shutdown) is not required per CTS 3.0.A.
In addition, not requiring the reactor to be placed in Cold Shutdown (mode switch in shutdown and average reactor coolant temperature 5 212*F) reduces the potential for an unnecessary shutdown transient and the resultant thermal effects on plant equipment.
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