ML20086A634
| ML20086A634 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/10/1983 |
| From: | Bauer E, Bradley E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20086A614 | List: |
| References | |
| NUDOCS 8311160052 | |
| Download: ML20086A634 (11) | |
Text
BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 AMENDMENT TO A MAY 3, 1983 APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 & DPR-56 Edward G. Bauer, Jr.
Eugene J. Bradley 2301 Market Street Philadelphia, Pennsylvania 19101 Attorneys for Philadelphia Electric Company 0311160052 831110 Ci PDR ADOCK 05000277
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PDR A
BEFORE THE
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UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 i
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l AMENDMENT TO MAY 3, 1983 APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 & DPR-56 On May 3, 1983, Philadelphia Electric Company, Licensee under Facility Operating Licenses DPR-44 and DPR-56 for Peach Bottom Units 2 and 3, filed an Application for Amendment of the Licenses which requested, amorg other things, that the. Technical Specifications contained in Appendix A of the Operating Licenses ~
be amended to meet the coolant leakage criteria identified in 1
LUREG 0313, " Technical Report on Material Selection and Processire Guidelines for BWR Coolant Pressure Boundary Piping."
Subsequently, as an Attachment V to a letter to D. G.
Eisenhut (NRC) from S. L. Daltroff, dated May 23, 1983, relative I
to returning Unit 2 to service following inspection of selected primary system welds for integranular stress corrosion cracking,.
the following justification was provided for modifying the limiting condition for operation such that the rate of change of l
2 qpm per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> surveillance period is applicable only when the reactor mode switch is in the RUN position.
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" Standard Technical Specifications apply this LCO to reactor operations-in the RUN, STARTUP or HOT SHUTDOWN mode.
During reactor operations in the startup mode, large variations in primary coolant system pressure result in changes of measured leakage not indicative of l
system degradation.
This rate of change criteria, if applied during STARTUP operations, could preclud's reactor power operation since the LOO for the rate of change of unidentified leakage would most likely be exceeded, resulting in unit shutdown.
The maximum leak rate of 5 gallons per minute during the limited duration-of the startup phase will assure primary coolant system integrity during this time period."
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In response to Generic Letter 81-04 on Implementation of NUREG-0313, Rev. 1, on December 15, 1982, in a letter to J.
F.
Stolz (NRC) from S. L. Daltroff, the Licensee identified the methods to detect and monitor unidentified leakage in the pressure boundary piping.
The Airborne Radioactivity Monitoring System was one of the systems discussed.
This discussion pointed out that the reliability, sensitivity, and response times of these airborne radiation monitors to detect Reactor Coolant Pressure Boundary (RCPB) leakage depends on many complex factors, such ass (A) Source of Leakage -
- 1) Location of I3akage, 2)
Coolant Concentrations, and 3) Other Sources of Leakager (B)
Drywell Conditions-
- 1) Eauilibrium Activity Levels, 2) Purge and Pressure Release Effects, and 3) Plateout, Mixing, Fan Coolant Depletion; and (C)
The Physical Properties and Capabilities of the Detectors - 1) Detector Ranges, 2) Sensitivity, and 3)
Counting Statistics and Monitor Uncertainties.
The conclusions that were made in the December 15, 1982, response were:
1)
"That airborne-concentrations cannot be directly correlat'ed to a-quantity of leakage without knowing the source of the leakage";
1!) " An increase in the coolant concentration could give increased containment concentrations when no increase in unidantified i
leakage occurs"r.3) "Since the unidentified leakage is:not the j
sole source of activity in the containment, changes.in other sources will result in changes in the containment airborne 4
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concentrations"; 4) Not uncommon high Drywell equilibrium activity levels make it difficult to detect small increases in leakager 5) "There is no direct correlation or known relationship between the detector count rate and the leakage rate, because the coolant activity levels, source of leakage and background radiation levels (from leakage alone) are not known and cannot be cost-effectively determined in existing reactors."
For all of the reasons cited from the December 15, 1982, response, and afte'r discussions with the NRC staff, the Licensee submitted revised surveillance requirements and limiting conditions for operation on August 9, 1983, as Attachment F to a letter from S. L.
Daltroff (PECo) to Dr. Thomas E. Murley (NRC) dealing with -
Response to I. E.
Bulletin 83-02 (Bulletin concerning stress corrosion cracking in large diameter stainless steel recirculation system piping).
This August 9, 1933,-revision deleted any requirements for the Air Sampling System existing from Technical Specification pages 146 and 146a.
Consequently,.
this-amendment to the May 3, 1983, amendment hereby deletes.any limiting conditions for operation, surveillance requirements, calibration frequency requirements and bases for the Drywell air i
monitoring systems from pages 76, 85 and 93 of the Technical Specifications relative to detecting'Drywell leakage.
On August 23, 1983,.the NRC staff sent to Philadelphia Electric Company a request for additional compensatory-measures 4
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following refuel outage where repairs had been done to recirculation and RHR system piping welds.
Among their requests was a commitment to follow additional limiting conditions for l
operation,and surveillance requirements until an amendment to the license could be submitted.
This request was I
"At least one primary containment sump collection and flow monitoring system shall be operable.
With the primary containment sump collection and flow monitoring system inoperable, restore the inoperable system to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or immediately initiate an orderly shutdown and be in at least hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in cold shutdown within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."
I The Licensee committed to this requect in a letter to Dr. T. E. Murley (NRC), from S. L. Daltroff, dated August 24, 1983.
The intent of this request has been incorporated into pages 146 and 146a of this Amendment.
To.better explain the existing primary containment (Drywell) sump collection and~ flow monitoring' system, the j
following paragraph has been added to the bases for Section 3.6.C and 4.6.C on pages 156 and 156a of the Technical Specification:
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The total leakage rate consists of all leakage, identified and unidentified, which flows to the Drywell floor drain and equipment drain sumps.
Both the Drywell floor drain and the equipment drain sumps have pump-out capacities of 50 gpm per pump.
Any one pump can, therefore, handle in excess of the maximum allowable total leakage of 25 gpm.
If the ability to measure pump-out flow from either of these sumps is lost, the inoperable sump will overflow into the remaining operable sump.
The remaining operable sump pump-out flow will then represent the total leakage rate.
During the time when one sump is overflowing, any increase in total flow will be assumed to be from an unidentified source.
This primary containment (Drywell) sump collection and flow monitoring system can' provide viable measurement of reactor coolant system leakage so long as one pump and its associated flow meter are operable."
On September 1, 1983, the NRC issued orders for Unit 3 return to service.
In these orders, the NRC responded favorably to revised pagga 146 and 146a.of Technical Specification with, "new limiting conditions for operation and surveillance requirements have beca developed.
.These enhanced surveillance measures will provide adequate assurance that.possible cracks iti
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pipes will be detected before growing to a size that will compromise the safety of the plant."
Therefore, in concluaion, to conform its earlier amendment application to the operating limitations agreed to by both NRC staff and Philadelphia Electric Company prior to restart of Unit 3, Licensee hereby amends its Application of May 3,-1983, by:
- 1) Adding explanation of primary containment (Drywell) sump collection and flow monitoring system to bases on pages 156 and 156a; 2) Deleting.any reference for requirements for the air j
monitoring system from pages 76, 85, 93, 146 and 146a; 3) i Providing modified limiting conditions for operation and surveillance requirements for sump collection and flow monitoring system on pages 76, 146 and 146a.
Additionally, Licensee proposes deletion of the last paragraph in Section 3.6.C and 4.6.C Bases (page 156a) considering the obsolete nature of the material.
The revisions are indicated by a vertical bar in the margin of the attached pages 76, 85, 93, 146, 146a, 156; and by the addition of page 156a.
The proposed changes to the operability and surveillance requirements regarding the monitoring of primary coolant leakage constitutes an additional limiting condition of operation and a more stringent surveillance requirement.
Consequently, Licensee i
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has concluded, in accordance with NRC Guidance (48 F.R. 14870) and the provisions of Section 50.92 of the Commission's regulations, that these changes do not involve a significant hazards consideration since they do nots (1) involve a significant increase in the probability or consequences of an accident previously evaluated, or (2) create the~ possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.
The Plant Operating Review Committee and the Nuclear Review Board (off-site safety review committee) have reviewed these proposed changes to the Technical Specifications, and have concluded that they do not involve an unreviewed safety question or a significant hazards consideration; and will not endanger the health and safety of the public.
Respectfully submitted, PHIIADELPHIA ELECTRIC COMPANY t
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By A* d.
6 -f Vice'Presipent 1*
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COMMONWEALTH OF PENNSYLVANIA ss.
COUNTY OF PHILADELPHIA S. L. Daltroff, being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing Amendment to Application for Amendment of Facility Operating Licenses and knows the contents thereof; and that the statements l
and matters set forth therein are true and correct to the best of his knowledge, information and belief.
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Subscribed and sworn to before me this /8 day of
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' MkN Notary Public PA1THCIA D. SCHOLE Notary Pubhc,linladelphia.11utadelphia Co.
My Commission Empres february 10,19iiG v
CERTIFICATE OF SERVICE I horcoy certify that a copy of the foregoing Amendment was served on the Commonwealth of Pennsylvania by mailing a copy thereof by first-class mail to Mr. Thomas Gerusky, Director, Bureau of Radiological Protection, P.O. Box 2063, Harrisburg, Pennsylvania, 17120 on this 10tWay of November,.,1983.
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l-1 Kugon /J. Ipfadley i
Attorney for Philadelphia Electric Company l
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