ML20087E050
| ML20087E050 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 01/10/1992 |
| From: | Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20087E055 | List: |
| References | |
| 91-02, 91-2, NUDOCS 9201210008 | |
| Download: ML20087E050 (16) | |
Text
{{#Wiki_filter:1 PillLADELPillA ELECTRIC COMPANY NUCIIAR Gt(OUP llEADQUAltTERS 955 65 CH1'STHilillK)OK BIND. V%YNE, PA 19087 5691 t (215) 640-6000 NUCt1AR LNGINilANG A $0R%ICI:3 DEFAltrMIWT January 10, 1992 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 U.S. Nuclear Regulatory Commission Attn: Document Contrei Desk Washington, DC 20555
SUBJECT:
Peach Bottom Atomic Power Station, Unita 2 and 3 Technical Specifications Change Roquest 91-02 Dear Sirs Philadelphia Elect.ric Cn:npany (PEco) hereby submits Technical Specifications Change Requeut (TSCR) No, 91-02, in accordant:e with 10 CFR 50.90, requesting a chenge to Appendix A of the Peach Bottom Facility Operating Licenses. The proposed changes concern the Allowable Out of Service times for the Emergency Service Water System.
. Attachment 1 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 regarding this matter, please contact us. Very trul yours O.. G J.jA Beck, Manager Licensing,Section L,
Enclosures:
. Affidavit, Attachment 1, Attachment 2 cc: T. T. Martin, Mm1Matrator, Region 1, USNRC l J. J. Lyash, USNRC Senior Resident Inspector, PBAPS L T. M.-Gerusky, commonwealth of Pennsylvania
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s . COMMONWEALTil OF PENNSYLVAhIA: 1 88. COUNTY OF CilESTER 1 D. R. Holwig, boing fA.a'..'>q sworn, deposon and enys: . That he jo Vice Presiddet, ot' Philadolphia Electric Company; the Applicant horoin; that ha him read the attached Technical 4 Specificationu change Roqiaost (thaber 91-02 ) for Peach Bottom Facility Operating Liconnus DP!f H and DPR-SG, and knows the contento thoroof; and that 'the statomonts and matters not forth thoroin are true and correct to the bout of his knowledge, information and belief. _ f4-i _ Vice Prosident,/ (, subscribed and sworn to before me this /d day of ( tru.uMit - 1992, d (' ,
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l. s s L - .- 1 ATTACllMENT 1 PEACil BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 t, Docket Non. 50-277 50 */70 Licenso Nos.-DPR-44 h DPR-56 TECilNICAL SPECIFICATION CHANGE REQUEST-91-02
" Revisions to Allowable Out of Service Times for
- the Emergency. Servica; Water Syatom'!
Supporting Information'for Changen-14 Pages @p 0;, >
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Docket Nos. 50-277 , 50-370 Licenso Nos. OPR-44 DPR-56 , I Philadolphia Electric Company (PEco), Liconsoo under l Facility Operating Licensos DPR-44 and DPR-$6 for the Peach Bottom : Atomic Power Station (PDAPS) Unit No. 2 and Unit No. 3, e respectively, requests that the Technical Specifications containt in Appendix A to the operating Licenson be amended. Proposed ! l changos to the Technical specifications are indicated by vertical ! bars-in the margins of pagos 221, 223, 224, 234, and 23Sa. Tho i proposed revised pages for each unit are included in Attachmont 2. , t i Descr@ tion of changos ; i Tho following changes and additions are being proposed. ; (3) Licensee proposes tNo addition of a Limiting Conditisn for Operation-(LCO) to Section 3.9.C, to be numberert 3__.9.C.2 which ; shall road: " If one ESW pump becomas inoperable the roactor
. inay remain in operation for a porlod not to excccd 7 days.
If [ this requiroment cannr>t be met, an orderly shutdown shall be-
- 1nitiated and the reactor'shall be placed in the cold shutdown condition within 24 hours.". .
i > (2) 'Licensoo-proposes to reduce the existing; Allowable Out-of Servico Time (A0T) delineated in curront TS Section 3.9.C.2 , from 1 month to requiro-plant shutdown to within six (G) hours I .- upon loss of two ESW pumps. This new LCO shall be numbered - l " 3.9.C.3 and shall road: If two ESW pumps becomo inoperable, i I w- 4 -r e m---wv,.. .wn,,-=-,- e- e-me**+.s.s_w - w-. s , *e-www-.e* .v- r e. m e,
Dockot Hos. 50-877 ! L , 50-370 l Licenso Nos. DPR 'e4 DPR-56 the roactor shall be placed in hot shutdown within (6) hours L l l and in cold shutdown within 36 hours.". l
- (3) Licensoo proposes to doloto the existing TS section 3.9.C.3 which discusses tho operability requiremonts of the ECW system
. to provido an equivalent function as ESW. This equivaloney has not boon proven conclusively and tha Licensoo therefore, requests to oliminato confusion from the Technien1 Specifications.
(4) Licensoo proposes to reduce the existing Survo111anco Test ! Interval (fTI) for the Emergency Cooling Water pump and the WSU booster pumps from onco por operating cycle to overy 3 months. Surveillanco requiremont 4.9.C.3.a shall road, "The ; Emergency = Cooling.Watur pump and ESW booster pumps shall be testod in accordance with section XI of the ASME noiler j Prossure Vetual' Code and appl.tcablo Addonda, except whero itoilot has been jcsnted."' i (5) Licensoo proposes to reduco-the existing-STI'for the Emergency Cooling-Tower fans from onco por operating cycle to ovory.
- three months.- Surveillance Requirement 4.9.C.3.b shall road
- '"The Emergency Cooling Tower f ans shall be tested onco every '
throo. months.". l; o n , P r 4
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l Docket Nos. 50-277 50-278 Licenso Nos. DPR-44 DPH-56 i (6) Licensuo proposou to reviso the Banen of Section 3.9 to j correctly define the relation betwoon the ECW pump and the ESW pump. The second, third and fourth sentonces of the last J paragraph shall bo dolotod. The ECW pump could not be conclusively provt, to satisfy the critoria to be equivalont to an ESW pump and its associated system for a Design Basis Acciderat (DBh); thorofore, all references in the TS to such an i equivalent function are being doloted. I ' i l I (7) Licenseo proposes to rovize the Bases of Section 3.9 by l 1 replacing the paragraph discussed in (6) with the following statement: "In the event onu of the ESW pumps becomes inoperable the 7 day allowable out of service timo is conservativolgiven the probability of an ovant requiring the use of both ESW pumps occurring in that amount of timo. One ; ESW pump is capable of supplying the entiro system. If both of.thu ESW pumps becomo inoperable placing the rooctor-in a ; shutdown condition is consistent with the soverity of the l sit uation. " . l t (0) .Licensoo proposes to reviso the Basos of Section 4.9. The i last paragraph of the noction shall be revised to oliminato roterences-to.the Emergency Cooling Water pump, tho ESW l Booster pumps ~and the Emergency Cooling Tower fans. This information belongs in the bases for the alternate heat sink facility as discussed in chango number 12. The last santonco , i
Dockot Nos. 50-27*/ 50-278 Licenso Nos. DPR-44 DPR-56 of Sect 8on 4.11.D Baasos will stato: "the testing of the omorgency cooling tower fans, the ESW Dooster Pumps and t.ho ECW pump, in accordanco with oxisting AS!4E codos, assures the required availability of the equipment.". (9) Licensco proposes to add an additional Survoillanco Requirement. This addit.ional requiremont will be numborod 4.9.C.3 and will stato: "Each manual valvo and onch elect.ric motor operated valvo, that is not in the system flow path and that is not locked, sealed or otherwise secured in position, shall be veriflod monthly to bo in its correct position.". (10) Licensoo proposes to add an additional Survo111anco Roquiromont. This additional requiremont shall be numborod 4.9.C.4 and will stato for Unit 2 TS: " Onco por operating cyclo the bottom of the 'A' ESW pump intako structure will be inspected and cleaned au necossary to removo excessive silt."; the Unit 3 TS will stato: "Once per oporating cycle tho bottom of the 'B' ESW pump intako structure will be inspected and cleaned as necessary to removo excessivo silt." The following changes are purely administrativo, such as renumbering and relocating sections of the TS. Thoso activities do not affact the safety of the plant and do not represent an unroviewed safety question. _ ______ _ __ _ _ _ _ __ _ _ ___ _ _______ _ _ ___ __ __ _ ____________ _ _ _ _ _ _ .a
Docket Hon. 50-277 50-270 Licenso Nos. DPR-44 DPR-56 (11) Licensou proposes that the LCOs for ono ESW pump and two ESW pumps being inoporable bo numbered 3.9.C.2 and 3.9.C.3, respectively. This numboring sequence is a purely administrativo chango designed to improve the logic and practicality of the TS. (12) Licensee proposos to relocato the TS Survo111anco Requiremonts currbntly numborod 4.9.C.3.a and 4.9.C.3.b to section 4.11.P of the TS. Additionna changos to those secti-'in are being requestod in thlo proposed amendment (paragraphs 5 and 6); howevor, the relocation to these sections to section 4.11.B is , consistont with the function of these specific sections and is a purely adutinistrativo function designed to improve the logic and practicality of the TS. (13) Lict.naco proposes to renamo A1tornato licat Sink Facility to Emergoney Heat Sink in twetion 3.11.8 and 4.11.B and their , associated bases. The proposed sections would read 3.11.D. Emergeneyjleat_ a sink /acility Tlio loval of the emergency reservoir of the Emerg mcy Heat Sink F'icility shall not bo less than i 17'. Should the level drop below this point action shall be taken to rest.oro the level to above the minimum, within 7 days. 4 .11. B uCmorgency heat Sink Facility
1 Docket Non. 50-277 i 50-278 1 Licenso Nos. DPR-44 , DPh-$6 j i l
- 1. The level in the emergency reservoir of tho l Emergoney llaat Gink facility shall be check once por month.
l The bauen sections would remain tho same except that emergency l l would replace alternato in the auction title. Those changes l would make the name of this facility consistant betwoon the ! l Updated Final Safety Analysis Hoport (UFSAR) and the Technical ~ Specifications ar.d oliminato nomo confusion among Licensoc personnel. This change is strictly administrativo. II. SAFETY' DISCUSSION Change request-(1) concerns an additional Lc0 to assign a 7 -E day A0T for either of the ESW pumps should they becomo inoperable.
- In the-event that one of. the two ESW pumps become inoperablo, the 7-l day timo period is considered conservative based on the fact'that
- an! additional 100% capacity pump would sti31 be available.. In addition, the */ day LCO is consistant with- the standard Technical ;
Spacification requirements for 100 porcent remaining capacity, A Probabilistic Risk assesamont comparison to tho-current TS ,
- allowable out of corvice times for the liigh- Prosauro injection +
Cooling (HPCI) system and each of the diesol' generat. ors was - completed.' The-proponed ? day LCO'for an ESW pump had an equal or less impact on the probability of a--coro damage accident in_all I
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Docket Nos. 50-377 50-878 License Nos. DPR-44 DPR-56 cases. The allowab1? out of service times for the HPCI and DG have been approved and they are consistent with industry levels of risk. The proposed allowable out of service time for the ESW pumps is therefore a logical limitation which will not create an undue risk of a core damage accident.
.The current Technical Specifications do not address this scensrio and allowed unlimited operation with an Emergency Cooling Water (ECW) pump or an ESW pump inoperable. The ECW pump could not be shown conclusively to be an equivalent ESW pump. The operating staff at PBAPS has recognized this' deficiency and has developed a formal plant policy in PORC Position Number 33 which takes no credit for the ECW pump and places nn administrative limit of 7 ,
days to restore the ESW pump to operability or begin shutdown.
-This TSCR will supplant PORC position 33 and replace an administrative limit with a TS limit.
Change request (2) concerns redue?.ng the existing AOr tor two ESW pumps'from~1 month-to.6 hours. Tho-loss of both ESW pumps indicates a-significant reduction in redunacncy in emergency
.cocding of the diesel' generators. This more restrictive limitation is proposed,to enhance plant safety although actual operating experience indicates that a simultaneous failure of both ESW pumps haa never. occurred. In the current TS there is no LCO for this scenario. The operations staff currently must recognize that it is appropriate to enter TS 3.0.C in this situation. The generic TS
r . l Docket Noc. 50-277 50-278 License Nos. DPR-44 DPR-56 3.0.C would also require a plant shutdown within 6 Sc ars; howev - by placing the requirement in the ESW section the human factors of the TS are improved. Change request (3) concerna the deletion of Section 3.9.C.3. I This section discusses the equivalency of the ESW and the ECW I pumps. After an engineering evaluation, it t;as determined that
-these pumps are not equivalent. Because of this determination the proposed TS amendment is being submitted. To clarify the TS it le requested that this section of the TS be removed.
Change request (4) changes the surveillance test interval (STI) for the ESW booster pumps and the Emergency Cooling Water Pump from once per operating cycle to once every 3 months as specified by the ASME Code. A review of the surveillance tests indicates that the testing does not disturb pumps or valves in any manner which would preclude operation of the system in the event of actual demand. Therefore, there is no presumed test unavailability for the ECW system. Change request (5) decreases the STI for the Emergency Cooling Tower Fans from once per operating cycle to once every three months. A review of the surveillance tests indicates that the testing does not disable the fans in any manner which would preclude operation of the system in the event of actual demand.
Docket Nos. 50-377 50-278 License Nos. DPR-44 DPR-56 Theretore, there is no presumed test availability for the EHS system. Chango raquests (6), (7) a..a s a) concern revising the Bases to accurately reflect changes proposed to Section 3.9 and 4.9. Consistency between the Bases and their corresponding LCOs and SRs is necessary to avoid misinterpretations and to enhance the understanding of the intent of the reqtirement. Change request (9) concerns the addition 01 a Surveillance requirement. This change conforms to the Standard Technical Specification surveillance requirements for valve position verification and would increase the reliability of the ESW system. No components in the ESW System are operated to perform this ST; therefore, there is no concern that increased testing could damage components or decrease system availability. Change request (10) concerns the addition of a Surveillance requirement. This change conforms to the Standard Technical Specification surveillance requirements for inspection of the bottom of the ESW pucp intake structure. The reliability of the ESW system would be improved by ensuring that the bottom of the structure was relative'y free of mud and debris that could affect pump suction or clog system heat exchangers. The ESW pump which draws a suction from the intake structure being inspected may be blocked from operating to ensure the safety of the inspection team. , i 1
Docket Nos. 50-277 50-278 i License Nos. DPR-44 DPR-56 This brief out of service time is not considered significant given the redundancy of the other ESW pump, the high ESW pump rollability and the improvement in system reliability that will result from this regular inspection. No coniponents in the ESW System are operated to perform this ST; therefore, there is no concern that increased testing could damage components or decrease system availability. Change request (11) and (12) concern the renumbering and location of LCOs and SRs to improve the logic and human factors of the Technical Specificatione These changes are strictly administrative in nature and have no offect on the safety of the plant. Change request (13) concerns the renaming of the Alternate - Heat Sink to the Emergency Heat Sink to eliminate a discrepancy in title between the UFSAR and'the TS. This change is strictly administrative and has no effect on the safety of the plant.
-No Significant Hazards Consideration The change requests proposed in this Application do not constitute a significant hazards consideration in that:
. - . . ~ . _ . -
Docket Nos. 50-377 50-278 4 License Nos. DPR-44 DPR-56 i) The proposed changes do not involve a significant I l increase in the probability or consequences of an ! accident previously evaluated. The proposed changes will not increase the probability or consequences of an accident previously evaluated. ;
.The changes to Allowable Out of Service Times do not change any of the operating functions or render inoperable any equipmentinecessary to_ mitigate the consequences of an accident. By_ decreasing the allowable out of service times, the equipment will more likely be available to respond to mitigate the consequences of an accident.
I ," I
.The addition of new surveillance requirements and changes to existing-surveillance requirements has a similar affect on plant equipment and has no affect on the probability _or consequences of an accident. By inspecting the pump pit and ,
the valve lline up on a regular basis the probability that the equipment will be:available to mitigate the consequences of an accident'will be increased. In addition the increased-surveillance of_the Emergency Service Water Booster pumps and-the' Emergency Cooling Tower Fans can only improve the likelihood.that this equipment will be operable when required. L
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Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56
- 11) The proposed changes do not create the possibility of a new or different kind of accident from_any previously evaluated.
l The proposed changes to the TS impact equipment that is
.important to safety and that mitigates the consequences of an accident. This equipment and the changes being proposed do not change the operation of PBAPS and therefore, the changes cannot introduce any new or different kind of accident.
111).The propo -1 changes-do not involve a significant j reduction-in-a margin of safety. l The margin =of safety-is not reduced by these changes. No credit was taken in accident analysis for the ECW pump to act as_an equivalent ESW-pump. _The other changos being proposed
. will give a greater assurance that - equipment important tx) safety will-be available to mitigate the consequences of an
. accident.
Environmental Assessment An environmental impact assessment is not required;for
'the changes proposed byLthis-Application because the changes conformLto the' criteria for " actions eligible for categorical exclusion" as specified in 10 CFR 51.22(c)(9). The proposed L
i s' *- Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 changes do not involve any systems that have a direct relationship with the environment. The changes involve tho definition of Surveillance Frequency. The Application involves no significant change in the types or significant increase in the amounts of any effluents that may be released off site and there will be no significant increase in individual or cumulative occupational radiation exposure.
-Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes and have conclude'd that they do not involve an unroviewed safety question and are not a threat to the health and safety of the public.
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