ML20094B104
| ML20094B104 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/17/1995 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20094B098 | List: |
| References | |
| NUDOCS 9510310288 | |
| Download: ML20094B104 (5) | |
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UNITED STATES g
j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. acese-ecoi
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION i
RELATED TO AMENDMENT NO. 215 TO FACILITY OPERATING LICENSE NO. DPR-56
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J PECO ENERGY COMPANY PUBLIC SERVICE ELECTRIC AND GAS COMPANY DELMARVA POWER AND LIGHT COMPANY j
ATLANTIC CITY ELECTRIC COMPANY PEACH BOTTOM ATOMIC POWER STATION. UNIT NO. 3 i
. DOCKET NO. 50-278 5
1.0 ' 1NTP,000CTION By letter dated September 1,1995, the PECO Energy Company (the licensee)
'6 submitted a request for changes to the Peach Bottom Atomic Power Station, Unit No. 3, Facility Operating Licer.se (FOL). The requested changes would delete
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FOL License Condition 2.C.(5) which restricts power levels to no less than seventy percent in a coastdown condition.
The NRC orally granted Notice of Enforc63ent Discretion (NOED) 95-6-013 on August 30, 1995 to allow Peach Bottom Atomic Power Station, Unit 3 to continue to operate although it was not in compliance with License Condition 2.C.(5).
The licensee had requested enforcement discretion in a_ letter dated August 30, 1995. The staff. confirmed the oral N0ED in writing in a letter dated September 1, 1995. The N0ED was authorized until such time as the staff could 4
disposition the licensee's request for a permanent change to License Condition 2.C.(5).
2.0 EVALUATION License Condition 2.C.(5) of the Peach Botton Unit 3 FOL states:
Operation beyond the end-of-cycle (all rods out condition) thermal power is limited to seventy (70) percent minimum.
Increasing core power level via reduced feedwater heating, once operation in the coastdown mode has begun, is not permitted unless the licensee has performed an analysis of this operating condition that confirms that this condition is bounded by the analysis for the particular cycle of i
operation.
License Condition 2.C.(5) was incorporated into the Unit 3 FOL as part of License Amendment 62, dated October 24, 1979. The limits in License Condition 2.C.(5) were imposed by the staff and agreed to by the licensee at the time Amendment 62 was issued.
In the safety evaluation which accompanied license
-Amendment 62, the staff stated:
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The staff has observed that several BWR (boiling water reactor]
licensees have stated in their reload applications that therma' power coastdown beyond EOC ARO [end-of-cycle all-rods-outl is permissible j
based on reference tn Section 5.2 of the Generic Reioad Fuel j
Application (NEDE-24011-P). Although several paragraphs on coastdown appear in the topical, the subject was never explicitly r.ddressed in i
our SER [ safety evaluation report) on the topical. However, we have been approving requests for coastdown operation via explicit plant-specific evaluations for core reloads. Our approvals have been 4
limited to not less than 70% coastdown core power level which is the limit of our acceptance of the safety analyses generally -referenced i
for such purposes. This 70% floor appears as a license condition for coastdown operation in our approvals.
l Subsequent to the issuance of License Amendment 62, the NRC issued Amendment 155 to the Unit 3 license on May 21, 1990 which was consistent with the i
guidance in Generic Letter 88-16, " Removal of Cycle-Specific parameter Limits i
from Technical Specifications." Amendment 155 removed certain cycle-specific' core parameter limits from the Technical Specifications (TSs) and replaced them with reference to a new document, called the Core Operating Limits Report 1
(COLR) which would contain the values for those limits.
Implementation of the COLR required the licensee to establish limits for the specified parameters j
using certain NRC-approved methodologies. Amendment 155 authorized the licensee to use the latest approved version of General Electric (GE) document NEDE-24011-P-A to establish the specified limits.
Although reactor power limits during coastdown operation is not one of the l
parameters discussed in the COLR, it is a parameter that is addressed in revisions of NEDE-24011-P-A that were issued subsequent to the issuance of Amendment 62. Section 4.3.2 of NEDE-24011-P-A, Revision 10,,(February 1991) j states that coastdown operation beyond full power is conservatively bounded by i
analyses at end-of cycle conditions. NEDE-24011-P-A, Revision 10 references a letter from R. Engel, GE, to T. Ippolito, NRC, dated September 1, 1981.
In the September 1, 1981 letter, GE states that the above conclusion is confirmed for operation down to forty percent power during coastdown for all boiling water reactors. The NRC staff has approved amendments to NEDE-24011-P-A up through Amendment 22 which is incorporated in NEDE-24011-P-A, Revision 10.
l The NRC staff approval of Amendment 22 was issued on July 23, 1990 (A.
Thadani, NRC, to J. Charnley, GE) and thus Revision 10 is the latest approved version of NEDE-240ll-P-A.
The staff concludes that coastdown operation below the seventy percent limit established in Peach Botton Unit 3 License Condition 2.C.(5) has been reviewed by the staff and is acceptable provided the licensee uses the approved 1
versions of NEDE-24011-P-A as specified in the TSs. Therefore, the staff finds deletion of the coastdown restriction in FOL License Condition 2.C.(5) acceptable.
The staff reviewed the FOL License Condition 2.C.(5) restriction against increasing core power by reducing feedwater heating once coastdown operation J
f
l-has begun. Consistent with the guidance in Generic Letter 88-16, the staff 1
concludes that this restriction is more appropriately treated by the licensee on a cycle-specific basis using approved methodologies. The methodology for i
performing this evaluation is provided in NEDE-24011-P-A which has been approved by the staff as described above. The staff concludes that the deletion of the restrictions in FOL License Condition 2.C.(5) regarding
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feedwater heating, is acceptable.
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3.0 STATE CONSULTATION
In accordance with the Comission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendment. The State official had no comments.
4.0 EXIGENT CIRCUMSTANCES
The staff has reviewed the licensee's proposed amendment and finds j-(1) that exigent circumstances exist, as provided for in 10 CFR'50.91(a)(6),,*
i in that the licensee and the Comission must act quickly and that time does
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not permit the Comission to publish a Federal Reaister notice allowing 30 days for prior public comment, and (2) that the licensee has not failed to use its best efforts to make a timely application and avoid creating the exigent circumstance.
5.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION
DETERMINATION 4
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The Comission has provided standards for determining whether a significant hazards consideration exists (10 CFR 50.92(c)). A proposed amendment to an i
operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of i
an accident previously evaluated; (2) create the possibility of a new or l
different kind of accident from any previously evaluated; or (3) involve a l
significant reduction in a margin of safety.
The licensee has analyzed the proposed amendment to determine if a significant hazard consideration exists:
(1) The proposed change does not involve a significant 1
increase in the probability or consequences of any accident i
previously evaluated. Deletion of License Condition 2.C.(5) is an administrative change that will not involve a
.significant increase in the probability or consequences of any accident previously evaluated. This license condition is more j
appropriately controlled by other licensing bases documents, which include the NRC approved GESTAR II analyses and the 4
cycle specific reload licensing reports, and should not be part of the FOL. Additionally, this FOL change will not alter any safety limits which ensure the integrity of fuel barriers, I
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and will not result in any increase to onsite or offsite dose.
No physical changes are being made to the plant, nor are there any changes being made in the operation of the plant as a result of this change which could involve a significant increase in the probability or consequences of any accident previously evaluated. Additionally, this change will not alter the operation of equipment assumed to be available for the mitigation of accidents or transients.
(2) The proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
Deletion of License Condition 2.C.(5) is an administrative change that will not create the possibility of a new or different type of accident from any previously evaluated.
Deletion of License Condition 2.C.(5) is an administrative change that will not involve any changes to plant systems, structures or components (SCCs) which could act as new accident initiators. This change will not impact the manner in which SSCs are tested such that a new or different type of accident from any previously evaluated could be created.
(3) This proposed change does not result in a significant reduction in the margin of safety.
No margins of safety are reduced as a result of the proposed deletion of License Condition 2.C.(5).
No safety limits will be changed as a j
result of this change. The proposed change does not involve a t
reduction in the margin of safety because this change is an administrative change which will not impact core limits or any i
l other parameters that are used in the mitigation of a UFSAR design basis accident or transient.
The change to the FOL does not introduce any hardware changes, and will not alter i
the intended operation of plant structures, systems or components utilized in the mitigation of UFSAR design basis accidents or transients. Additionally, this change will not i
introduce any new failure modes of plant equipment not i
previously evaluated.
i Based on the above considerations, the staff concludes that the amendment
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meets the standards set forth in 10 CFR 50.92 for a no significant hazards determination. Therefore, the staff has made a final determination that the proposed amendment involves no significant hazards consideration.
6.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR
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! Part 20. -The NRC staff has determined that the amendment involves no i
significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no i
significant increase in individual or cumulative occupational radiation i
exposure..The Commission has made a final no significant hazards consideration determination. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental 4
assessment need be prepared in connection with the issuance of the amendment.
7.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will no' be endangered by operation in the proposed manner, (2) such activities wi' be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common i
defense and security or to the health and safety of the public..
Principal Contributor:
J. Shea i
Date: October 17, 1995 i