ML20097J381
| ML20097J381 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/19/1984 |
| From: | Bauer E, Bradley E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20097J377 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.K.3.18, TASK-TM NUDOCS 8409210221 | |
| Download: ML20097J381 (10) | |
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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket No. 50-277 50-278 PHILADELPHIA ELECTRIC COMPANY 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 8409210221 840919 ~
PDR ADOCK 05000277 P
BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket No. 50-277 50-278 PHILADELPHIA ELECTRIC COMPANY APPLICATION FOR. AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 & DPR-56 Philadelphia Electric Company, Licensee under Facility Operating Licenses DPR-44 and DPR-56 for the Peach Bottom Atomic Power Station Unit No. 2 and Unit No. 3, respectively, hereby requests that the Technical Specifications contained in Appendix A of the Operating Licenses be amended by revising Table 3.2.B as indicated by a vertical bar in the margin of attached page 67.
The revision
. reflects a proposed modification to the Automatic Depressurization System (ADS) required to comply with Item t
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- II.K.3'.18 of NUREG-0737, "Clorification of TMI Action Plan Requirements".
NUREG-0737, Item II.K.3.18, requested modification of'the ADS actuation logic to minimize the need for manual actuation to assure adequate core cooling.
Philadelphia Electric Company participated in the BWR Owners' Group program to develop and submit proposed design changes to the NRC.
By correspondence dated June 3, 1983 (J. F. Stolz, NRC, to E. G. Bauer, Jr., PECo), the staff, among other things,
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approved two design proposals suggested by the Owners' Group.
Licensee _ committed to implement option (2) as approved by the NRC, i.e.
(a) the addition of a timer that bypasses the high drywell pressure permissive after a specific time interval-following receipt of a low reactor water level signal, and (b) the addition of a manual inhibit switch.
This application proposes an appropriate Technical Specification change requested in the June 3, 1983 correspondence.
The ADS is currently activated automatically upon coincident signals of (1) low water level in the reactor, (2) high drywell pressure, and (3) low pressure ECCS pumps running.
For transient and accident events which do not directly produce a high drywell pressure signal and are degraded by a loss of all high pressure injection systems, adequate core cooling is assured by manual depressurization of the reactor followed by injection from the low pressure systems.
To reduce the dependence on operator action and to !
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..n 00tikfy Itca II.K.3.18 of NUREG-0737, Licensee proposas to V
. modify the ADS control logic as shown by the broken lines on
. Figure 1 of this application.
The high drywell pressure initiation signal is bypassed by installing a bypass timer that is actuated by low reactor water level (level 1).
The low reactor water level signal will be sealed in so that the bypass timer will not
' automatically reset.
When this timer times out, the high drywell pressure signal'will be bypassed and the ADS.will be initiated on & low reactor water level signal alone.
Each of the four existing drywell pressure instrument channels has its own bypass circuit.
The reset of the sealed-in low reactor water level signal is performed by the same switches that originally reset the high drywell pressure seal-in.
A manual inhibit switch is added to each of the two ADS initiation logics.
The manual inhibit switches are located on a control room panel near the controls for the safety relief valves.
A keylocked switch is used for the manual inhibit function to provide a means of limiting the
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potential for inadvertent actuation of the manual inhibit.
Alarms alert the operator of time-out of the bypass timer and activation of the manual inhibit.
A design analysis was performed to determine the delay setting for the new bypass timer.
The analysis showed f
n' ie
. 'that a catt'ing.of tsn ainutes or loss will assure adaquate l
~ core cooling for transient or accident events which may requ' ire rapid depressurization.
The study evaluated the limitin'g event of a main steam line break outside the containment, with the goal of limiting the maximum peak clad
' temperature to 1500 degrees F, using 10 CFR Appendix K models..The analysis also confirmed that an 8-minute time
' delay or more provides sufficient time to allow recovery of
. reactor water level.above level 1 to prevent undesirable
. automatic initiation during an anticipated transient without scram (ATWS)-event.
This is based on computer analyses that
. confirmed 'the ability of the High Pressure Coolant Injection (HPCI). system-to maintain the reactor water level above level l'during an ~ ATWS event with no operator action.
s Based on the analysis, an allowance for inaccuracy of the timer (plus 'or minus 54), and an allowance for timer setpoint drift (plus or minus.5%), a time delay of 9 minutes (plus or minus 1 minute) was chosen for the high 'drywell pressure bypass logic.
In the event of an ATWS event, this setting, when combined with the existing 105 second timer in
-the ADS logic, &llows sufficient time for the operator to correctly diagnose.the plant conditions and follow the emergency operating procedures to manually inhibit the ADS.
All design requirements applicable to the original ADS equipment and circuitry were applied to this modification.
These requirements include, but are not L
< licitc'd tof.onvironnantal qualification, maismic
. qualification, separation criteria, quality assurance, and
' testability.
The modification has a negligable ef fect on bus loading.
Accordingly, Licensee requests a revision to Table 3.2.B (page 67) of the Technical Specifications that would incorporate a surveillance requirement for the ADS Bypass Timer.
Additionally, Licensee requests that the title of the
'" Auto Blowdown Timer" be changed to " ADS Actuation Timer" in order to correctly identify the function of the timer.
A change is not necessary to Table 4.2.B regarding surveillance
-requirements since'the new timer is considered an auto
. sequencing. timer and hence is covered by the requirements presently contained in the table.
Further, Licensee requests that this amendment take ef fect upon completion of the modification described herein.
As stated in correspondence dated duly 15, 1983 (S. L. Daltrof f, PECo, to J. F. Stolz,
.NRC), the modifications will be implemented during the first refueling outage,_ for each unit, commencing af ter issuance of the requested amendment.
Significant Hazards Consideration Determination This application does not reduce the requirements of the current Technical Specification.
The proposed change constitutes an additional Limiting Condition of Operation and surveillance requirement for a new safety system component.
'Tha chIng3*refiscts-a modification nsadad to maet cn NRC
' requirement'in-NUREG-0737, " Clarification of TMI Action Plan
, Requirements".
The Commission has provided guidance conce'rning the application of the standards for determining whether license amen'dments' involve no significant hazards considerations by providing certain-examples (48 FR 14870).
. Two of the' examples -(11 and vii) of actions involving no
-significant hazards consideration are: (1) a change that constitutes an additional limitation, restriction, or control not presently. included in_the Technical Specifications, and (2) a change to make a license conform to changes in the regulations where the license change results in very minor changes to facility operations clearly in keeping with the regulations..The proposed change to Table 3.2.B to add the' new ADS bypass timer fits both of these examples of an action not involving a significant hazards consideration.
Consequently, Licensee-has concluded, in accordance with NRC Guidance (48 FR 14870) and the provisions of Section 50.92 of the Commission's regulations, that this change does not constitute a significant hazards consideration since it does not 4
(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
a (3) involva o significt.nt reduction in a margin of safety.
The Plant Operating Review Committee and the Nuclear Review Board (of f-site safety review committee) have reviewed this proposed change to the Technical Specifications and have concluded that it does not. involve an unreviewed safety
-question or a significant hazard consideration and will not endanger the health and safety of the public.
Respectfully submitted, PHILADELPHIA ELECTRIC COMPANY
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Vibe President /4 J
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- COMMONWEALTH OF PENNSYLVANIA :
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COUNTY OF PHILADELPHIA S. L. Daltrof f, being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company, th'e Applicant herein; that he has read the foregoing Application for Amendment of Facility Operating Licenses and knows the contents thereof; and that the statements and matters set-forth therein are'true and correct to the best of his
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-knowledge, information and belief.
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Subscribed and sworn to before me this ay l$$Y of p rA w
>f j s Notary Public t-c :,
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I PhTRICIA D. SCHOLE
'k f[C g *, * ; r,,, NWary PuMic. Philadelphia. PMaddphia Co.
"'?',j,,,My Commission Expires February 10,1986 o,,.
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CERTIFICATE OF SERVICE I certify that service of the foregoing Application was cade-upon the Commonwealth of Pennsylvania, by mailing a copy thereof; via'first-class mail, to Thomas R.
Gerusky, Director,
' Bureau of!Padiological Protection, P.O.
Box 2063,tHarrisburg, PA 17120; all-this 19th day of September, 1984.
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Bradley Attorney for Philadelphia Electric Company a