ML20100J736

License Change Request 95-11 to Licenses DPR-44 & DPR-56, Reflecting Implementation of 10CFR50,App J,Option B

ML20100J736
Person / Time
Site:	Peach Bottom
Issue date:	02/15/1996
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20100J739	List: ML20100J736 ML20100J759
References
NUDOCS 9602290236
Download: ML20100J736 (7)

Text

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o Etition Support Dey,crimint L

=;=- 10 CFR 50.90 PECo Energy Company Nuclear Group Headquarters 965 Chesterbrook Boulevard Wayne. PA 19087 5691 February 15,1996 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Subject. Peach Bottom Atomic Power Station, Unks 2 and 3 License Change Request No. 95-11

Dear Sir:

PECO Energy Company hereby submits License Change Request No. 95-11, in accud.nce with 10 CFR 50.90, requesting changes to the Ponch Bottom Atomic Power Station, Unks 2 and 3 Facility Operating Licenses. The proposed changes reflect the implementation of 10 CFR 50, Appendix J, Option B.

As discussed in the final rule (60 FR 49495, September 26,1995) concoming the adoption of 10 CFR 50, Appendix J, Option B, the requirements in other or both Option B, Ill.A for Type A tests, j and Option B, Ill.B for Type B and C tests may be adopted on a voluntary basis in substkution i of the requirements for those tests contained in Option A by submitting the implementation plan and requesting a revision to the Technical Specifications. We request that the proposed changes be approved by May 3,1996 and be made effective by June 28,1996. PECO Energy's cunent implementation plan is to have the Primary Containment Leakage Rate Testing Program in place by June 28,1996 which will permk the use of Option B, Ill.A and Option B, Ill.B at the PBAPS, Units 2 and 3.

Attachment 1 to this letter describes the proposed Technical Specifications' changes, and provides justification for these changes. Attachment 2 contains the revised Technical Specifications' and Bases pages.

If you have any questions, please do not hesitate to contact us.

Very truly yours,

.b.Y f ef G. A. Hunger, J r., j Director - Licensing l l

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Enclosures:

Affidavit, Attachment 1, Attachment 2 l I

c.c: T. T. Martin, Administrator, Region I, USNRC W. L Schmidt, USNRC Senior Resident inspector, PBAPS R. R. Janati, Commonwealth of Pennsylvania l

200056 "

9602290236 960215 PDR ADOCK 05000277 Op l p PDR

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i a COMMONWEALTH OF PENNSYLVANIA  :  :

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as.  !

COUNTY OF CHESTER  :

D. B. Fetters, being first duly swom, deposes and says: l l

That he is Vice President of PECO Energy Company; the Applicant herein; that he has read the

$ attached License Change Request (Number 95-11) for Peach Bottom Faclity Operating Ucenses DPR-44 l

and DPR-56, and knows the contents thereof; and that the statements and matters set forth therein are 4 true and correct to the best of his knowledge, information and belief.

k\ ~- ud  %

Vice President i

Subscribed and swom to before me this /D day of 996.

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% Notary ublic L&

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• Notarial Seal < l Mary Lou Skrocki. Notary Public  !

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i Tredyttrin Twp., Chester Count j

'. 'My Comm: scion Expires toay 17. l'm' li

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i ATTACHMENT 1 PEACH BOTTOM ATOMIC POWER STATION ,

UNITS 2 AND 3 Docket Nos. 50-277 50-278 ,

License Nos. DPR-44 DPR-56 i

UCENSE CHANGE REQUEST No. 95-11

' Adoption of 10 CFR 50, Appendix J, Option B'  ;

Supporting Wormation - 4 Pages i i

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,. Dock-2 Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 Introduction l PECO Energy Company (PECO Energy), Licensee under Factity Operating Licenses DPR-44 and DPR-l 56 for the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, requests that the Technical Specifications (TS) contained in Appendk A of Operating Licenses DPR-44 and DPR-56 be amended.

The proposed changes reflect the implementation of 10 CFR 50, Appendk J, Option B.

This License Change Request provides a diammalan and description of the prapnand TS changes, a i safety discussion of the proposed TS changes, information supporting a finding of No Significant I Hazards Consideration, and information supporting an Environmental Asseeement ,

i Discussion Effective October 26,1995, the Commission amended ks regulations (10 CFR 50, Appendix J) to provide a performance-based option for leakage-rate testing of containments of light-water-cooled nuclear plants.

The proposed changes to the Technical Specifications would permit the implementation of this performance-based option, which allows leakage testing intervais to be based on component performance Primary containment leakage-rate testing required by 10 CFR 50, Appendix J includes the performance  !

of an integrated Lankage Rate Test (Type A tests, often referred to as ILRTO) and Local Laak Rate Tests  !

(Type B and C tests, often referred to as LLRTs). The Type A test measures overall leakage rate of the l primary reactor containment. The Type B test measures the leakage rate across each pressure-cvWuditg or leakage 4imiting boundary for various primary reactor containment boundaries. The Type C test measures containment isolation valve leakage rates.

These test requirements ensure that leakage through the containment, or components, does not exceed allowable leakage rates specified in the Technical Specifications. Addklonally, these tests ensure the integrty of the containment structure is maintained during its service life. l The U. S. Nuclear Regulatory Commission (USNRC) pubilshed a notice in the Federal Register on February 4,1992 (57 FR 4186), presenting ks planned initiative to begin eliminating requirements that are marginal to safety and yet impose significant regulatory burdens on liconeses. In the notice, the USNRC concluded that decreasing the prescriptiveness of some regulations could increase their effectiveness by '

giving the licensees the flexibilty to implement more cost-effective safety measures. Additionally, the regulatory process could be made more efficient. To increase flexibility, the detailed and prescriptive technical requirements contained in some regulations could be improved and replaced wth l portormance-based requirements and supporting regulatory guides.

In accoroance with these conclusions, the USNRC indicated that Appendix J was a candidate whose requirements may be relaxed or eliminated based on cost-beneficial considerations. To support the 10 CFR 50, Appendix J, Option B rule change, the USNRC used an analytical approach documented in NUREG-1493, " Performance-Based Containment Leakage-Test Program," which confirms previous observations of insensitivity of population risks from severe reactor accidents to containment leakage rates.

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,. Docid Nos. 50-277 3 50-278

Woonee Nos. DPR-44 i DPR-56

) Description of the Prononad Change i

j in a USNRC letter dated November 2,1996 (C.1. Grimes (USNRC) to D. J. Modoen (NEI)), the USNRC l provided a model TS which provides guidance to licensees for preparation of amendment requests to j incorporate 10 CFR 50, Appendk J Option B. PECO Energy has utlized this model for the changes to

the PSAPS, Units 2 and 3 TS as it pertains to the current TS. As discussed in the final rule, the submittal for TS reviolons must contain justification ll the licenses chanaan to deviste from methods approved by

! the USNRC and endorsed by Regulatory Guide 1.163, Performance-Based Containment Lankago-Test i Program " No deviations are being taken for PBAPS, Units 2 and 3.

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j. Safety Discussion i

The regulatory safety objective of the reactor containment design is stated in 10 CFR 50, Appendk A,

" General Design Criteria for Nuclear Power Plants," Criterion 16, " Containment Design " GDC 16 mandates "an essentially leak-tight barrier against the uncontrolled release of radioactivity to the environment..." The previous version of 10 CFR 50, Appendk J implemented GDC 16 through prescriptive containment leakage testing requirements that stipulated the tests that should be performed, i the frequency of testing, and reporting of the test results The revised 10 CFR 50, Appendk J regulation i maintains the prescriptive leakage testing requirements (now referred to as Option A), but now recognizes a performance-based leakage testing program (referred to as Opdon 8) as an amaf*=Na altamative to the prescriptive (Option A) requirements, This performance-based leakage testing approach allows test intervels to be based on component testing performance, thereby providing greater flavu*y and cost-benefit in implementing the safety objectives of the regulation. The revised Appendk J

1) makes Appendk J Ices prescriptive and more pedormance oriented,2) moves detats of Appendk J tests to a regulatory guide (1.163) as guidance, 3) endorses in the regulatory guide the industry guideline (NEl 9401, "Irdustry Guideline For implementing Performance-Based Option of 10 CFR Part 1 50, Appendk J," Revision 0) on the conduct of containment tests (the methods for testing are contained l in an industry standard ANSI /ANS 56.8-1994, " Containment System Leakage Testing Requirements,"

which is referenced in the guideline), and 4) allows voluntary adoption of the new regulation, i.e., cummt detailed requirements in Appendix J will continue to be acceptable for compliance with the modified rule.

In the February 1996 prnpnaad rule, the USNRC proposed a new risk-based regulation based on the performance history of components (containment penetrations and valves) as the means to justify an increase in the interval for Type A, 8, and C tests. The revised regulation requires tests to be conducted ,

on an interval based on the performance of the containment structure, penetrations and valves without i specifying the interval in the regulation. Currently, three Type A tests are conducted in every 10 year period Type 8 (except air locks, which are tested more frequently) and C tests are conducted on a frequency not to exceed 2 years. The USNRC proposed to base the frequency of Type A tests on the historical performance of the overall containment Specific findings documented in NUREG-1493 that justify this proposal include-

1. The fraction of leakages detected only by ILRTs is small, on the order of a few percent.

2. Reducing the frequency of ILRT testing from 3 overy 10 years to 1 overy 10 years leads to a marginal increase in risk.

3. ILRTs also test the strength of the containment structure. No attemative to ILRTs has been identified to provide assurance that the containment structure would mest allowable leakage rates during design-basis accidents.

4. At a frequency of 1 test every 10 years, industry-wide occupational exposure would be reduced by 0.087 person-sievert (8.7 person-rem) por year.

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Docket Nos. 50-277 50-278 lj Ucense Nos. DPR-44 DPR-56 4

Bened on specNic, desded - :iw of data from the North Anna and Grand Gull nuclear power plants, i

l and data from twenty-two nudear plants, performance-based altometNes to current LLRT methods are l fannihte with marginal impact on riek. Specific findings include

[ 1. Type B and C test are capable of detecting over 97 percent of containment leakages.

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2. Of the 97 percent, virtuaNy d leakages are identified by LLATs of containment lantatinn vanes (Type C tests).

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3. Based on the detded evaluation of the experience of a single two-unit station, no correlation of fdures with type of veNe or plant service could be found.

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! 4. For the 20 years of remaining operations, changing the Type B/C test frequency to once every 5

years for good-performing components is estimated to reduce industry-wide ormatianal radiation awfmaure by 0.72 person-elevert (72 pomon-rom) por year. If a 20-year liconee

! extension is assumed, the estimate is 0.75 person-sievert (75 person-rom) per year.

I infortp=*lan *=vertino a Findino d No Sionificant Harards Con =1riaratian i

We have concluded that the proposed changes to the PBAPS, Units 2 and 3 TS do not constitute a Significant Hazards Consideration. In support of this determination, an evaluation of each of the three

! (3) standards set forth in 10 CFR 50.92 is provided below.

f 1) The oraanmari chanans do not irrealve a sionificant incr- in the orahahekv or copaarum of any accident oraviously evaluated l

) The adoption of 10 CFR 50, Appendix J Option B wiH not invoNo a significant ncrease in the probability or consequences of any accident previously evaluated The proposed changes to 4

the TS reflect the use of the performance-based containment leakage-testing program. The USNRC has approved the use of a performance-based option for containment leakage testing programs when it amended 10 CFR 50, Appendix J (60 FR 49495). For adoption of the revloed i regulation, licensees are required to incorporate into their TS, by general reference, the USNRC regulatory guide or other plant-specific implementing document used to develop their

performance-based leakage testing program. A new AdministratWe Control subsection (5.5.12,

" Primary Containment Leakage Rate Testing Program") has been added that requires the establishment and maintenance of a Primary Containment Lankage Rate Testing Program. The

TS wiu stiu require the performance of a periodic general visual inspection of the containment to

, ensure early detection of any structural deterioration d the containment that may occur.

I As conduded in NUREG-1493, given the insensitivky d risk to containment leakage rate and the amoH fraction of leakage paths detected solely by ILRT testing, increasing the

, interval between ILRTs is possible wkh minimal impact on public risk. Additionally, performance-based allematkos to current LLRT requirements are feasible without I significant risk impacts. Additionally, these changes wiu not alter any safety limits which j ensure the integrity of fuel barriers, and will not result in a significant increase to onelle

or offsite does.

i No physical changes are being made to the plant, nor are ttere any changes being made in the  !

operahon of the plant as a result of these changes which could invoNe a significant increase in a

the probabBky or conesquences of any accident previously evaluated. A:iditionally, these changes win not alter the operation of equipment assumed to be avalebis foc the mitigation of j accidents or transients 3

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.- Docket Nos. 50-277 50-278 Lkame Nos. DPR-44 DPR-56

2) haaaaad chartr== do not create the = "'3hv d a new or dlNerent idr 1 of :W=a 6.,,

any Dreviously evaluated.

The adoption of 10 CFR 50, Appendix J Option B wu not create the poselbilty of a new or dlNorent type of accident from any previously evaluated. These changes to the PBAPS, Units 2 and 3 TS WIN not involve any changes to plant systems, structures or components (SCCs) which could act as new accident initiators. These changes wlN not impact the manner in which SSCs are tested such that a new or different type of accident from any previously evaluated could be >

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3) The oraanand charmaaa do not m* In a alareir=nt radw*ian in the T.e.a. of anfatv No margins of safety are reduced as a result of the prapanad adoption of 10 CFR 50, Appendix I J Option B. As stated previously, the USNRC has apprmed the use of this performance 4ased j option for containment leakage testing programs when it amended 10 CFR 50, Appendix J (80  :

FR 4g406). These changes wul not impact core limks or any other parameters that are used in  !

the mitigation of a UFSAR design-basis accident or transient. AdditioneNy, these changes do not l Introouce any hardware changes, and will not alter the intended operation of plant structures, '

systems or components utilized in the mitigation of UFSAR design-basis accidents or transients. l These changes wNl not introduce any now failure modes of plant equipmen: not previously j evaluated. '

information Sunoorting an Environmental Annasament An environmental manaamment is not required for the proposed changes since the proposed changes conform to the crkeria for " actions eligible for categorical exclusion" as specNied in 10 CFR 51.22(c)(9).

The prapaamd changes wlN have no impact on the environment The proposed changes do not involve a signlReant hazards consideration as discussed in the preceding section. The proposed changes do not involve a significant change in the types or significant increase in the amounts of any enluonts that may be released offsite in addition, the proposed changes do not involve a significant increase in individual or cumulative occupational radiation exposure.

Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed the proposed changes to the PBAPS, Units 2 and 3 TS and have concluded that the changes do not involve an )

unreviewed safety question and wul not endanger the health and safety of the public, j i

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