ML20102B237
| ML20102B237 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 07/20/1992 |
| From: | Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20102B239 | List: |
| References | |
| NUDOCS 9207280277 | |
| Download: ML20102B237 (17) | |
Text
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2 PillLADELPIIIA ELECTRIC COSil%NY NUCLEAR GROUP llEADQUARTERS 955-65 CHESTERDROOK BLVD.
WAYNE, PA 19087 5691 (215) 640L6000 NVCLEAR ENGINEERING & SERVICES DEPARTMENT July 20 , 1992 Docket Nos. 50-277 50-278 License tios. DPR-44 DPR-56 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Peach Bottom Atomic Power Station, Units 2 and 3 Technical Specifications Change Request 91-02, Rev. 1
REFERENCE:
Letter dated 1/10/92 from G. J. Beck (PECo) to NRC
Dear Sir:
Philadelphia Electric Cocpany (PECo) hereby resubmits Technical Specifications Change Request (TSCR) No. 91-02, Rev. 1 in accordance with 10 CFR 50.90, requecting a change to Appendix A of the Peach Bottom Facility Operating Licenses. This TSCR is being resubmitted because of an omission in the original submittal '
(reference 1). Changes in Appendix I as a result of this revision are indicated by revision bars in the margin. The proposed changes concern the Allowanle Out of Service times for the Emergency Service Water Syotem.
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. We regret any inconvenience this resubmittal may have caused.
Very truly yours, r :
7 G. JC,, Beck, Manager Licensing Section
Enclosures:
Affidavit, Attachment 1, Attachment 2 s 'h l 9207280277 920720 I PDR ADOCK 05000277 h- i P PDn l
P ll-
!. . TU.S.
Nuclear Regulatory' Commission July 20, 1993 l '
- TSCR,#91-02, Rev. 1 Page 2 i-f cc: T. T. Martin, Administrator, Region I, USNRC j~ J. J. Lyash, USNRC Senior Resident Inspector,, PBAPS i; W. P. Dornsife, Commonwealth of Pennsylvania l
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COMMONhEALTH OF PENNSYLVANIA:
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COUNTY OF-CHESTER :
D. M. Smith, being first duly sworn, deposes and says:
That he is Sr. Vico President of Philadelphia Electric Company; the Applicant herein; that he has-reed the attached Technical Specifications Change Request (Number 91-02, Rev. 1) for Peach Bottom racility Operating Licenses DPR-44 and DPR-56, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge,
.information and belief.
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Sr. Vice President subscribed and sworn to before me_thisdb day L of 1992.
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Notary Public-
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ATTACHMENT 1 PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 Docket Nos. 50-277 50-278 l- License Nos. DPR-44 L -
. TECHNICAL SPECIFICATION CHANGE REQUEST 91-02, Rev.- 1 L " Revisions to Allowable Out of Service Times-for the Emergency Service Water System" Supporting Tnformation for Changes 14 Pages J
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Y Docket Nos. 50-277.
50-278.
l License Nos. DPR-44 DPR-56 Philadelphia Electric Company (PEco), .Licensuo under L.
Facility Operating Licenses DPR-44 and DPR-56 for the Peach Bottom
-Atomic Power Station (PBAPS) Unit No. 2 and Unit No. 3, respectively, requests that the Technical Specifications contained in Appendix A to the operating Licenses be amended. Proposed changes to the Technical Specifications are indicated by vertical bars in the margins of pages 221, 223, 224, 234, 235a and 236a.
.The. proposed revised pages for each unit are included in Attachment L
2.
Description of Changes L
The following changes and additions are being proposed.
-(1) Licensee proposes the addition of a Limiting Condition for
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' Operation (LCO) to Section 3.9.C, to be numbered 3.9.C.2 which l
shall-read: "If one-ESW pump becomes inoperable the reactor may-remain in operation for a period not to exceed seven (7) 1.
days. If this requirement cannot be met, an orderly shutdown shall be initiated and the reactor shall be placed in the cold
-. shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.".
.(2) . Licensee proposes to reduce the existing Allowable Out of r
Service Time (AOT) delineated in current TS Section 3.9 C.2 L
lfrom l' month to require plant shutdown to within six (6) hours upon loss of two ESW pumps. This new LCO shall be numbered
Docket Nos.'50-277-
', . 50-270 License Nos. DPR-44 DPR-56 3.9.C.3 and shall read: "If two ESW pumps become inoperable,- l the reactor shall be placed in hot shutdown within (6) hours and in co.'d shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.".
(3) Licensee proposes _to delete the existing TS section 3.9.C.3 which-discusses the operability requirements of the ECW system _
to provide an equivalent function as ESW. This equivalency has not.been proven conclusively and the-Licensee therefore, ;
requests to eliminate confusion from the Technical Specifications.
(4) Licensee proposes to reduce the existing Surveillance-Test Interval-(STI) for the Emergency Cooling Water pump and the ESW booster pumps from once per operating cycle to every 3 months. Surveillance requirement 4.9.C.3.a shall read, "The Emergency Cooling Water pump and ESW booster pumps shall'be tested in accordance with Section X. of the ASME Boiler f
Pressure Vessel Code and applicable Addenda, except where relief-has been granted."
_(5)__ Licensee proposes to reduce the existing STI for the Emergency Cooling Tower-fans-from once per operating cycle to every three months. Surveillance Requirement 4.9.C.3.b shall read:
"The Emergency Cooling Tower fans shall be tested _once every three months to verify operability.".
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-Docket-Nos. 50-277 50-278' License Nos.-DPR-44 DPR-56 (6) Licensee proposes to revise the Bases of Section 3.9 to correctly define the relation between the ECW pump and the ESW pump. The second, third and fourth sentences of the last paragraph shall be deleted. The ECW pump could not be conclusively proven to satisfy the criteria to be. equivalent to an ESW pump and its associated system for a Design Basis Accident (DBA); therefore,-all references in the TS to such an equivalent function are being deleted.
(7) Licensee proposes to revise the Bases of Section 3.9 by replacing the paragraph discussed in (6) with the following statement: "In the event one of the ESW pumps becomes ,
inoperable, the 7 day allowable out of service time is conservative given the probability of an event requiring-the use of both ESW pumps occurring in that amount of time. One
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ESW-pump is capable of cnpplying the entire system. If both of- the ESW pumps beer,me inoperable, placing the reactor in a shutdown condition la consistent with the severity of the situation.".
(8) Licensee-proposes to revise the Bases of Section 4.9. -The last paragraph of the section shall be-revised to eliminate references to the Emergency Cooling Water pump, the ESW Booster pumps and the Emergency Cooling Tower fans. .This information belongs in the bases for the alternate heat sink l facility as discussed in change number 12. The 4.11.B Bases
. Docket Nos. 50-277
', 50-278 License Nos.lDPR-44 '
-will state: "The testing of the ESW Booster Pumps and the ECW pump is in accordance with existing ASME. codes and applicable addenda except where relief has been granted and assures the required availability of the equipment.".
(9) -Licensee proposes to add an additional SurveJ11ance :
Requirement. This additional requirement will be numbered 4.9.c.3 and will state: "Each manual valve and each electric motor operated valve, that is_not in the-system flow path and that is not-locked, sealed or otherwise secured in position, ,
shall be verified monthly to be in its correct posit 3cn.".
(10) Licensee _ proposes to add an additional Surveillance l
Requirement. This additional requirement shall be numbered 4;9.C.4 and will state for Unit 2 TS: "Once per refuel outage ,
the bottom of the 'AESW pump intake structure will be inspected and' cleaned as necessary to remove excessive silt.";
_the Unit 3 TS will state: "Once per refuel outage the bottom of the 'B' ESW pump intake structure will be inspected and' cleaned as necessary to remove excessive silt."
The_following. changes _are purely administrative, such as renumbering land relocating sections of the TS. These activities do
- not: affect the safety of the plant and do not represent an unreviewed safety question.
Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56
-(11) Licensee proposes that the LCOs for one ESW pump and two ESW pumps being inoperable be numbered 3.9.C.2 and 3.9.C.3, respectiaely. This numbering sequence is a purely administrative change designed to improve the logic and practicality of the TS.
(12) Licensee proposes to relocate the TS Surveillance Requirements currently numberea 4.9.C.3.a and 4.9.U.3.b to section 4.11.B of the TS. Additional changes to these sections are being requested in this proposed amendment (paragraphs 4 id 5);
} however, the relocation to these sections to section 4.11.B is consistent with the function of these specific sections and is
, a purely administrative function designed to improve the logic and practicality of the TS.
(13) Licensee proposes to rename Alternate Heat Sink Facility to Emergency Heat Sink in Section 3.11.B and 4.11.B and their associated bases. The proposed sections would read:
3.11.B. Emer_gency Heat Sink Facility The level in the emergency reservoir of the Emergency Heat Sink Facility shall not be less than 17'. Should the level drop below this point action -
shall be taken to restore the level to above the minimum, within 7 days.
4.11.B. Emergency Heat Sink Facility l
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DochotLNos..50-377 l 50-278 '
License Nos.-DPR-44 DPR-56
- 1. The level in the emergency reservoir of the Emergency Heat Sink Facility shall be checked once per month.
In addition to the changes proposed in-paragraph'8, emergency would replace alternate in the section title. These changes
- would-make the_name of this facility consistent between the Updated Final Safety Analysis Report (UFSAR) and the Technical Specifications and eliminate some confusion among Licensee
. personnel. This change is strictly administrative.
t II .- SAFETY DISCUSSION Change request-(1) concerns an additional LCo-to assign a 7 day AOT for either of the ESW pumps should they become-Inoperable. ;
In the event that one of the two ESW pumps become inoperable, the 7 day time period is considered conservative-based on the fact that'
-an additional 100% capacity pump would still be available. In addition, the 7 day LCO is consistent with the standard Technical
-Specification: requirements for 100-percent remaining capacity.
- A Probabilistic Risk Assessment _ comparison to the. current TS allowable out of_ service times for the High Pressure Injection
-Cooling (HPCI) system and each of the diesel generators was
. completed. The proposed 7 day LCO for an ESW pump had an equal or less impact on the probability of a core damage accident in all L.
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... Docket Nos. 50-277 50-278 l
4 License Nos. DPR-44 l DPR-56 cases. The allowable out of service times for the llPCI 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.
i The current Technical Specifications do not address this scenario and allowed unlimited operation with an Emergency Cooling Watcr (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 an-administrative limit of 7 days to restore the ESW pump to operability or begin shutdown. ,
t This-TSCR-will supplant PORC position 33 and replace-an administrative limit with a TS limit.
Change request (2) concerns reducing the existing AOT for two ESW pumps from-1--month to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The loss of both ESW pumps
-indicates a significant reduction in redundancy in emergency
-cooling 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 f-l: has 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 l
L, Docket Nos. 50-277 50-278 License Nos. DPR-44
-DPR-56 3.0.C would also require a plant shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; however, by placing the requirement in the ESW section the human factors of the TS are improved.
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Change request (3) concerns the deletion of Section 3.9.C.3.
This section discusses the equivalency of the ESW and the ECW pumps. After an engineering evaluation, it was determined that these pumps are not equivalent. Because of this determination the proposed TS amendment is being submitted. To clarify the TS.it is requested that this section of the TS be removed.
Change request (4) changes the surveillance test interval
.(ST1) for the ESW booster pumps and the Emergency Cooling Water Pump from once per operating cycle to once overy 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 sutveillance 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.
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Docket Nos. 50-277 4 - -
50-378 License Nos. DPR-44 DPR-56 Therefore, there is no presumed test availability for the EHS system.
' Change requests (6), (7) and (8) concern revising the Bases to l accuratelyfreflect changes proposed-to-Section 3.9, 4.9 and 4.11.
Consistency-between the Bases and their corresponding LCOs and SRs l-l-
is necessary to avoid misinterpretations and to enhance the understanding.of the intent of the requirement.
Change' request (9) concerns the addition of 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.
NOTcomponents in the ESW System are operated to perform this ST; therefore, there is no' concern ~that~ increased testing could damage components or decrease system availabilityL.
, Change request (10) concerns the addition of a Surveillanco requirement. .This change' conforms to the StandardLTechnical Specification surveillance requirements for inspection of the bottom of the ESW-pump intake structure. The reliability of the
'vSW system-would be improved by ensuring that the bottom of the structure wasirelatively free of mud 'd debris that could affect I 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.
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. Docket lios . 50-277 50-278 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 reliability and the improvement in system reliability that will result from this regular inspection. 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 (11) and (12) concern the renumbering and location of LCOs and SRs to improve the logic and human factors of the Technical Specifications. These changes are strictly administrative in nature and have no effect 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 chenge is strictly administrative and has no effect on the safety of the plant.
9 No Significant Hazards Consideration The change requests proposed in this Application do not constitute a significant hazards consideration in that:
T:
., Docket Nos. 50-277-50-278 License Nos. DPR-44 DPR-56 i) The proposed changes do not involve a significant 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
. equipment necessary 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.
The addition of new survaillance requirements and changes to existing surveillance requirements has a similar affect-on p1 ant' equipment and has.no affact on the probability or consequences of an accident. By inspecting the pump pit and the-valve line up on a regular' basis the probability that the e.quipment will be-available to mitigate the coneequences of an accident-will be increased. In addition the increased f
surveillance of the Emergency Service Water Booster pumps and the Emergency Cooling Tower Fans can only improve the l
I e u
- ?i Docket. !Jos. 50-277 t#
S0-270 LJ ense IJo s . DPil-44 DPH-56 1i) The_p_roposed changes do not create the passibi1ity_of a now or difforent kind of accident from any_proviously evaluated.
The proposed changes to the TS impact equipiaent that is important to safoty and that mitigates the consequences of an accident. This equipment and the changes being proposed do not change *he operation of PBAPS and therefore, the changes s cannot. Introduce any new or dif f erent. kind of accident.
111) The proposed changes do not involve a signifIcant reduction in a margin of safety.
The margJn of safety is not. reduced by these changes. !Jo credit. was taken in accident, analysis for the ECW pump to act as an equivalent. ESW pump. The other changes bLing proposed will give a greater assurance that equipment important to sa f et.y will be available t.o mitigate the conses:ences of an accident.
Environmental Assessment An environmental impact assessment is not required ior the changes proposed by this Application because the changes conform to the criteria for " actions eligible for categorical exclusion" as specified in 10 CFR 51.22(c)(9). The proposed
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' Docket Non. 50-277
. 50-278 Licenso Nos. DPI(-44 DPit-56 i 1
changos do not' involve any systems that have a direct relationship l with tho environment. The changes involvo the definition of Survo111anco Frequency. The Application involvos no significant.
change in the types or significant increaso in tho amounts of any l of flu'inta that. may be released of f site and thoro will be no :
significant. Increase in Individual or cumulative occupational s radiation oxposure.
Conclusion The Plant. Opernt. ions lloview Committoo and the Nuclear Review Board have reviewed thoso proposed changes and have t concluded that they do not involve an unroviewed safoty question and are not a t.hreat to the health and safoty of the public.
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