ML20107D620

Application for Amend to Licenses DPR-44 & DPR-56,changing Tech Specs Re Radiological Effluents.Certificate of Svc Encl

ML20107D620
Person / Time
Site:	Peach Bottom
Issue date:	02/15/1985
From:	Boyer V, Bradley E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20107D619	List: ML20107D620
References
NUDOCS 8502250062
Download: ML20107D620 (11)

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BEFORE TIIE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket No. 50-277 50-278 PIIILADELPIIIA ELECTRIC COMPANY APPLICATION FOR AMENDMENT OF 1

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 8502250062 850219 1

PDR ADOCK 05000277 P

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r BEFORE T!!E UNITED STATES NUCLEAR REGULATORY COMMISSION In the 11atter of Docket No. 50-277 50-278 PIIILADELPilIA ELECTRIC COMPANY APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 & DPR.

Philadelphia Electric Company,; Licensee un' der Facility Operating Licenses DPR-44 and DPR-56-for'the Peach Bottom Atomic

' Power. Station Unit--No. 2 and Unit No.

3, respectively,:hereby re, quests that the Technical Specifications contained in Appendix A of the Operating Licenses be amended by revising certain sections as! indicated by a vertical'bar-in the margin'of the-attached pages 206, 211 and 214.

All of the revisions requested in' this: submittal concern the Radiological Ef fluent Technical Specifications issued August 3,.1984, as Amendment Nos. 102 and 104 to Peach Bottom Atomic Power Station, Unit Nos. 2 and 3, respectively.

The Application requests the following changes:

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(1): The current Technical Specification 4.8.D.3a on 2

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.page 206 requires, in part, that a functional test be performed

-once/ month-to demonstrate that a downscale failure of the

.radwaste liquid effluent radiation monitor will automatically

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isolate the radwaste discharge valve and actuate the downscale

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failure alarm in the control room.

The radwaste liquid effluent rad monitor has two failure modes, the downscale failure and the INOP failure.

The downscale failure occurs when the gross activity detected by the monitor decreases.below a pre-set value.

The INOP failure occurs when

.any one of the following. conditions exists: (1) low voltage to

'the:radwaste liquid effluent radiation detector, (2) radwaste cliquid-effluent rad monitor modo switch not in " operate", or (3).

removal of any one of the plug-in modules in the radwaste liquid

. effluent-rad monitor.

Either failure mode actuates a common downscale/INOP alarm in the control room.

By design, a downscale failure'of the radwaste liquid effluent rad monitor =does not automatically isolate the radwcote.

. discharge valve.

An INOP.fa'ilure, however, does. automatically isolate'the:radwaste' discharge valve.

Upon actuation of-the common downscale/INOP alarm in the

' control: room, the radwastecliquid effluent rad monitor front-3

panel'lightsJare checked to determine which' failure mode actuated.

th. alarm.

If,the INOP-light <on the' monitor front panel is lit,

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-the radwasteLdischarge: valve-is verified to be-closed and an

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L investigation is initiated to determine the cause of..the INOP m (",

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failure. 'If the downscale light on the monitor front panel is lit, an investigation is initiated to determine the cause of the downscale failure.

Technical Specification 3.8.B.3.d allows radwaste liquid effluent releases to continue when the radwaste liquid effluent rad monitor experie es a failure provided that best efforts are taken to make the rad monitor operabic and that, prior to each release, two independent effluent samples are analyzed and two technically qualified members of the facility staff independently verify release rate calculations and discharge line valving.

Peach Bottom Surveillance Test, ST-4.5, Revision 3, is performed once/ month for the purpose of verifying, in part, proper operation of the radwaste discharge valve.

Steps 23 and 24 of ST-4.5 verify that an "INOP" cond,ition will automatically isolate the radwaste discharge valve.

Ue. request that the word "downscale" be changed to "INQP" in Technical Specification 4.8.D.3a.2 on page 20G.

This-change is requested since the downscale failure does not automatically isolate the radwaste discharge valve and is

. justified since a downscale alarm is provided to alert the operator.to the downscale condition and Technical Specification 3.8.D.3.d allows radwaste releases to continue when the radwaste liquid effluent rad monitor c5:periences a failure provided the requirements of this Technical Specification are met satisfactorily prior to each release.

This. change is requested as a result lof an oversight in review of a previous Technical 4

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Specification Amendment Application submittal concerning radioactive effluent materials.

(2)

The current Technical Specification 4.8.C.6c on page 214 requires calibrating the recombiner hydrogen analyzers using a 1% hydrogen-balance nitrogen gas and a 4% hydrogen-balance nitrogen gas.

As a result of a plant modification implemented prior to the effective date of Amendment Nos. 102 and 104, two new helium-immune hydrogen analyzers were installed in parallel with two of the existing hydrogen analyzers for the purpose of facilitating main condenser leak testing.

The calibration gases required for the new helium-immune hydrogen analyzers are different from the calibration g' aces required for the existing hydrogen analyzers.

The-span gas used to calibrate the existing hydrogen analyzers is 4% hydrogen-balance nitrogen.

However, the span gas required for the new helium-immune hydrogen analyzers is 2%Lhydrogen-balance air.

Therefore, to properly calibrate both types of hydrogen analyzers, and to avoid listing the individual gas concentrations required for each type of hydrogen analyzer in the Technical Specifications, we are requesting a revision to page 214 of the Technical Specifications to delete 4.0.C.6c and to expand 4.8.C.6b to require the use of standard bottled hydrogen gas.

-Peach Dottom Surveillance Tests ST-9.13 and ST-9.13A specify the method of calibration for the existing hydrogen analyzers and the helium-immune hydrogen analyzers, respectively.

The effectiveness'of-the Technical Specifications is enhanced by

' limiting its scope to the_ essential operability and surveillance y

requirements.

The benefit of limiting the volume of the Technical Specifications was acknowledged in the NRC's proposed

Rule change-to 10 CFR 50.36, published March 30, 1982.

For this reason, and considering the effectiveness of existing plant procedures, it is not appropriate to incorporate a listing of the various recombiner hydrogen analyzer calibration gases into the Technical Specifications.

(3)

Tbc current Technical Specification 4.8.C.4c on page 211 requires, in part, performing an instrument check on the

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main stack iodine and particulate sample flow rate monitors every

. day.

The ma.in stack sample flow rate monitors are located at the base of the main stack.

In order to obtain access to this location, technicians must travel by vehicle to the Peach Dottom North Substation and obtain access through the security gates at the Substation.

Due to the remote location of the main stack

sample flow monitors, it is desireable to limit the number of excursions to the base of the main stack.to once/ week.

Peach Dottom Surveillance Test ST-7.6.1.f is performed once/ week for the purpose of changing out the main stack sample flow filters.

Dy limiting the frequency of the main stack sample u

flow monitor instrument check to once/ week, both tasks (changing 4

out'the. filters and performing the instrument check) could be accomplished simultaneously.

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L Additionally, an installed set of pressure switches already exists which actuate an~ alarm in the main control room in the event of main stack sample flow trouble and therefore compensates for the requested change in the surveillance frequency.

Therefore, we request that the frequency of the main stack sample flow monitor instrument check be changed from once/ day to once/ week.

The attached Technical Specification 4.8.C.4c, page 211, indicates our proposed change.

Significant IIazards Consideration Determination The Commission has provided guidance concerning the

. application of theLstandards for determining whether license amendments. involve no significant hazards considerations by providing certain examples (48 FR 14870).

One of the examples of actions involving no significant hazards consideration is a purely. administrative change to Technical Specifications required as the result of art error.

Amendment requests (1) and (3) of this submittal conform to this example.

The errors are the result of an oversight in review of a previous Technical Specification amendment application submittal concerning radioactive effluent materials.

The proposed changes involving the recombiner hydrogen analyzer calibrations ~ (Amendment Request 2) are-required as the result of a plant modification implemented prior to the effective date of the Radiological Effluent Technical Specifications which

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- installed a new type of hydrogen analyzer in addition to the

-existing ~ hydrogen analyzers.

The new analyzer requires a

- different type of calibration gas than the existing analyzer.

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- Therefore,.a change to the Technical Specifications is required to allow proper calibration of both types of analyzers.

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proposed change is justified by the benefits of limiting the volume of'the Technical Specifications, and the effectiveness of

- existing plant. procedures establishing the calibration

- requirements.

This change conforms to example vi (48 FR 14870) of actions involving no significant hazards consideration since the results of the change are clearly within,all acceptable criteria.

For these' reasons, the amendment requests do not p

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constitute a significant hazards consideration since.they do not:

(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 (3) involve.a significant-reduction in a margin of safety.

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The Plant Operational Review Committee and the Nuclear Review Board (off-site safety review committee) have reviewed

'l these proposed changes to the Technical Specifications and have j

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- concluded that they do not involve an unreviewed-safety question or a significant hazards consideration and will not endanger the health and safety of the public.

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Respectfully submitted, PHILADELPHIA ELECTRIC COMPANY F v v [m Senior Vice Prb%ident 6

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COUNTY OF PIIILADELPIIIA V. S. Boyer, being first duly sworn, deposes and says:

That he is Senior Vice President of Philadelphia Electric Company, the 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 knowledge, information and belief.

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V Subscribed and sworn to before=me-thisI ay of"/ATZK (9[Si

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NotIry'Public PATRICIA D. SCHOLI:

Notary Public, Philadelphia, Phi!adc!phis Co.

My Commission Expires Febray 10,1906 a

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CERTIFICATE OF SERVICE r

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I certify that service of the foregoing Application for l

' Amendment was made upon the Commonwealth of Pennsylvania, by

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mailing a copy thereof, via first-class mail, to Thomas R. Gerusky, Director, Bureau-~of Radiological Protection, P.O. Box 2063, Harrisburg, PA 17120; all this 19th day of February, 1985 e

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Eugfe/J. Bradley [

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