ML20128D587
| ML20128D587 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/23/1985 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20128D570 | List: |
| References | |
| NUDOCS 8505290128 | |
| Download: ML20128D587 (11) | |
Text
{{#Wiki_filter:. BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION 'In the Matter of Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 & DPR-56 Edward G. Bauer, Jr. Eugene J. Bradley i 2301 Market Street Philadelphi'h', Pennsylvania 19101 Attorneys.for Philadelphia Electric Company t- "BR'2;g;ggeggggg;,- P =
c BEFORE THE ' UNITED STATES NUCLEAR-REGULATORY COMMISSION In the-Matter of. Docket Nos. 50-277 -PHILADELPHIA ELECTRIC COMPANY 50-278 APPLICATION FOR AMENDMENT OF l FACILITY OPERATING LICENSES DPR-44 & DPR-56 i l' Philadelphia Electric Company, Licensee under Facility .-Operating Licenses DPR-44 and DPR-56 for the Peach Bottom Atomic Power Station Unit Nos. 2 and 3, respectively, hereby requests -that'theTechnicalSpecificationsincorporate}dinAppendixAof the operating Licenses be amended by revising certain sections as V. H indicated'by a vertical bar in the margin of the attached pages 1, 214 and 215, and by~the addition of new page 214a which is also attached hereto and incorporated herein by reference. s The' revision requested to page 1 concerns the definition of' Alteration of the Reactor Core. Secondary containment
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integrity is maintained when alterations to the reactor core are in progress. During certain circumstances, all reactor fuel is removed from the reactor vessel. An assessment for the need for secondary containment integrity during in-core maintenance with all' fuel removed has been made. It was determined that the Technical Specification Core Alteration definition does not recognize nor should it apply to alterations which occur within the reactor vessel when there is no fuel in the reactor vessel. This determination is based on the fact that the ' Core' is non-existent with no fuel present in the vessel. The proposed revision on page 1 provides clarification of the definition and is consistent with the definition in the Commission's Standard Technical Specifications which states, " Core Alteration shall be the addition, removal, relocation or movement of fuel, sources, incore instruments or reactivity controls within the reactor pressure vessel with the vessel head removed and fuel in the vessel. Suspension of Core A,terations shall not preclude completion of the movement ot a component to a safe conservative position," for General Electric Boiling Water Reactors. The revisions requested to pages 214fand 215 concern the Limiting Conditions of Operation for the hydrogen concentration in the offgas recombiner system and associated hydrogen analyzers. The Licensee requests the following changes. (1) The current Technical Specification Section 3.8.C.6 requires that the concentration of hydrogen downstream .of the~recombiners shall be limited to less than or i: equal to_2% by volume. Technical Specification Section 8.C.6.a, on-page 214, further states that if the 3 concentration of hydrogen down' stream of the recombiner becomes. greater than 2%, but less than or equal to 4% by volume,Lthe concentration must be restored to 2% within 48 hours. Technical Specificatien Section 3.8.C.6.b states that if the concentration of hydrogen downstream of the recombiner exceeds 4% by volume, an orderly reduction of power shall'be initiated within one hour to bring the concentration of hydrogen downstream of the recombiner to less than or equal to 2% by volume. Philadelphia Electric Company has replaced the Unit 2 -compressed storage offgas system (mechanical compressors and pressurized holdup pipe) with a low pressure ambient charcoal delay system consisting of a cooler t condenser / moisture separator, guard bed, main adsorber l bed,_and glyco 1' cooling equipment. The compressed storage delay system (pressurized holdup pipe) was not detonation resistant downstream of th'd mechanical ) j compressors due to the high operating pressure (approximately 200 psig). As modified, the holdup pipe of the system (which is partially filled with charcoal) operates at essentially atmospheric pressure and is, i therefore, detonation resistant. In addition, the potential for a hydrogen detonation has been reduced due. O
t-to the elimination of many active components from the gas stream. Since the new system is designed to withstand hydrogen detonation, we ' request that the i Technical Specification Section 3.8.C.6.a be revised to i modify the time required to restore the concentration of hyd'rogen downstream of the recombiner to less than or equal-to 4% by volume. This criteria is consistent with the Stando.rd Technical Specifications for General Electric Boiling Water Reactors (NUREG-0473, Rev. 2, page 11-16) for systems designed to withstand a hydrogen explosion. Therefore, we request that Technical Specification Sections 3.8.C.6 and 3.8.C.6.a be revised to modify the limit of the concentration of hydrogen downstream of the recombiners to less than or equal to 4% by volume, and delete current Technical Specification Section 3.8.C.6.b. (2) The current' Technical Specification Section 3.8.C.6.c on page 214 requires two hydrogen monitors downstream of the recombiner to be operable during power operation. In addition, Technical Specification Section 3.8.C.6.d allows continued operation for 14 days in the event the number of operable hydrogen monitors are one less than required, provided grab samples are taken and analyzed
every 4 hours. With replacement of the compressed storage delay offgas system with an ambient charcoal treatment system, which is designed to withstand a hydrogen detonation, the requirement to initiate system isolation when high ~ hydrogen concentrations are detected no longer exists. Upon removal of the mechanical compressors, the hydrogen analyzers will be utilized only as an alarm function. One out of two analyzers in service is adequate to meet the requirements of Section 11.3, Gaseous Waste Management, Subsection II.B.6 of the Commission's Standard Review Plan, which states that the process gas stream should be analyzed and potentially explosive mixtures annunciated. The proposed change is also consistent with the Commission's NUREG-0473, Revision 2, " Radiological Effluent Technical Specifications for BWR's." Therefore, we request that the Technical Specifications be revised to require one hydrogen monitor downstream of gh the recombiner operable during power? operation. In addition, we request that the Technical Specifications be revised to allow operation to continue up to 30 days with the number of hydrogen monitors operable less than required provided that grab samples are taken and analyzed every 4 hours during power L
operation. This change is also consistent with the Commission's Standard Technical Specifications i previously referenced. 1 i .The Licensee requests that the existing Technical Specification Sections 3.8.C.6 through 3.8.C.6.d and , Sections 4.8.C.6.a through 4.8.C.6.c on pages 214 and 215 be relocated onto the new page 214a of the Technical Specifications. In addition, the revised Technical I Spccification Sections 3.8.C.6, 3.8.6.C.a, 3.8.C.6.b, 'and 3.8.C.6.c, will also be located on new page 214a, with the-asterisked note stating that these new sections of the Technical Specifications take effect upon completion of the installation of the ambient charcoal treatment system. The purpose for locating the existing Technical Specification Sections 3.8.C.6 through 3.8.C.6.d and Sections 4.8.C.6.a through 4.8.C.6.c and the revised Technical Specification Sections 3.8.C.6 through 3.8.C.6.c-on the same new page is to minimize the potential for operator error which could occur if i these sections were located on separ.dte pages. i Significant Hazards Consideration Determination d The proposed changes to the Technical Specification Section 3.8.C.6 constitute revisions to a limiting condition for-operation to reflect improvements in the system design. The
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proposed addition of the words "with the vessel head removed and r fuel in the vessel" to the " Alteration of the Reactor Core" definition provides clarification consistent with its intent of avoiding fuel damage. The Commission has provided guidance concerning the application of the standards 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: (vii) 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 changes to Technical Specification Section 3.8.C.6 most closely fit this example of an action not involving a significant hazards determination since they are in compliance with the Commission's Standard Technical Specifications and Standard Review Plan. Consequently, the proposed changes do not: (1) involve a significant increase in the probability or con' sequences 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. The Plant Operational Review Committee and the Nuclear Review Board (off-site safety review committee) have reviewed these proposed changes to the Technical Specifications and have 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. Respectfully submitted, PHILADELPHIA ELECTRIC COMPANY Ox ) ( ) a . A f'{A.-1-{ By +' s Vice' President /{ t ?; e 9 e 0 y-v--w-_,,wt-i-
. COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF PHILADELPHIA S. L. Daltrof f, being first duly sworn, deposes and says: That he is 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, infor:aation and belief. ) / /{ Aflui j / i i Subscribed and sworn to before me thisala.tday of MM, I'l6 a loN 1hh Notary Public JUDITH Y. FRANKUN Notary Public Phila., Phila. Co. My Commission Empires Jufy 28,1e87 ,n-- .._,-c
l. CERTIFICATE OF SERVICE I certify that service of the foregoing Application for Amendment was made t:pon the Coninonwealth of Pennsylvania, by 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 23rd day of May, 1985. %c C b /f Eugen J./Bradley / Attorney for Philadelphia Electric Conpany N l i i + . _ _ _ _,}}