ML20140D850
| ML20140D850 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/04/1997 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20140D856 | List: |
| References | |
| NUDOCS 9706110107 | |
| Download: ML20140D850 (8) | |
Text
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Cution Crpport Department
_A 10 OFR 50.90 PECO NUCLEAR reco teerov cereneev 965 Chesterbrook Boulevard A Unit of PECO Energy Wayne PA 19087-5691 June 04,1997 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 i
J U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 l
Subject:
Peach Bottom Atomic Power Station, Units 2 and 3 l
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License Change Application ECR 97-00086 j
Dear Sir:
PECO Energy Company (PECO Energy) hereby submits License Change Application ECR 97-00086 in accordance with 10 CFR 50.90, requesting a change to the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 Facility Operating Licenses. This proposed change will revise Section SR 3.0.2.1 of the PBAPS, Units 2 and 3 Technical Specifications (TS) to eliminate an inconsistency between the requirements for ECCS operability and the auto-start and trip bypass of the Emergency Diesel Generators (EDGs) on an ECCS initiation signal during:
MODE S, the spent fuel storage pool gates are removed, e
water level is 2 458 inches above reactor pressure vessel instrument zero, and there are no operations with the potential of draining the reactor vessel (OPDRVs) in i
progress.
Information supporting this request is contained in Attachment 1 to this letter, and the marked up pages showing the proposed changes to the FBAPS, Units 2 and 3 TS are contained in
~. We request that this amendment to the PBAPS, Units 2 and 3 TS be approved by August 29,1997.
If you have any questions, please do not hes'. tate to contact us.
f Ver/ truly yours, G
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Director-Licensing
Enclosures:
Affidavit, Attachment 1, Attachment 2 cc:
H. J. Miller, Administrator, Region I, USNRC W. L. Schmidt, USNRC Senior Resident inspector, PBAPS R. R. Janati, Commonwealth of Pennsylvania 9706110107 970604 PDR ADOCK 05000277 P
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COMMONWEALTH OF PENNSYLVANIA ss.
COUNTY OF CHESTER J. B. Cotton, being first duly swom, deposes and says:
That he is Vice President of PECO Energy Company; the Applicant herein; that he has read the atttaned License Change Application ECR 97-00086, for Peach Bottom Facility 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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Vice President Subscribed and swom to before me this day of 1997.
Notary ublic Lau SNI, Nota Putic Twp, chester l
St"es May 17, 999,
. WWenis Amannsehn of Notarm
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ATTACHMENT 1
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PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 3
Docket Nos. 50-277 50-278 j
License Nos. DPR-44 DPR-56 LICENSE CHANGE APPLICATION ECR 97-00086 1
l "ECCS/EDG Shutdown Technical Specifications" Supporting information - 4 Pages i
Docket Nos. 50-277 4
50-278 License Nos. DPR-44 DPR-56 l
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Introduction l
PECO Energy Company, Licensee under Facility Operating Licenses DPR-44 and DPR-56 for the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, requests that the Technical Specifications (TS) contained in Appendix A to the Operating License be amended to revise Sect,on SR 3.8.2.1 of the PBAPS, Units 2 and 3 Technical Specifications to eliminate an inconsistency between the requirements i
for Emergency Core Cooling System (ECCS) operability and the auto-start and trip bypass of the i
Emergency Diesel Generators (EDGs) on an ECCS initiation signal during MODE 5, the spent fuel 1
storage pool gates are removed, water level is 2 458 inches above reactor pressure vessel instrument zero, and there are no Operations with the Potential of Draining the Reactor Vessel (OPDRVs) in progress. The TS and Bases pages showing the proposed changes are contained in Attachment 2. This License Change Application (LCA) provides a discussion and description of the proposed TS changes, a safety assessment of the proposed TS changes, information supporting a finding of No Significant i
Hazards Consideration and information supporting an Environmental Assessment.
Discussion and Descriotion of the Proposed Chanae Surveillance Requirement SR 3.8.2.1 will be annotated with a note which specifies that the requirements 3
for SR 3.8.1.12, SR 3.8.1.13, and SR 3.8.1.19 are not required to be met when the associated ECCS are d
not required to be OPERABLE.
j The proposed change to the facility does not make any physical changes to the facility. The benefit of this proposed change to the facility will provide increased flexibility for reactor level instrumentation work and testing during refueling outages.
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A Bases change is included as a part of this request. The Bases section for SR 3.8.2.1 (page B3.8-46) will be revised to include the. explanation for the note added to SR 3.8.2.1, and to indicate that the i
i penods for which the ECCS are required are specified in LCO 3.5.2, "ECCS - Shutdown".
f Safety Assessment This proposed change will revise Section SR 3.8.2.1 of the PBAPS, Units 2 and 3 Technical Specifications (TS) to eliminate an inconsistency between the requirements for ECCS operability and the auto-start and trip bypass of the Emergency Diesel Generators (EDGs) on an ECCS initiation signal
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during MODE 5, the spent fuel storage pool gates are removed, water level is 2 458 inches above j
reactor pressure vessel instrument zero, and there are no operations with the potential of draining the reactor vessel (OPDRVs) in progress. Under certain plant conditions it is acceptable not to require any ECCS to be OPERABLE (i.e., the plant in MODE 5, the spent fuel storage pool gates are removed, water i
level is 2 458 inches above reactor pressure vessel instrument zero, and there are no OPDRVs in j
progress), it is therefore unnecessary to impose the requirements of EDG auto-start and trip bypass on the ECCS Initiation signal (SR 3.8.1.12, SR 3.8.1.13, and SR 3.8.1.19) during these plant conditions.
The plant conditions which do not require any ECCS to be OPERABLE (i.e., the plant in MODE 5, the spent fuel storage pool gates are removed, water level is 2 458 inches above reactor pressure vessel i
instrument zero, and there are no OPDRVs in progress), ensure sufficient coolant inventory to allow 1
operator action to prevent uncovering the fuel. The ability of the EDGs to auto-start on a loss of offsite power or degraded voltage will remain unchanged.
Technical Specification Table 3.3.5.1-1, " Emergency Core Cooling System Instrumentation", requires that the instrumentation for Reactor Vessel Water Level - Low Low Low (Level 1) be OPERABLE in MODES 4 and 5. This requirement is annotated with a note which specifies OPERABILITY is only required when the associated subsystem (s) are required to be OPERABLE. The instrumentation for Reactor Vessel Water Level-Low Low Low (Level 1) and Drywell Pressure High are annotated in Technical Specification Table 3.3.5.1-1 as being required to initiate the associated EDGs. Technical 1
Docket Nos. 50-277 50-278 Licerse Nos. DPR-44 DPR-56 Specification Table 3.3.5.1-1 does not require the instrumentation for Dr)well Pressure - High to be l
OPERABLE in MODES 4 and 5.
Technical Specification 3.5.2, "ECCS - Shutdown *, requires that two low pressure ECCS injection / spray subsystems be OPERABLE during MODE 4 and MODE 5, except with the spent fuel storage pool gates removed, water level 2 458 inches above reactor pressure vessel instrument zero, and no OPDRVs in progress. Therefore, if the plant is in MODE 5, the spent fuel storage pool gates are removed, water level is 2 458 inches above reactor pressure vessel instrument zero, and there are no OPDRVs in progress, no ECCS subsystems I,re required to be OPERABLE. The justification for this is provided in Technical Specification Bases B3.5.2, 'ECCS - Shutdown".
Technical Specification 3.8.2, AC Sources - Shutdown requires two EDGs each capable of supplying one onsite Class 1E AC electrical power distribution subsystem during MODES 4,5 and during movement of irradiated fuel assemblies in the secondary containment. As part of the compliance with this Technical Specification, SR 3.8.2.1 invokes the applicability of SR 3.8.1.12, SR 3.8.1.13, and SR 3.8.1.19. SR 3.8.1.12 requires the verification that on an actual or simulated ECCS initiation signal each EDG auto-starts from the standby condition. SR 3.8.1.13 requires verification that certain EDG trips are bypassed on an actual or simulated ECCS initiation signal. SR 3.8.1.19 requires the verification that on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated ECCS initiation signal, each EDG auto-starts from the standby condition. The purpose of SR 3.8.1.12 and SR 3.8.1.19 is to demonstrate that the EDG automatically starts and achieves the required voltage and frequency within the specified time (10 seconds) from the design basis actuation signal (LOCA signal) and operates for 2 5 minutes. The purpose of SR 3.8.1.13 is to demonstrate that non critical protective functions are bypassed on an ECCS initiation signal. Under the current Technical Specifications, SR 3.8.1.13 and SR 3.8.1.19 are not required to be performed when the unit is in MODES 4 and 5, however, the capability to meet the associated requirements must be maintained.
The design basis actuation signal (ECCS initiation - LOCA signal) for an EDG auto-star 1 consist of two signals. The two signals are a Drywell Pressure - High signal or a Reactor Vessel Water Level-Low Low Low (Level 1) Lignal.
The Drywell Pressure - High signal is required to be OPERABLE when the ECCS or EDG is required to be OPERABLE in conjunction with times when the Primary Containment is required to be OPERABLE es stated in Technical Specification Bases B3.3.5.1. Per Technical Specification 3.6.1.1, " Primary Containment", Primary Containment is required to be OPERABLE in MODES 1,2, and 3, therefore. Re l
Drywell Pressure - High signal is not required to support EDG OPERABILITY in MODES 4 and 5.
j The Reactor Vessel Water Level - Low Low Low (Level 1) signal is required to be OPERABLE whea ECCS or EDG are required to be OPERABLE as stated in Technical Specification Bases B3.3.5.1 j
Technical Specification Table 3 3.5.1-1 requires Reactor Vessel Water Level - Low Low Low (Le /ei 1) to be OPERABLE in MODES 4 and 5 only when the associated subsystem (s) are required to be OPERABLE. As stated earlier, in MODES 4 and 5, the Reactor Vessel Water Levelinstrumentation is not required to be OPERABLE if the associated subsystem (s) are not required to be OPERABLE.
Therefore, if the plant is in MODE 5, the spent fuel storage pool gates are removed, water !evel is 2 458 inches above reactor pressure vessel instrumerit zero, and there are no OPDRVs in progress, the Reactor Vessel Water Level instrumentation is not required to be OPERABLE to support ECCS Operability. Presently no such exception for EDG Operability is specified for periods when ECCS are not required.
Since under certain plant conditions it is acceptable not to require any ECCS to t'e OPERABLE, it is unnecessary to impose the requirements of SR 3.8.1.12, SR 3.8.1.13, and SR 3.8.1.19, EDG auto-start and trip bypass on the ECCS initiation signal during all plant conditions. The plant conditions which do not require any ECCS to be OPERABLE,(i.e., the plant in MODE 5, the spent fuel storage pool gates are 2
DoclGt Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 removed, water level is 2 458 inches above reactor pressure vessel instrument zero, and there are no OPDRVs in progress) ensure sufficient coolant inventory to allow oprator action to prevent uncovering the fuel. The ability of the EDGs to auto-start on a loss of offsite power or degraded voltage will remain unchanged.
i SR 3.8.2.1 will be annotated to indicate that the requirements for SR 3.8.1.12, SR 3.8.1.13, and SR 3.8.1.19 are not required to be met when the associated ECCS is not required to be OPERABLE.
Information Sucoortina a Findina of No Sianificant Hazards Consideration We have concluded that clarifying SR 3.8.2.1 to state that the EDG auto-start and EDG trip bypass on ECCS initiation capability is not required during periods in which ECCS is not required to be OPERABLE, does not involve a Significant Hazards Consideration. In support of this determination, an evaluation of each of the three (3) standards set forth in 10CFR50.92 is provided below.
- a. The orooosed chance to the facility does not involve a sianificant increase in the probability or consecuences of an accident previously evaluated.
The proposed change will eliminate an inconsistency between Technical Specifications 3.3.5.1,3.5.2, and 3.8.2 by clarifying that the EDG auto-start and EDG trip bypass on ECCS initiation capability is not i
required during periods in which ECCS is not required to be OPERABLE. No physical changes to the facility will be made per this change. The systems, structures, and componer.ts affected by this change are considered to be accident mitigators and not accident initla' ors. The affected systems, structures, and components will continue to operate within the current design parameters. The ability of the EDGs to auto-start on a loss of offsite power or degraded voltage will remain unchanged. No new failure modes or conditions adverse to safety will be created as a result of this change. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- b. The proposed chance to the facility does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed change will eliminate an inconsistency between Technical Specifications 3.3.5.1,3.5.2, and 3.8.2 by clarifying that the EDG auto-start and EDG trip bypass on ECCS initiation capability is not required during periods in which ECCS is not required to be OPERABLE. No physical changes to the facility will be made per this change. The systems, structures and components affected are considered to be accident mitigators not accident initiators. The affected systems, structures and components will continue to operate within the current design parameters. No new failure modes or conditions adverse to safety will be created as a result of this change. The plant conditions which do not require any ECCS to be OPERABLE, (i.e., the plant in MODE 5, the spent fuel storage pool gates are removed, water level is 2 458 inches above reactor pressure vessel instrument zero, and there are no OPDRVs in progress) ensure sufficient coolant inventory to allow operator action to prevent uncovering the fuel. The ability of the EDGs to auto-start on a loss of offsite power or degraded voltage will remain unchanged. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- c. The orooosed chanae to the facility does not involve a sianificant reduction in a marain of safety.
The proposed change will eliminate an inconsistency between Technical Specifications 3.3.5.1,3.S.2, and 3.8.2 by clarifying that the EDG auto-start and EDG trip bypass on ECCS initiation capability is not required during periods in which ECCS is not required to be OPERABLE. The ECCS and EDGs capability to perform the required safety functions as described / required in the bases of the current plant 3
Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 4
Technical Specifications will be maintained. Therefore, the proposed change to the facility does not result in a significant raduction in any margin of safety.
Information Suooortina en Environmental Assessment An environmental assessment is not required for the proposed changes since the proposed changes conform to the criteria for "ections eligible for categorical exclusion" as specified in 10 CFR 51.22(c)(9).
The proposed changes will have no impact on the environment. The proposed changes do not involve a significant 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 effluents 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 this proposed change to the PBAPS, Units 2 and 3 TS and have concluded that it does not involve an unreviewed safety question, and will not endanger the health and safety of the public.
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ATTACHMEtJT 2 PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 TECHNICAL SPECIFICATIONS CHANGES List of Attached Pages Units 2 and 3 j
TS Pages 3.8-24 Bases Pages B 3.8-46 l
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