ML20141L008

License Change Application ECR 96-02324,revising Section 5.5.12 to Exclude Measured Main Steam Isolation Valves Leakage from Total Type B & C Local Leak Rate Test Results

ML20141L008
Person / Time
Site:	Peach Bottom
Issue date:	05/23/1997
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20141L010	List: ML20141L008 ML20141L011
References
NUDOCS 9706020239
Download: ML20141L008 (9)

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Ctation Support Departmtrit

• 10 CFR 50.90 l- .  :

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PECO NUCLEAR reco emernv cemoeev 965 Chesterbrook Boulevard A Unit of PECO Energy Wayne, PA 19087 5691 May 23,1997 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, Units 2 and 3 License Change Application ECR 96-02324

Dear Sir:

PECO Energy Company (PECO Energy) hereby submits License Change Application ECR 96-02324, 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 win revise Section 5.5.12 of the PBAPS, Units 2 and 3 Technical Specifications to exclude the measured Main Steam isolation Valves (MSIVs) leakage from the total Type B and C Local ' Leak Rate Test (LLRT) results.

Information supporting this request is contained in Attachment 1 to this letter, and the marked up pages showing the proposed changes to the PBAPS, Units 2 and 3 TS are contained in Attachment 2. We request that this amendment to the 1 PBAPS, Units 2 and 3 TS be approved by August 29,1997.

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

Very truly yours, hY'f n 1 G. A. Hunger, Jr.,

Director - Licensing 4C g

Enclosures:

Affidavit, Attachment 1, Attachment 2 cc: H. J. Miller, Administrator, Region I, USNRC W. L. Schmidt, USNRC Senior Resident inspector, PBAPS I R. R. Janati, Commonwealth of Pennsylvania

9706020239 970523 PDR ADOCK 0500o277 lfll l

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COMMONWEALTH OF PENNSYLVANIA:

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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 attached License Change Application ECR 96-02324, 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.

hA/I

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w Vice President Subscribed and sworn to before nu this JJM day of % 1997.

lLL 4fu kQCA V v Notary Public Notonal Seal y$r n~Twp. d e My commission Expires Dec.1 00 Momber, Pennsytvania Association of Notanes

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ATTACHMENT 1 PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 LICENSE CHANGE APPLICATION ECR 96-02324

" Main Steam isolation Valve Leakage" i

Supporting Information - 5 Pages 1 1

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Dockst Nos. 50-277 50-278 l License Nos. DPR-44 i DPR-56 1

Introduction 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 Section 5.5.12 of the PBAPS, Units 2 and 3 Technical j Specifications to exclude the measured Main Steam isolation Valves (MSIVs) leakage i from the total Type B and C Local Leak Rate Test (LLRT) results. 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 Hazards Consideration and information supporting an l Environmenta! Assessment.

Discussion and Descriotion of the Proposed Chance As discussed in the current TS Section 5.5.12, the total leakage from Type B and C  !

LLRTs is now limited to 0.6 L., where L. is equal a 0.5% volume per day Primary  !

Containment leak rate. This LCA revises Section 5.5.12 of the PBAPS, Units 2 and 3 Technical Specifications to exclude the measured MSIV leakage from the total Type B and C LLRT results.

I The benefit of this change is that exclusion of MSIV leakage from 0.6 L. provides additional operational margin when evaluating the total Type B and C LLRT leakage against TS Limits. This exclusion is justified because MSIVs have separate leakage limits, and the onsite and offsite post-LOCA doses from MSlV leakage during a design basis accident have been analyzed separately from the Primary to Secondary Containment leakage.

The original PBAPS, Units 2 and 3 TS (approved in a Safety Evaluation Report dated August 11,1972) excluded the measured MSIV leakage from the total Type B and C LLRT results. This exclusion was deleted from the TS as a part of the Improved  ;

Technical Specifications. The improved Technical Specifications were approved in a l Safety Evaluation Report (Amendment Nos. 210 and 214) on August 30,1995. i l

On September 12,1995, the U. S. Nuclear degulatory Commission (USNRC) approved j issuance of a revision to 10 CFR 50 Appendix J, " Primary Reactor Containment i Leakage Testing for Water-Cooled Power Reactors" which was subsequently published l

in the Federal Register on September 26,1995, and became effective on October 26, l 1995. The USNRC added Option B, " Performance-Based Requirements" to allow Licensees to voluntarily replace the prescriptive testing requirements of 10 CFR 50, Appendix J with testing requirements based on both overall leakage rate performance

and the performance of individual components. As discussed in the Federal Register, 4

Regulatory Guide 1.163, " Performance-Based Containment Leak-Test Program,"

I endorses the Nuclear Energy institute (NEI) 94-01, Revision 0, " Industry Guideline For

implementing Performance-Based Option of 10 CFR Part 50, Appendix J," as guidance

for developing a performance-based leakege-testing program. Additionally, if an exception is being taken from the methoda endorsed in the regulatory guide, this exception must be identified in the TS under Section 5.5.

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License Nos. DPR-44 DPR-56 L The requirements for maintaining total Type B w :_K test results are specified in the NEl 94-01. PBAPS, Units 2 and 3 is taking exvion to NEl 94-01 by excluding MSIV leakage from the combined total of Type B and C leak test results. Therefore, a change is being entered into TS Section 5.5.12 to reflect MSIV leakage exclusion.

Several Bases changes are included as a part of this request:

1. Bases Surveillance Requirement (SR) 3.6.1.1.1 is being revised to delete a discussion concerning leakage limits. Specific leakage limits no longer exist in SR >

1 3.6.1.1.1. Primary Containment leakage limits are contained in the Primary Containment Leakage Testing Program.

l 2. Bases Surveillance Requirement 3.6.1.3.14 is being clarified to state that MSIV i leakage is Secondary Containment bypass leakage, and is independent of the Primary to Secondary Containment leakage.

3. Reference 1 to Bases Section 3.6.1.1 is being revised to reflect a new reference to '

Section 14.9 of the PBAPS, Units 2 and 3 Updated Final Safety Analyses Report ,

(UFSAR). l Safety Assessment l

As stated in the PBAPS, Units 2 and 3 Updated Final Safety Analysis Report (UFSAR) i (Section 4.6, " Main Steam isolation Valves"), the safety objective of the two MSIV's, '

one on each side of the primary containment barrier in each of the main steam lines, is to close automatically to: 1) prevent damage to the fuel barrier by limiting the loss of reactor coolant in case of a major leak from the steam piping outside the Primary Containment,2) limit release of radioactive materials by closing the nuclear system process barrier in case of gross release of radioactive materials from the reactor fuel to the reactor cooling water and steam, and 3) limit release of radioactive materials by closing the Primary Containment barrier in case of a major leak from the nuclear system inside the Primary Containment. This LCA proposes to exclude the measured MSIV leakage from the total Type B and C LLRT test results. This exclusion is justified because MSIVs have separate leakage limits, and the onsite and offsite post-LOCA doses from MSIV leakage during a design basis accident have been analyzed separately from the Primary to Secondary Containment leakage. Therefore, the proposed TS will maintain the safety objective of the MSIVs.

As discussed in current TS Section 5.5.12, the total Type B and C LLRT leakage is limited to 0.6 L., where L. is equal to 0.5% Primary Containment volume per day  ;

Primary Containment leak rate. MSIVs are currently included in the 0.6 L. total.

Additionally, the MSIVs have a separate TS Surveillance Requirement of 11.5 standard cubic feet per hour (scfh) per valve. The Primary to Secondary Containment leakage rate analyzed in design basis calculations, as described in the UFSAR, is 0.635%

Primary Containment volume per day, or 1.27 times L.. This leakage is filtered by the Standby Gas Treatment System (SGTS) and then released through the stack. The additional Secondary Containment bypass leakage (through the MSIVs at their TS limit of 11.5 scfh per valve) is identified as a separate 0.145% Primary Containment volume per day containment leak rate.

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This leakage has an expected release path through the steam lines and turbine / condenser. Plateout credit is given (for elemental and particulate, but not organic iodine), and the turbine / condenser is assumed to leak at one volume percent per day. Ground level release dispersion factors are used for onsite and offsite dose analyses. Because MSIV leakage has a separate TS limit of 11.5 scfh per valve, and its impact on design basis accident doses has been analyzed separately, it is unnecessary to consider MSIV leakage to be part of the Primary to Secondary Containment leak rate which has been analyzed as 1.27 times L..

As shown in Table 1, offsite doses (Exclusion Area Boundary (EAB), Low Population Zone (LPZ)) are dominated by SGTS filtered stack releases (i.e., the Primary to Secondary Containment leakage). Offsite dose contributions from the Secondary Containment bypass component (i.e., MSIV to condenser releases) are also shown in ,

Table 1. l TABLE 1: PBAPS, Units 2 and 3 Offsite Dose Analysis for DBA LOCA )

Calculated Offsite Offsite Doses Resulting from Offsite Doses Resulting from '

Doses Secondary Containment SGTS Filtered Stack Bypass Releases Thyroid Whole Body Thyroid Whole Body (REM) ' (REM ) (REM) (REM)

EA8 Stack Releases Not Addressed Not Addressed 14.8 0.665 EAS MSIV to Condenser Releases 2.8E-06 1.3E-07 Not Addressed Not Addressed 1

LPZ Stack Releases Not Addressed Not Addressed 239 3.83 LPZ MSIV to Condenser Releases 2.4E-01 8.0E-04 Not Addressed Not Addressed

1. 10 CFR 100 limits are 300 REM Thyroid and 25 REM Whole Body.

2. Note that in every case the MSIV Leakage caused doses are much smaller than those resulting from the design basis accident calculated doses resulting from a 0.636% PC vol. per day leak rate to secondary containment.

The dominant contributor to Onsite (Control Rcom, Technical Support Center, Vital Areas, and Vital Area Access Routes) airborne activity caused doses is the Secondary Containment bypass leakage. The proposed exclusion would have no impact on these doses. Loadings on Control Room and Technical Support Center charcoal intake filters consider both Primary to Secondary Containment leakage and Secondary Containment bypass leakage. Therefore, loadings are not increased by this change.

The combined dose rates from the two release paths (i.e., Primary to Secondary Containment leakage and Secondary Containment bypass leakage) are unchanged as a result of this change, and are within the limits of 10 CFR 100, and in conformance with NUREG-0737 post-accident access requirements.

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{ information Suooortina a Findina of No Sionificant Hazards Consideration 1

i We have concluded that the proposed change to the PBAPS, Units 2 and 3 TS, which

! will revise TS 5.5.12, does not involve a Significant Hazards Consideration. In support i of this determination, an evaluation of each of the three (3) standards set forth in 10 j CFR 50.92 is provided below.

1 1 1. The orooosed TS chanaes do not involve a sionificant increase in the probability l or conseauences of an accident oreviousiv evaluated.

. Excluding the MSIV leakage from the total Type B and C LLRT results does not

involve any change in the safety function or method of operation of any plant component, system, or structure. No new accident initiators or failure modes are created as a result of this change. Therefore, this change will not result in an increase in the probability of an accident previously evaluated.

i i The MSIV leakage release pathway is of significance only for the evaluation of l the design basis LOCA as described in the PBAPS, Units 2 and 3 UFSAR. The

! doses effectively reflected in the PBAPS, Units 2 and 3 UFSAR reflect the

{ impact of a 0.635% Primary Containment volume per day Primary to Secondary

Containment leakage, plus a 0.145% Secondary Containment bypass leakage to the condenser. Since accident consequences already reflect both leakage

} release pathways, the consequences of the design basis LOCA are not

increased.

i j 2. The orooosed TS chances do not create the possibility of a new or different kind j of accident from any accident previousiv evaluated.

j The MSIV's provide the means for mitigating the radiological consequences of an accident. Revising Section 5.5.12 of the PBAPS, Units 2 and 3 TS to i exclude the measured MSIVs leakage from the total Type B and C LLRT results has no effect on accident initiators which lead to a new or different kind of accident. This change will not involve any changes to plant systems, structures,

or components which could act as new accident initiators. The design, function, i and reliability of the MSIVs are also not impacted by this change. Therefore, this

change will not create the possibility of a new or different kind of accident from l any previously evaluated.

3. The orooosed TS chanaes do not involve a sianificant reduction in a marain of safety.

No margins of safety are reduced as a result of this change to the TS. No safety limits will be changed as a result of this TS change. The MSIVs will continue to perform their intended rafety function. The combined dose rates from the two release paths (i.e., Primary to Secondary Containment leakage and Secondary Containment bypass leakage) are unchanged as a result of this change, and are within the limits of 10 CFR 100, and in conformance with NUREG-0737 post-accident access requirements.

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License Nos. DPR-44 DPR-56 Information Suooortino an Environmental Assessment An environmental assessment is not required for the proposed changes since the proposed changes conform to the criteria for " actions 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. l 1

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l ATTACHMENT 2

, PEACH BOTTOM ATOMIC POWER STATION

! UNITS 2 AND 3 i

! Docket Nos. 50-277

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License Nos. DPR-44 DPR-56 TECHNICAL SPECIFICATIONS CHANGES List of Attached Pages

! Units 2 and 3 l

TS Pages 5.0-17,18 Bases Pages 3.6-4,5,29 1

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