ML20151V785

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Application for Amend to License DPR-44,revising Tech Specs to Correct Errors & Change Nomenclature on Figures 3.5.1.M & 3.5.1.N Which Could Be Used to Perform Manual Calculations If Process Computer Inoperable
ML20151V785
Person / Time
Site: Peach Bottom Constellation icon.png
Issue date: 04/19/1988
From: Gallagher J
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML19302D529 List:
References
NUDOCS 8805030184
Download: ML20151V785 (10)


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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION l

In the Matter of Docket No. 50-277 PHILADELPHIA ELECTRIC COMPANY APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSE DPR-44 Edward G. Bauer, Jr.

Eugene J. Bradley 2301 Market Street Philadelphia, Pennsylvania 19101 Attorneys for Philadelphia Electric Company Rkbbbk4h8883h7- {}

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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket No. 50-277 PHILADELPHIA ELECTRIC COMPANY APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSE DPR-44 Philadelphia Electric Company, Licensee under Facility Operating License DPR-44 for the Peach Bottom Atomic Power Station (PBAPS) Unit No.

2, hereby requests that the Technical Specifications contained in Appendix A to the Operating License be amended by revising pages 142-1 and 142-m.

The revisions are being requested to correct errors and revise nomenclature on Figures 3.5.1.M and 3.5.1.N, which could be used to perform manual calculations if the process computer is inoperable.

Licensee proposes to correct the following errors: i

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1.

On Page1142-1, the curves of the most and least limiting Maximum Average Planar Linear Heat Generation Rate (MAPLHGR) versus planar average exposure for the LTA310 fuel type were inadvertently used for the graph of the BD319A fuel type.

However, the discrete MAPLHGR values printed on this graph are correct for the BD319A fuel type.

Thus, the values printed on the graph are correct; only the shape of the curves is incorrect.

2.

On Page 142-m, the curves of the most and least limiting MAPLHGR versus planar average exposure for the LTA310 fuel type were also inadvertently used for the graph of the BD321A fuel type.

However, the discrete MAPLHGR values printed on this graph are correct for the BD321A fuel type, with the following exception.

The least limiting MAPLGHR value at 20,000 MWD /T planar average exposure was incorrectly printed as 12.17.

The correct value is 12.18 as specified in General Electric Company Document NEDE-24081-P-1 which was submitted to the Commission by letter dated March 24, 1987 to support the Unit 2 Reload 7 License Amendment Application (subsequently approved as Amendment No. 123.)

With this one exception, the values printed on the graph are correct; only the shape of the curves is incorrect.

I In addition to correcting the aforementioned errors, Licensee j

proposes to revise the nomenclature that identifies the MAPLHGR curves on pages 142-1 and 142-m from "MOST LIMITING MAPLHGR" and "LEAST j L

LIMITING MAPLHGR" to "Most Limiting Lattice" and "Least Limiting Lattice", respectively, to be consistent with the text of Technical Specification 3.5.I.

Also, the lagibility of these figures was greatly improved by the use of computer graphics.

The graphs on pages 142-1 and 142-m are based on information provided in two General Electric Company documenta that were submitted to the NRC to support the Unit 2 Reload 7 Amendment Application of January 9, 1987, which was subsequently approved by the NRC and issued as Amendment No. 123 (dated September 11, 1987).

Lattice specific MAPLHGR values versus planar average exposure for the BD319A, BD321A and LTA310 fuel types were set forth in General Electric Company document NEDE-24081-P-1, Revision 1, "Loss-of-Coolant Accident Analysis for Peach Bottom Atomic Power Station Unit 2, Supplement 1",

dated March 1987.

The most and least limiting lattice MAPLHGR values versus planar average exposure for these same fuel types have been set forth in Errata and Addenda Sheet No, 11, dated November 1986, of General Electric Company Document NEDO-24031, "LOCA Analysis for Peach Bottom Atomic Power Station Unit 2".

These two documents each contain one typographical error, as described below:

1.

On Page A-6 of NEDE-24081-P-1, Revision 1, the final average planar exposure point for lattice 4 of the LTA310 fuel type is incorrectly printed as 39.8 GWd/St.

The correct value is 50 GWd/St, as printed in Errata and Addenda Sheet No. 11 of NEDO-24081 in Table 4-3m.

The correct value was incorporated into the Technical Specifications on page 142-n by Amendment No. 123.

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2.

On Page 4-14 of Errata'and Addenda Sheet No. 11, the least limiting MAPLHGR value for the BD321A~ fuel type at an average-planar exposure of 20.0 GWd/St is incorrectly printed as 12.17.

(This accounts for the error on page 142-m of the Technical Specifications discussed previously herein).

The correct value is 12.18, as printed in NEDE-24081-P-1, Revision 1 on page A-4.

These two typographical errors have been corrected in General Electric Company Document NEDE-24081-P-2, Revision 2, "Loss-of-Coolant Accident Analysis for Peach Bottom Atomic Power Station Unit 2, Supplement 1",

dated January 1988 and in Errata and Addenda Sheet No.

12, dated January 1988, of General Electric Company Document NEDO-24081, "LOCA Analysis for Peach Bottom Atomic Power Station Unit 2",

which are filed herewith and incorporated herein by reference.

General Electric Company has advised the Licensee that Document UEDE-24081-P-2, Revision 2 contains information which it considers confidential and proprietary, and wishes the document to be withheld from public disclosure.

For the same reasons stated in the affidavit of Ricardo Artigas of General Electric Company dated March 17, 1987 which was submitted to the Commission with the Unit 2 Reload 7 Amendment Application for Revision 1 of this document, the Licensee hereby requests that this document be withheld from public disclosure j

in accordance with the provisions of 10 CFR Section 2.790.

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SAFETY ASSESSMENT:

During normal operation, the process computer contains, and acts on, the full details of lattice specific MAPLHGR limits.

The MAPLHGR values presented on pages 142-1, 142-m and 142-n are primarily for information only.

In the event that hand calculations of MAPLHGR are required (process computer inoperative), the most limiting values as shown on Pages 142-1 and 142-m.are used for all limits.

The correct most limiting values were printed on both graphs.

The one incorrect printed value is on a least limiting curve which would not be used to manually determine operating limits.

If an operator used the most limiting curve to manually determine MAPLHGRs, and chose values from the ordinate of the graph rather than the printed values, incorrect limits would have been used.

However, those limits would have been even more restrictive than the correct limits.

Based on the above, these errors posed no safety significance.

Therefore, correction of these errors is purely administrative in nature.

Furthermore, Unit 2 has not operated in accordance with these revised Technical Specifications (Amendment 123) because Cycle 8 has not begun.

SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION:

i The NRC has provided guidance concerning the application of the standards for determining whether license amendments involve no significant hazards considerations by providing examples (51FR7751).

An example (i) of a change that involves no significant hazards consideration is "a purely administrative change to technical '

specifications: for example, a change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature."

These proposed changes fit this example.

They are purely administrative changes because they correct errors and change nomenclature for consistency.

It has been determined that the changes requested herein do not involve a significant hazards considerations for the following reasons:

1)

The MAPLHGR values are a composite of results obtained from both thermal-mechanical and Loss-of-Coolant Accident (LOCA) considerations.

During normal operation, the process computer contains, e.oj acts on, the approved lattice specific MAPLHGR lialts.

Further, the correct and approved most limiting lattice MAPLHGR limits were printed on the graphs.

Since this change corrects the improperly drawn curves and corrects one least limiting MAPLHGR value, it does not involve a significant increase in the probability or consequences of an accident previously evaluated.

11)

These changes correct errors and revise nomenclature.

Because these changes do not affect operations, the changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

111) Because the approved MAPLHGR limits are not being t

changed and only administrative changes are being proposed, the changes do not involve a significant reduction'in a margin of safety.

l ENVIRONMENTAL-IMPACT:

An environmental impact assessment is not required for the changes requested by this Application because the requested changes conform to the criteria for "actions eligible for categorical exclusion" as specified in 10 CFR 51.22(c)(9).

The requested changes are purely administrative in nature and will

- have no inpact on the environment.

The Application involves no significant hazards consideration as demonstrated in the preceding section.

The Application involves no significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and there is no significant increase in individual or cumulative occupational radiation exposure.

CONCLUSION:

I The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes to the Technical Specifications and have concluded that they do not involve unreviewed safety questions or involve Significant Hazards Considerations, and will not endanger the health and safety of the public.

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A Respectfully submitted, PHILADELPHIA ELECTRIC COMPANY Y Ad b.W v

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COMMOINEALTH OF PENNSYLVANIA cs.

COUNTY OF PHILADELPHIA J. W. Gallagher, being first duly sworn, deposes and sayst That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing Application for Amendment of Facility Operating License DPR-44 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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Subscribed and sworn to before me this 6 day I

of April, 1988 b%lJ ;-}1a, / L' i

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