ML20153C788
| ML20153C788 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/18/1988 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC |
| Shared Package | |
| ML20153C772 | List: |
| References | |
| NUDOCS 8809010294 | |
| Download: ML20153C788 (34) | |
Text
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i ga' BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION i
In the Matter of :
- Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANY : 50-278 APPLICAT'lON FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 & DPR-56 P
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Eugene J. Bradley 2301 Market Street Philadelphia, Pennsylvania 19101 -
Attorney for Philadelphia Electric Company l l
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8009010294 080826 PDR ADOCK 05000277 P PNV o
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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 I
Philadelphia Electric Company, Licensee under Facility
, Operating Licenses DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS) Units 2 and 3, respectively, hereby requests that the Technical Specifications contained in Appendix A of the Operating
, Licenses be amended by revising sections c.s indicated by a vertical bar in the margins of the attached pages 127, 128, 132, 132a, and 136, i
' l and by adding of pages 128a and 128b to accommodate a redistribution l l
of material. These changes are requested to clearly identify the components which comprise the Containment Cooling System. In l
addition, proposed changes (2), (7), (8) (14) and (16'i are requested I in response to unresolved item 278/85-07-01 (combined NRC Inspection Reports 50-277/85-07; 50-278/85-07), and to expand the scope of the PBAPS Technical Specifications to include the torus cooling, torus I
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spray and drywell spray modes of the Residual ~ Heat Removal System (RHRS) as components of the Containment Cooling System. Proposed change (18) is in response to unresolved item 277/86-16-02 (NRC Inspection Report 277/86-16). and proposes to reduce testing of Emergency. Core Cooling Sys;em (E7CS) pumps.
Licensee propor.es to implement the changes proposed herein within 90 days of issuance of the License Amendment to accommodate revisions to station proctdures.
System Discussion - Containment Cooling The PBAPS Updated Final Safety Analysis Report (UPSAR) does not address the Containment Cooling System as a single, independent system. The UFSAR describes containment cooling as a function of the RHRS in concert with the High Pressure Service Water (HPSW)
System. This Application proposes that the Technical Specifications address the systems which perform the containment cooling function: torus cooling, torus spray and drywell spray modes of the RHRS, and the HPSW System as an integrated system.
Section 4.8.6.2 of the UFSAR describes the torus cooling mode of the RHRS as "an integral part of the RHRS and is placed in [
] operation to limit the temperature of the water in the suppression pool so that, immediately after the design bssis LOCA has occurred, pool temperature does not exceed 170 degrees F."
"With the RHRS in the containment cooling mode storus cooling) of operation, the RHRS main system pumps are aligned to pump water l
o from the suppression pool through the RHRS heat exchangers, where cooling takes place by transferring heat to the high pressure.
service water (system). The flow returns to the suppression pool via the full flow test line."
The RHRS may also be operated in the torus spray and drywell spray modes. Section 4.8.6.2 of the UFSAR states that in these modes, water is pumped through the RHRS heat exchangers, diverted to spray headers above suppression pool is.d in the drywell. The spray headers in the drywell condense any steam that'may exist in the drywell, thereby lowering containment pressure. The spray collects in the bottom of the drywell until the water level rises to the level of the pressure suppression vent lines, where it overflows and drains back to the suppression pool.
The last subsystem which contributes to containment cooling is the HPSW System. As described in Section 10.7 of the UFSAR, "the safety object 3/e of the HPSW System is to provide a reliable '
supply of cooling water for RHR under post-accident conditions."
To fulfill this objective, one of the design bases of the HPSW system is the "capacity and redundancy to supply cooling water to the RHR under post-accident conditions."
"Each high pressure service water system consists of four 4,500-gpm pumps installed in parallel in the pump structure. Normal water supply to the suction of the pumps is from Conowingo Pond.
When the HPSW System is operated in conjunction with the emergency heat sink, the auction is from the emergency cooling tower basin.
The pump discharge is manifolded and provided with a normally l
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closed, motor-operated gate valve separating the four pumps into groups of two. Two parallel headers run from the pump structure to the reactor building. Each header delivers the discharge from two pumps to two RHRs heat exchangers also in parallel."'
i "Each pump is sized to accommodate the design heat removal i capacity of one RHRS heat exchanger. They have adequate head: (1) !
to maintain the high pressure service water system cooling water at a higher pressure than the RHRS, thus precluding leakage of radioactivity, and (2) to permit operation in conjunction with the emergency heat sink. Further, the-pumps have both a normal and a standby power supply. In the event of the loss of off-sjte power, the pumps are supplied from the diesel-generators on a selective basis."
"Sufficient redundancy is provided in the number of pumps and power supplies, and in the piping strangement, so that no single i
system component failure can prevent the system from supplying )
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cooling water to accommodate the normal shutdown mode and the containment cooling mode. Therefore, core decay heat removal during the shutdown periods, or containment cooling during the post-accident condition, can be maintained."
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Discussion - Change Request (1)
Chang? Request (1) is a change in-nomenclature which will refer to containment cooling as a system. It is requested that throughout Limiting Conditions frr Operation 3.5.B and 3.5.F, Surveillance Requirements 4.5.8 and their Bases, the term "Containment Cooling Subsystem" be replaced with the term "Containment Cooling System." ,
Discussion - Change Request (2) i Change Request (2) is a clarifying change which identifies the components that comprise the Containment Cooling System. It is requested that the headings for Limiting Conditions for Operation ,
3.5.B and Surveillance Requirement 4.5.B reflect that the Containment Cooling System consists of not only the HPSW System, but also the torus cooling, drywell spray, and torus spray modes '
of the RHRS. It is also requested that the Bastis be amended to l
- reflect this change.
Discussion - Change Request (3)
Change Request (3) proposes to include reference to the proposed i Limiting Conditions for Operation 3.5.B.5 and 3.5.B.6 (Change Request (15)) in Limiting Condition for Operation 3.5.B.1.
Discussion - Change Request (4)
Change Request (4) is a clarifying change which accommodates Change Requests (1) and (2). It is requested that Surveillance l
l Requirement 4.5.B.1 be amended to state, "Containment Cooling i L l
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4 System components shall be tested as follows:" The proposed wording clearly introduces the surveillance requirements which follow.
Discussion - Change Request (5)
Change Request (5) is a format change which redesignates Survoillance Requirement 4.5.B.l.d as'4.5.B.l.g in order.to accommodate the addition of the proposed Surveillance Requirements of Change Request (14).
Discussion - Change Request (6)
Change Request (6) is a clarifying change which applies to Surveillance Requirements 4.5.B.l.a, b and c. Change Request (6) assures consistency with Change Request (2) which clearly defines the Containment Cooling System; and Change Request (14) which proposes to add Surveillance Requirements 4.5.B.1.d, o and f. I Since the Surveillance Requirements 4.5.B.l.a, b, and c apply only to the HPSW system, Change Request (6) proposes that they be so revised.
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Discussion - Change Request (7) !
Change Request (7) is a clarifying change which defines the requirements for continued reactor operation with two inoperable HPSW pumps. Change Request (7) would be required as a result of Change Request (2) which would clarify the increase in scope of these Specificatioast and is needed because of Change Request (14), which proposes to add Surveillance Requirements 4.5.B.l.d, e and f. Since the existing Limiting. Condition for Operation 3.5.B.2 and Surveillance Requirement 4.5.B.2 apply only to the HPSW pumps, Change Request (7) proposes that they be so revised.
Discussion - Change Request (8)
Change Request (8) is a clarifying change, which defines the requirements for continued reactor operation with three inoperable HPSW pumps. Change Request (8) would be required as a result of ,
Change Request (2) which would clarify the increase in scope of these Specifications; and is necessary because of Change Request f
(14) which proposes to add Surveillance Requirements 4.5.B.l.d, e and f. Since the existing Limiting Conditions for Operation 3.5.B.3 and existing Surveillance Requirements 4.5.B.3 apply only I
to the HPSW pumps, Change Request (8) proposes that they be so 1
revised.
Discussion - Change Request (9)
Change Request (9) is a format change which applies to Limiting Conditions for Operation 3.5.B.3 and Surveillance Requirements 4.5.B.3. To provide consistency in the presentation of information in the Technical Specif8 cations, Change Request (9) proposes to spell the number "thre9".
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. Discussion - Change Request (10) l Change Request (10) is a format change, which redesignates Action Statement 3.5.B.5 as 3.5.B.7, in order to acccmmodate and include the addition of the proposed Limiting Conditions for Operation discussed in Change Request (16).
Discussion - Change Request (11)
Change Request (11) proposes to correct a orevious administrative error. It is requested that the column healing "3.5.F.3 (Cont'd)"
at che top of page 132a be changed to "3.5.F.4 (Cont'd)" since it is the existing Limiting Conditions for Operation 3.5.F.4 which is continued from page 132.
Discussion - Change Request (12)
Change Request (12) proposes to correct another previous administrative error. As a reuult of an Amendment issued March 26, 1980, Surveillance Requirement 4.5.F.2 was deleted from the PBAPS Technical Specifications; however, the column heading "4.5.F.2 (Cont'd)" remains on page 132a. It is requested that i this column heading be deleted.
Discussion - Change Request (13) I I
l Change Request (13) is the final administrative request. As a result of a modification which permanently removed the rer.ctor recirculation pumps' discharge valves' bypass valves from the I
recirculation system, it is requested that Limiting Conditions for ;
Operation 3.5.A.6 and Surveillance Requirement 4.5.A.6 be revised j i
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. . to remove reference to these bypass valves. It is also requested that the note at the bottom of page 127 referring to these bypass valves be removed from the Technical Specifications. These request are proposed for the PBAPS Unit 3 Technical Specifications only, because the Unit 2 Technical Specifications have been similarly revised by Amendment number 47, issued on October 10, 1978. Upon approval of Char.ge Request-(13), page 127 will be identical for both Units 2 and 3.
Safety Significance - Change Requests (1) thru (13)
Section 14 of the UFSAR contains analyses of four design basis accidents: the Control Rod Drop Accident, the Loss of Coolant Accident, the Refueling Accident and the Main Steam Line Break.
These Change Requests do not impact the accident precursors, initial conditions, assumptions, sequences-of-events or results of these accidents as described in the UFSAR.
Change Requests (1) thru (13) enhance the content of the Specifications by removing ambiguity and more accurately specifying their requirements. These Change Requests also permit the Specifications to more accurately reflect plant equipment and i
design. It is, therefore, concluded that these Change Requests will improve the Technical Specifications, without adversely impacting plant safety.
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Significant Hazards Consideration - Change Requests (1) thru (13)
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 (51 FR 7751). One of the examples of actions involving.
no significant hazards consideration is an' administrative change to the Technical Specifications. Change Requests (1) thru (13) of this submittal conform to this example. Operation of the plant with the proposed Limiting Conditions for Operation and Surveillance Requirements will not:
(1) Involve a significant increase in the probability or consequences of an accident previously evaluated.
Four design basis accidents described in Section 14 of the UFSAR ares the Control Rod Drop Accident, the Loss of Coolant Accident, the Refueling Accident and the Main Steam Line Break. The administrative nature of these Change Requests '
does not impact the precursors, initial conditions, assumptions, or sequences-of-events described for these accidents. It is, therefore, concluded that the probability or consequences of an accident previously evaluated will not be increased by the implementation of these Change Requests.
OR (2) Create the possibility of a new or different kind of accident from any accident previously evaluated.
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. These Change Requests do not alter the content or intent of the Specifications to which they apply. These Change Requests clarify the intent of the Specifications and provide additional assurance that the Specifications, accurately ar.d completely describe the systems and components to which they apply. Implementation of these administrative Change Requests will not 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.
These Change Requests improve the clarity of the Specifications, and correct previous errors. These Change Requests will not reduce a margin of safety associated with any component or system described by the Technical Specifications or UFSAR.
Discussion - Change Request (14)
Change Request (14) proposes to expand Surveillance Requirement 4.5.B.1, which applies to the Containment Cooling System. As a result of the clarifications made by Change Request (2), it is requested that Surveillance Requirement 4.5.B.1 be expanded to require monthly testing of the torus cooling motor operated valves (4.5.B.1.d), drywell spray motor operated valves (4.5.B.l.e), and torus spray motor operated valves (4.5.B.1.f).
. Safety Significance - Change Request (14)
The operability of the. equipment cited in Change Request (14) is required for Containment Cooling System operability, and is ,
currently part of the surveillance test program at PBAPS. The inclusion of this equipment into Surveillance Requirement 4.5.B.1 would increase the Containment Cooling System reliability, as required by the current Technical Specifications.
Section 14 of the UFSAR contains analyses of four design basis accidents: the Control Rod Drop Accident, the Loss of Coolant
-Accident, the Refueling Accident, and the Main Steam Line Break.
Amending the Technical Specifications to include Surveillance Requirements for the Containment Cooling System components would assure operability of those components. Change Request (14) will not change the test methods or procedures currently implemented and will not affect the accident precursors, initial conditions, ;
assumptions, sequences-of-events or results of these accidents as described in the UFSAR. It is, therefore, concluded that implementation of Change Request (14) will not adversely impact plant safety.
Significant Hazards Consideration - Change Request (14)
A second example of amendments involving no significant hazarde consideration presented in 51 FR 7751 is a change that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications. Change Request (14) of !
this submittal conforms to this example. Operation of the plant i
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under the proposed Surveillance Requirements would nott I
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(1) Involve a significant increase in the probability or consequences of an accident previously evaluated.
Assurance of the operability of the Containment Cooling System components is necessary to ensure plant safety.
Although these components'are part of the current surveillance test program, including Surveillance Requirements for all of these components in the Technical Specifications will provide additional assurance of their operability.
Four design basis accidents described in Section 14 of the UFSAR are: the Control Rod Drop Accident, the Loss of Coolant :
Accident, the Refueling Accident and the Main Steam Line j Break. Amending the Technical Specifications to include complete Surveillance Requirements for components of the i Containment Cooling System will not affect the accident precursors, initial conditions, assumptions or sequences-of- i events as described in the UFSAR. It is concluded that these additional testing and operability requirements involve neither an increase in the consequences nor the probability of an accident previously evaluated. !
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(2) Create the possibility of a new or different kind of acci, dent !
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Change Request (14) reflects the expansion of the Containment Cooling System ac defined in Change Request (2). The a
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. additional assurance of the operability of each of these components enhances safety. Since additional testing and operability requirements are not new accident precut-sors, it is concluded that the possibility of a new or different kind of accident from any accident previously evaluated is not created.
OR (3) Involve a significant reduction in a margin of safety.
The proposed testing and operability requirements do not i involve a significant reductio) in a margin of safety, since they increase assurance of the availability of systems which will mitigate the consequences of an accident, and therefore enhance the safety margin.
Discussion - Change Request (15)
Change Request (15) proposes to maintain the intent of the current Surveillance Requirement 4.5.B.4 and accommodate the clarification of the Containment Cooling System proposed in Change Request (2).
The existing Surveillance Requirements apply and refer to "containment cooling subsystem loops" which are defined by the -
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a existing Bases as one RHR and one HPSW pump. The loop operability, by definition also requires an operable diesel generator to provide power to these pumps. The existing Surveillance Requirement 4.5.B.4 requires testing of the remaining l operable containment cooling subsystem loop and its associated diesel generator when three such loops are inoperable. In concett i
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. with Change Request (16) and (17) which redefine Limiting Conditions for Operation 3.5.B.4 and Surveillance Requirement 4.5.B.4 for the RHR modes, Change Request.(15) proposes to revise Surveillance Requirements 4.5.B.3 to require immediate testing of the remaining operable HPSW pump and its associated' diesel generator when three HPSW pumps are inoperable.
Safety Significance - Change Request (15)
Change Request (15) imposes a diesel generator test provision to l Surveillance Requirement 4.5.B.3 tc accommodate Change Request (17) and the new definition of the Containment Cooling System and maintain the intent of the existing Surveillance Requirement 4.5.B.4. By requiring the immediate testing of.the diesel t
generator with the remaining operable HPSW pump when three HPSW-d pumps are inoperable assures that the remaining HPSW pump can be relied upon to perform its safety function. Change Request (15) will not change the test methods or procedures which are currently I implemented.
, Section 14 of the UPSAR contains analyses of four design basis accidents: the Control Rod Drop Accident, the Loss of Coolant
] Accident, the Refueling Accident and the Main Steam Line Break.
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- Implementation of Change Request (15) will not adversely impact I the accident precursors, initial conditions, assumptions, sequences-of-events or results of these accidents as described in the UFSAR. It is, therefore, concluded that implementation of Change Request (15) will not adversely impact plant safety.
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. Significant Hazards Consideration - Change Request (15)
Change Request (15) also conforms to the second example of an amendment involving no significant hazards consideration, a change that constitutes an additional limitation, restriction or control not presently included in the Technical Specifications. Operation of the plant under the proposed Surveillance Requirement 4.5.B.3 would t:
i (1) Involve a significant increase in the probability or t
consequences of an accident previously evaluated.
i The testing of the diesel generator associated with the j remaining operable HPSW pump is both conservative and consistent with the intent of the current Surveillance Requirement 4.5.B.4.
Four design basis accidents described in Section 14 of the UFSAR are: the Control Rod Drop Accident, the Loss of Coolant Accident, the Refueling Accident and the Main Steam Line i l
Break. Amending Surveillance Requirement 4.5.B.3 to include immediate testing of the associated diesel generator will not impact the accident precursors, initial conditions, )
assumptions or sequences-of-events as described in the UPSAR.
It is concluded that this additional testing requirement involve neither an increase in the consequences nor the probability of an accident previously evaluated.
(2) Create the possibility of a new or different kind of accident from any accident previously evaluated.
Change Request (15) reflects-the clarified definition of the Containment Cooling System from Change Request (2). It also maintains the intent of the current Surveillance Requirement-4.5.B.4. Since the diesel generator. testing methods are not changed and an additional testing requirement is not a new accident precursor, it is concluded that the possibility of a r.ew or different kind of accident is not created.
OR (3) Involve a significant reduction in a margin of safety.
The proposed testing requirement does not involve a significant reduction in a margin of safety since it assures and demonstrates the availability of systems which will mitigate the consequences of an accident.
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. Discussion - Change Request (16) ;
J Change Request (16) proposes changing Limiting Conditions of Operation 3.5.B.4, and adding Limiting Conditions of Operation 3.5.B.5 and 3.5.B.6 to address the operability requirements of the torus cooling, drywell spray and the torus spray modes of the RHRS, respectively, as they comprise the Containment Cooling System. The existing Limiting Conditions for Operation 3.5.B.5 would become 3.5.B.7, as discussed in Change Request (10) of this Application. These changes are necessary to establish complete operability requirements for the Containment Cooling Systems, thereby satisfying the intent of the current Limiting conditions for Operation while improving the clarity of the requirements.
Safety Significance - Change Request (16)
Change Requests (16) expands the scope of these Technical Specifications to more clearly define the operational requirements of the Containment Cooling System, thereby addressing the aforementioned unresolved item (combined NRC Inspection Reports 50-277/85-07; 50-278/85-07). The incorporation of these Limiting Conditions for Operation into the Technical Specifications assures the availability of additional systems, which can mitigate the I
consequences of reactor transients and accidents. The proposed Limiting conditions for Operation are operationally more conservative and rest'tictive than the existing requirements. )
I Section 14 of the UFSAR contains analyses of four design basis accidents: the Control Rod Drop Accident, the Loss of Coolant Accident, the Refueling Accident and the Main Steam Line Break.
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. The inclusion of Limiting Conditions for Operation for all containment Cooling System components will not affect the accident precursors, initial conditions, assumptions, sequences-of-events or results of these accidents, as described in the UFSAR. It has been concluded that the nature of Change Request (16) does not l affect plant parameters, but enhances the Specifications, and therefore, does not degrade plant safety.
Significant Hazards Consideration - Change Request (16)
Change Request (16) also conforms to the second example of amendments involving no significant hazards consideration: a change that constitutes an additional limitation, restriction, or ;
control not presently included in the Technical Specifications.
Change Request (16) proposes Limiting Conditions for Operation to the Technical Specifications concerning torus cooling, drywell spray, and torus spray. Operation of the plant under the proposed Limiting Conditions for Operation would not:
(1) Involve a significant increase in the probability or consequences of an accident previously evaluated.
l Four design basis accidents described in Section 14 of the UFSAR are the: Control Rod Drop Accident, the Loss of Coolant Accident, the Refueling Accident and the Main Steam Line Break. Adding Limiting Conditions for Operation to clearly address all Containment Cooling System functions does not impact the precursors, initial conditions, assumptions, or sequences-of-events of these accidents. It is, therefore, I
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. concluded that these additional operability requirements ;
impact neither the consequences nor the probability of an accident.
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(2) Create the possibility of a new or different kind of accident from any accident previously evaluated.
Change Request (16) does not alter the intent of the 4 ,
Technical Specifications, rather it assures compliance with ;
the intent. Adding Limiting Conditions for Operation for all ;
components of the Containment Cooling System will help assure -
safe plant operation. Additional, more conservative '
operabili&.y requirements are not a potential new accident '
precursor. It is, therefore, concluded that implementation l of Change Request (16) will not create the possibility of a ;
new or different kind of accident from any accident previously evaluated. ,
OR (3) Involve a significant reduction in margin of safety, i
The proposed operability requirements assure the availability of systems which will mitigate the consequences of an ;
] accident and therefore enhance the safety margin. )
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. Discussion - Change Request (17) i Change Request (17) proposes changing Surveillance Requirement 4.5.B.4 and adding Surveillance Requirements 4.5.B.5 and 4.5.B.6 to address the torus cooling, drywell spray and torus spray modes of the RHRS, respectively. These changes, in concert with Change Request (15), continue to satisfy the original intent of Sarveillance Requirement 4.5.B.4 while demonstrating the '
availability of the redundant RHRS loop when one RHRS loop is inoperable.
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- Safety Significance - Change Request (17)
Change Request (17) expands the scope of these Surveillance i Requirements to assure that the operability requirements proposed in Change Request (16) (Limiting Conditions for Operation 3.5.B.4, 3.5.B.5 and 3.5.B.6) are met. The incorporation of these Sarveillance Requirements demonstrates the availability of these systems which can mitigate the consequences of reactor transients {
or accidents. i 1
The frequency of the current Surveillance Requirement is i
"immediately and daily thereafter." The proposed frequencies are s
"immediately", with the proposed corresponding Limiting Conditions for Operation of one week. These are consistent with the 1
frequencies of Surveillance Requirements 4.5.B.2 and 4.5.B.3, i i
which are "immediately and weekly thereafter.". The apparent i
decrease in surveillance frequencies is appropriate because the j proposed Limiting Conditions for Operation which correspond to J
these Surveillance Requirements are more restrictive. Since the 2
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. current daily testing requirement applies when three of four a t subsystem loops are inoperable, and the proposed requirement j
applies to one of two loops, the Unit would be in a much less i degraded state when the proposed Surveillance Requirement.s are invoked. Implementation of proposed Surveillance Requirements !
will meet the original intent of the current Requirement, i i
1 increasing the restrictions which would be imposed, thereby I improving safety.
] Section 14 of the UFSAR containe analyses of four design basis [
accidents: the Control Rod Drop Accident, the Loss c' Coolant Accident, the Refueling Accident and the Main Steam Lirie Break.
The inclusion of these surveillance requirements will not impact the accident precursors, initial condition, assumptions, f j sequences-of-events or results of these accidents as described in the UFSAR. It has been concluded that the nature of Change
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t Request (17) in concert with Change Request (15) fulfills the i intent of the current Surveillance Requirement 4.5.B.4 and does !
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4 not adversely impact plant safety.
! Significent Hazards Consideration - Change Request (17) !
! i Change Request (17) also conforms to the cecond exemple of I t
amendments involving no significant hazards considerations a- !
i change that constitutes an additional limitation, restriction or [
- control not presently included in the Technical Specifications. t i
Change Request (17) proposes Surveillance Requirements for the l
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toras ccoling, drywell spray and torus spray modes of the RHRS.
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4 Operation of the plant under the proposed Surveillance Requir ements would nots (1) Involve significant increase in the probability or consequences _of an accident previously evaluated.
Four design basis accidents described in Section 14 of the UFSAR are the: Control Rod Drop Accident, the Loss of Coolant Accident, the Refueling Accident, and the Main Steam Line Break. Adding Surveillance Requirements to address all of the Containment Cooling System functions will not affect the accident precursors, initial conditions, assumptions or sequences-of-events as described in the UFSAR. It is concluded that these additional testing requirements involve neither an increase in the consequences nor the probability of an accident previously evaluated, i
OR l (2) Creatt the possibility of a new or different kind of accident from any accident previously evaluated.
Change Request (17) reflects the expanded operabilacy requirements proposed by Change Request (16). The availability or the redundant loop and the associated diesel generators must be demonstrated in order to ensure safety when the associated proposed Limiting Condition for Operation is met. Since these proposed Surveillance Requirements are consistent with the intent of the current Surveillance
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. Requirement 4.5.B.4 and additional testing requirements are l not new accident precursors, it is concluded that the possibility of a new or different kind of accident is not created.
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(3) Involve a significant reduction of a new margin of safety. ;
! The proposed testing requirements do not involve a 4
1 significant c?uction in a margin of safety, since they '
l r j demonstrate .e availability of systems which will mitigate !
L the consequences of an accident. !
a j Discussion - Chance Request (18) l Change Request (18) proposes to relax the operating restrictions when one diesel generator is inoperable. Currently, Limiting j Condition for Operation 3.5.P.1 states that when one diesel generator is inoperable, continued operation is permitted provided I
- all low pressure core and containment cooling systems are operable. Change Request (18) proposes that operation be {
permitted if the low pressure core and containment cooling systems '
which are powered by the remaining diesel generators are operable.
This requirement is appropriate since the systems which are i powered by the inoperable diesel generator would not be available !
l to mitigate the consequences of a design basis accident since they would no longer have a reliable emergency power supply.
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. Implementation of Change Request (18) would increase operational flexibility without impacting safety.
Safety Significance - Change Request (18)
Relaxing Limiting Conditions for Operation 3.5.P.1 as described will not adversely impact safety. Since the inoperable diesel generator effectively renders one train of the Low Pressure Core and Containment Cooling Systems unavailable te mitigate the consequences of an accident, mechanical operability of the train becomes a moot issue. Requiring operability of only the low pressure core and containment cooling system powered by the remaining diesel generators provides operational flexibility without degrading a margin of safety.
Section 14 of the UPSAR contains analyses of our design basis accidents: the Control Rod Drop Accident, the Loss of Coolant Accident, the Refueling Accident and the Main Steam Line Break.
Imp 4ementation of Change Request (18) will not impact the precursors, initial conditions, assumptions, sequences-of-events or results of these accidents as described in the UFSAR. It is, therefore, concluded that implementation of Change Request (18) will not adversely impact plant safoty, i Significant Hazards Consideration - Change Request (18)
Cha ge Request (lb) conforms to the third example of amendments involving no significant hazards consideration a change which may result in some reduction in a safety margin, but where the results of the change are clearly within all acceptable criteria. The
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. flexibility-gained through this Change. Request Will not degrade '
i safety. As discussed, operability of a system train which is l powered by an inoperable power supply is a moot point. Operation I of the plant under the proposed Limiting Conditions for Operation (
will not f
r (1) Involve a significant increase in the probability or consequences of an accident prev 3ously evaluated i
i Four design basis accidents described in Section 14 of the !
UFSAR are the: Control Rod Drop Accident, the Loss of Coolant ;
t Accident, the Refueling Accident and the Main Steam Line
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Break. Since no credit can be taken for operability of the [
}
j Low Pressure Core and Containment Cooling Systems which are powered by the inoperable diesel generator, the precursors, initial conditions, assumptions or sequences-of-events of )
these accidents, as described in the UFSAR are not impacted. f It is, therefore, concluded that the probability or consequences of an accident previously evaluated are not {
increased.
(
)
[ (2) Create the possibility of a new or different kind of accident j
from any accident previously evaluated. i i
] Removing the mechanical operability requirement of systems which do not have a reliable electrical source, as the ,
associated diesel generator is inoperable, will not introduce l
j i 1
0 .
, potential new accident precursors, since no credit can be l
taken for their operability.
OR (3) Involve a significant reduction in a margin of safety, a The inoperable diesel generator renders the power supply to I j the Low Pressure Core and Containment Cooling System loops a ,
unreliable. Thus, these loops are effectively rendered I
inoperable. It is, therefore, concluded that removing this meet.anical operability requirement does not decrease a margin ,
of safety.
Discussion - Change Request (19) t i
I Change Request (19) proposes to delete testing requirements for !
i s
the Low Pressure Core and Containment Ccoling Systems when one '
diesel generator is inoperable.
Change Request (19) is consistent with the Standard Technical i
Specifications (STS), NUREG-0123, Revision 3; as the STS do not i i
r' squire accelerated testing of the Low Pressure Core and !
Containment Cooling Systems when a diesel generator is inoperable, i
Further, implementation of Change Requese (19) will reduce ;
unnecessary system startup stresses, as well as reduce system unavailability resulting from its being out-of-service during 0
testing, thereby addressing the aforementioned unresolved item (NRC Inspection Report 277/86-16).
o
, It is requested.that the requirement to test the Low Pressure Core I and Containment Cooling Systems when one diesel generator is inoperable be deleted from the current Surveillance Requirement 4.5.F.1. t Safety Significance - Change Request (19)
A review of surveillance test records indjeates that approximately l 1490 surveillance tests have been performed on the RHR, Core ,
- Spray, and HPSW systems over the last 10 years (1/1/78-1/1/88) for the purpose of verifying proper operation of these systems when 1
- redundant components or subsystems were inoperable. These records
- indicate that only 10 of these 1490 surveillance tests' results j were unsatisfactory. This history o
- ! these special tests demonstrate the reliability of the AHR, Cere Spray, and HPSW Systems at PDAPS which is assured by the monthly surveillance testing and other programs, thus justifying the request for l eliminating accelerated testing of the Low Pressure Core and Containment Cooling Systems when a diesel generator is inoperable.
Elimination of the accelerated testing provision should be made in !
] concert with Change Request (14) regarding the testing of I additional Containment Cooling System components, since in the absence of Change Request (19), the accelerated testing j
requirement would significantly expand the scope of testing.
l Further, inoperability of a diesel generator does not impact the operability of the Low Pressure Core and Containment Cooling l Systems supplied by the operable dieuel generator. Operability of these systems would be assured in other sections of the Technical Specifications, namely proposed Limiting Con 61tions for Operation a
l I
i I
~ - _ = _ - . .
E o ,
, 3.5.A and 3.5.B, and proposed Surveillance Requirements 4.5.A and 4.5.B.
Section 14 of the UFSAR contains analyses of four design basis accidents: the Control Rod Drop Accident, the Loss of Coolant f Accident, the Refueling Accident and the Main Steam Line Break. ,
Implementation of Change Request (19) will not affect the r
- precursors, initial conditions, assumptions, sequences-of-events t
l or results of these accidents, as described in the UPSAR. It is, l therefore, concluded that implementation of Change Request (19)
I will not adversely impact plant safety. !
l l1 Significant Hazards c onsideration - Change Request (19)
]
Change Request (19) conforms to a third example of amendments
\
involving no significant hazards considerations a change which may result in some reduction in a safety margin, but where the results
- of the change are clearly within all acceptaale criterit. Testing i experience at PBAPS has shown that daily testing of all Low
(
Pressure Core and Containment Cooling Systems, for an inoperable I redundant component or diesel generator, results in the detection 4
r 1
of an extremely small number of fiailed components. Operation of l
l the plant under the proposed Surveillance Requirements would not (1) Involve a significant increase in the probability or consequences of an accident previously evaluated.
i The reliability and redundancy of the Low Pressure Core and Containment Cooling Systems, along with the Surveillance Requirements established in other sections of the Technical 1
s
, Specifications, assure the operability of these systems necessary to mitigate the consequences of an accident.
Four design basis accidents described in Section 14 of the UPSAR are the Control Rod Drop Accident, the Loss of I
Coolant Accident, the Refueling Accident and the Main Steam Line Break. Change Request (19) will not adversely impact the precursors, initial conditions, assumptions or sequences- !
of-events of these accidents, as described in the UFSAR.
Therefore, an increase in the probability or consequences of an accident previously evaluated is not created. >
J l OR '
f (2) Cryate the possibility or a new or different kind of accident l 4
from any .ccident previously evaluated. >
I 4 ,
Surveillance and operability requirements are not potential new accident precursors. The surveillance tests and their l
) criteria will remain unchanged, and exccasive challenges to the ECCS will be reduced. It is, therefore, concluded that '
implementation of Change Request (19) will not create the
] possibility of a new or different kind of accident from any ,
i accident prevAously evaluated.
I t
d OR 1
I l
l i
l i
o .
. (3) Involve a significant reduction in a margin of safety.
Relaxing the accelerated testing provisions will reduce long-term equipment wear-out and encourage preventive maintenance at more frequent intervals. For these reasons, a net improvement in the reliability of these essential systems can be anticipated, thus enhancing the margin of safety.
Environmental Consideration Licensee has determined that implementation of the Change Requects included in this Application will involve no increase in the amounts cf, and no change in the types of eftluents that may be released offsite. Licensee has also determined that no environmental consideration is involved, consequently, an er.ironmental report is not submitted.
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4
, Conclusion -
i
.I The Change Requests contained herain were reviewed to determine how I i
they would affect the accident analyses contained in Section 14 of the
]
UFSAR. In addition, the review of the Significant Hazards j Considerations was completed. In all cases, it was concluded that I these Change Requests will improve the Technical Specifications and l improve plant operation.
4 The Plant Operations Review Committee and the Nuclear Review Board i
3 have reviewed these proposed changes to the Technical Specifications, r
have concluded that they do not involve an unreviewed safety question !
) or a significant hazards consideration, and will not endanger the 1 !
health and safety of the public. l i i l !
- l I Respectfully submitted, j PHILADELPHIA ELECTRIC COMPANY ;
i f a t 1
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N [
il C/ Vice Prtbident :
- t 1 i 4 .
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COMMONWEALTil OP PENNSYLVANIA : ,
a ss.
COUNTY OF PHILADELPHIA :
J. W. Gallagher, being first duly sworn, deposes and sayst f
That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing Application for Amendment of Pacility 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.
l N M% U
?
CJ .
Vice President i 4
f I
Subscribed and sworn to
]
before me this # day I of August, 1988 '
l N Y ! RD. N
- c:/ Notary Public
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4 annusennsun :
Wen Peet neh PMk CE )
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