ML20202F415
| ML20202F415 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/04/1998 |
| From: | Cotton J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20202F419 | List: |
| References | |
| NUDOCS 9802190196 | |
| Download: ML20202F415 (7) | |
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PECO NUCLEAR nm o,--
A Unit of PECO Energy N[m$NNhN February 4,19wo Docket Nos. 50 277 50-278 License Nos. UPR-44 i
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 96-02071
Dear Sir:
PECO Energy Company (PECO Energy) hereby submits License Change Application ECR 96-02071, in accordance with 10 CFR 50.90, requesting a change to the Peach Bottom Atomic Power Stebon (PBAPS), Units 2 and 3 Facility Operating Licenses. This proposed change will revise Technical Specifications (TS) Surveillance Requireinent 3.6.4.1.2 concerning Secondary Containment doors.
hformanon 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 conta;ned in Attachment 2. We request that this amendment to the PBAPS, Units 2 and 3 TS be approved by August 15,1998, if you have any questions, please do not hesitate to contact us.
Very truly yours, h4
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Director - LicensingjY8 i
Enclosures:
Affidavit, Attachment 1. Attachment 2 cc:
H. J. Miller, Administrator, Region I, USNRC A. C. McMurtray, USNRC Senior Resident inspector, PBAPS R. R. Janati, Commonwealth of Pennsylvania Dk DOh o
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CdMMONWEALTH OF PENNSYLVANIA:
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i COUNTY OF CHESTER J. B. Cotton, being first duly sworn, 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 96-02071, for Peach Bottom Facility Operating Licenses DPR-44 and DPR-56, and knows the contents thereof; and that the statements and maticrs set forth therein are true and correct to the best of his knowledge, information and belief.
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Vice President Subscribed and sworn to before me this b day of dm
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4 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 96-02071
" Secondary Containment Doors" Supporting Information 4 Pages
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Dock:t Nos. 50-277 50 278 Licenso Nos. DPR-44 DPR 56 inkoducMon 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 Surveillance Requirement (SR) 3.6.4.1.2 and the associated Bases, to reflect changes in requirements for Secondary Containment doors. The TS and Bases pages showing the proposed changes are contained in Attachment 2. This License Change Application 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 Cor@mtion and information supporting an Environmental Assessment.
Discussion and Descriotion of the Prooosed Change TS SR S 6.4.1.2 currently requires verification that "each secondary containment access door is closed, except when the access opening is being used for entry and exit, then at least one door shall be closed." PECO Energy Company proposes that SR 3.6.4.1.2 be revised to verify "that either all inner or all outer secondary contalriment access doors are closed in each air lock." This change will result in greater flexibility in performing maintenance on the Secondary Containment doors and greater flexibility in moving materials in and out of Secondary Containment. Currently, maintenance of the Secondary Containment doors requires declaring the Secondary Containment inoperablo and entering a four (4) hour action statement. Failure to complete the ma ntonance within the four (4) hours would require the plant to be in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and Mode 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Entering Mode 3 or 4 for Secondary Containment door maintenance results in undue hardship without any significant benefit In safety.
Safety Assessment As stated in the PBAPS, Units 2 and 3 Updated Final Safety Analysis Report (UFSAR)
(Section 5.3," Secondary Containment System"), the safety objective of the reactor building Secondary Containment, in conjunction with other engineered safeguards, is to limit the ground level release of airborne radioactive materials and to provide a means for controlled elevated release of the building atmosphere so that off-site doses from l
the postulated design basis accidents are below the guideline values of 10 CFR 100. In l
order to maintain this safety objective, the reactor building has personnel and l
equipment entrances. The entrances are provided with alrtight doors forming an air j
lock system to maintain the leak t;ghtness of the building. The proposed TS will maintain this safety objective of the Secondary Containment.
As stated above, PECO Energy Company proposes that TS SR 3.6.4.1.2 be revised to verify "that either all inner or all outer secondary containment access doors are closed in each air lock." During the times that one or more inner (or outer) doors are open, the closed outer (or inner) doors will serve as the Secondary Containment barrier. Allowing certain inner or outer Secondary Containment doors to be open does not compromise the safety oblective of the Secondary Containment since no commitment is made in the PBAPS, Units 2 and 3 UFSAR to consider the single failure of passive 3
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Dock;t Nos. 50-277 50-278 License Nos. DPR-44 DPR 56 structural components such as Secondary Containment doors. As discussed in Section 1.5 of the UFSAR, ".... Essential safety actions shall be carried out by equipment of sufficient redundance and independence that no single failure of active components can prevent the required actions". The same UFSAR section goes on to state that, "For passive electrical comoonents are considere(d, as well as single failures of a components,in recognition of the higher anticipated failure rates of passive electrical components relative to passive mechanical components." Therefore, based on this UFSAR discussion, it is concluded that failure of outer (Inner) secondary containment doors need not be postulated with an inner (outer) door being open.
Controls exist to ensure that Secondary Containment is maintained. Blue lights provide visual waming if either an inner or outer barrier in an air lock is opon (a barrier is usually comprised of a single door, but in some cases two doors are provided). This supervisory electrical system also alarms upon a condition where both an inner and outer barrier are open in any air lock. The alarms consist of a Control Room alarm and local audible alarms. The Alarm Response Card (ARC) for this alarm requires that personnel be dispatched to close doors if the alarm has not cleared. This supervisory system is tested periodically. Procedures also exist which specify the administrative requirements for the extended opening of any Secondary Containment access door.
in addition, a Secondary Containment capability (draw down) test is performed with the Standby Gas Treatment System once per cycle on each unit. This test verifies the capability to maintain Secondary Containment with only inner or only outer doors closed in each air lock, thus testing the capability of only inner and then only outer doors.
This change will not result in greater or more frequent loading of Secondary Containment doors, and does not result in changes that impact the reliability of the Secondary Containment and the Standby Gas Treatment System.
Information Sucoorting a Finding of No Significant Hazards Consideration We have concluded that the proposed change to the PBAPS, Units 2 and 3 TS, which will revise TS SR 3.6.4.1.2, does not involve a Significant Hazards Consideration. In support of this determination, an evaluation of each of the three (3) standards set forth in 10 CFR 50.92 is provided below.
1.
The orocosed TS chanaes do not involve a slanificant increase in the orobability or consecuences of aC wident oreviously evaluated.
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TS SR 3.6.4.1.2 wil' J to require either all inner or outer secondary containment access
,, be closed in each air lock. This revision will not adversely affect the abihty of the Secondary Containment to mitigate the radiological consequences of a Loss-of Coolant Accident or fuel handling accident, and does not involve a significant increase in the probability or consequences of an accident previously evaluated. During those times that one or more inner (or outer) doors are open, the closed outer (or inner) doors will serve as the Secondary Containment boundary. Allowing certain inner or outer Secondary Containment access doors in an air lock to be open does not 2
Docket Nos. 50-277 50-278 License Nos. DPR44 DPR 56 compromise the design of the Secondary Containment. No commitment is made in the UFSAR to consider the single failure of passive structural components such as Secondary Containment doors. As discussed in Section 1.5 of the UFSAR, ".... Essential safety actions shall be carried out by equipment of sufficient redundance and independence that no single failure of acityn components can prevent the required actions". The same UFSAR section goes on to state that,"For systems or components to which IEEE 279 (1968)is applicable, single failures of passive electrical compDnenis are considered, as well as single failures of active components,in recognition of the higher anticipatec failure rates of passive electrical components relative to passive mechanical components." Therefore, based on this UFSAR discussion, it is concluded that failure of outer (inner) secondary containment doors need not be postulated with the inner (outer) door being open.
The performance of the Secondary Containment and the Standby Gas Treatment S stem is unaffected by this activity. Surveillance testing will prove the capabilit to maintain Secondary Containment with only inner or only outer doors close. This change will not result in greater or more frequent loading of Secondary Containment doors, and does not result in changes that impact the reliability of the Secondary Containm6nt and the Standby Gas Treatment System.
2.
The oroposed TS changes do not create the possibilltv of a new or different kind of accident from any accident nreviously evaluated.
The Secondary Containment, in conjunction with the Standby Gas Treatment System, provides the means for mitigating the radiological consequences of an accident. The configuration of the Secondary Containment has no effect on accident initiators wilch lead to a new or different kind of accident. This change will not involve any changes to plant systems, structures, or components whic 1 could act as new accident initiators. The design, function, and reliability of Secondary Containment and the Standby Gas Treatment System are also not impacted by this change. Therefore, this change will not create the possibility of a new or different kind of accident from any previously evaluated.
3.
The oronosed TS changes do not involve a significant reduction !n a raargin of sale.ty, No margins of safety are reduccd as a result of this change to the TS. No safety limits will be changed as a result of this TS change. The Secondary Containment will continue to perform its intended safety function of limiting the ground level release of airborne radioactive materials and to provide a means for controlled elevated release of the building atmosphere so that off-site doses from the postulated design basis accidents are below the limits of 10 CFR 100. The des gn and reliability of the Secondary Containment are also not impacted as a result of this change.
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l Docktt Nos. 50 277 l
50-278 j
Information Sunnartina an Environmental A=====mant An environmental asseesment is not required for the proposed changes since the -
proposed changes conform to the criteria for " actions eligible for categorical exclusion" i
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 s gnificant hazards consideration i
- as discussed in the preceding section. The proposed changes do not involve a -
t significant change in the types or significant increase in the amounts of any effluents i
that may be released offsite. In addition, the propostd changes do not involve a -
1 significant increase in Individual or cumulative occupational radiation exposure. -
Conclualon i
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 l
of the public.
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