ML20207P379

Application for Amends to Licenses DPR-44 & DPR-56,revising Tech Specs Re Jet Pump Operability & Surveillance & Core Thermal Hydraulic Stability Requirements & Removing Operating Restriction on Unit 2

ML20207P379
Person / Time
Site:	Peach Bottom
Issue date:	01/12/1987
From:	Bauer E, Bradley E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20207P372	List: ML20207P371 ML20207P379 ML20207P393
References
A00L-870112, AL-870112, NUDOCS 8701160085
Download: ML20207P379 (22)

Text

.r

-o' e

- TSP 86-16 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 Edward G. Bauer, Jr.

Eugene J. Bradley 2301 Market Street Philadelphia, Pennsylvania 19101 Attorneys for Philadelphia Electric Company

${k kOO

{7 O

P

t; a

^.

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 Philadelphia Electric Company, Licensee under Facility Operating Licenses DPR-44 and DPR-56 for the Peach Bottom Atomic Station Unit No.

2. and Unit No.

3, respectively, hereby requests that the Technical Specifications contained in Appendix A of the Operating Licenses be amended by revising pages 10 and 149 for Unit 2; pages 149, 149a, 149b and 164d for Unit 3; pages 148 and 160 for both Units 2 and 3; and by adding new pages 149a, 149b and 164d for Unit 2; as indicated by a vertical bar in the margin of the attached pages.

Furthermore, deletion of page 149c from the Unit 3 Technical Specifications is being proposed because of a reduction in material.

The material on page 149b has not changed; only the page number associated with the material has changed.

A set of pages are attached 1 l'

r r

with revision bars applicable to. Unit 2 and a set with revision bars applicable to Unit 3.

- Pages 148 and 149b have revision bars applicable to both units.

The revisions requested in this submittal concern-(I) reactor core thermal hydraulic stability, and (II) operation with jet pump flow indication failures and jet pump operability surveillance requirements.

In addition, it is requested that the present restriction on operating Unit 2 at a maximum of 50% Thermal Power in the single-loop mode be removed.

This restriction was placed on Units 2 and 3 via the transmittal letter of Amendment Nos. 78 and 77, dated May 15, 1981.

This restriction was subsequently removed for Unit 3 (after the core thermal hydraulic stability Technical Specifications were implemented) via the transmittal letter of Amendment No. 107, dated December 3, 1984.

I.

Thermal Hydraulic Stability This Application proposes the addition of provisions to the Unit 2 Technical Specifications to prevent core thermal hydraulic 4

instability and revisions to similar provisions which were added j

to the Unit 3 Technical Specifications by Amendment No. 107, issued December 3, 1984.

The proposed revisions will establish stability Technical Specifications which are identical for Unit 2 and Unit 3.

The proposed revisions are discussed in detail below.

NRC Staff recommendations provided to the Licensee during a June 2, 1986 telephone discussion with the Nuclear Reactor Regulation Staff have been incorporated, to the extent feasible, into this submittal.

The revisions proposed herein reflect the NRC-approved,

~e,

,-t c.e

-r--e

=e no

,mv-

.,e------,

.,,..--,,,nn,------,---,,,.,-,----..-,.n,-a,...----

,-.m-,

e---,

-~.-,--r

~

stability criteria-(G.E. Co. SIL-380, Revision 1) as set forth by Generic Letter 86-02, dated January 23, 1986.

The discussion of core thermal hydraulic stability which exists in the Unit 3 Bases is proposed to be added to the Unit 2 Bases on page 160 and the title of the Bases is proposed to be changed for both Units 2 and 3.

A.

Unit 3 Revisions Pursuant to the Staff's recommendations during the June 2, 1986 telephone discussion, the.following revisions to the Unit 3 Technical Specifications are proposed: (1) removal of APRM and LPRM noise level monitoring requirements in operating Regions 2, 3, and 4, as the Regions are presently defined (Figure 3.6.5, page 164d); (2) a decrease in the allowable time (for taking action) of several limiting conditions for operation (LCOs); (3) a reduction in the upper core flow limit for Region 1 from 45% to 39% of rated; and (4) a decrease in the cut-off criterion for neutron flux noise levels from 5% to 4%.

Additionally, the stability Specifications were reworded to make them easier to understand and conform with typical Technical Specification language.

Each of these proposed rev.isions is discussed individually belcu.

1)

It is proposed to remove the requirements to monitor APRM and LPRM noise levels in operating Regions 2, 3 and 4, as the Regions are presently defined.

Therefore, _,

y,.

these Regions have been removed frou Figure 3.6.5 and LCO 3.6.F.7, and existing Surveillance. Requirement 4.6.F.2 has been removed.

In addition, the requirements to monitor APRM and LPRM noise levels in operating Regions 2 and 4 have.been removed from existing LCO' 3.6.F.6 and existing Surveillance. Requirement 4.6.F.1.

2)

A decrease in the time limit in existing LCO 3.6.F.6.a.1 (renumbered 4.6.F.2) is proposed.

APRM and LPRM noise levels are to be determined at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, instead of.24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, after entering a region which requires monitoring.

The NRC Staff recommended that consideration be given to' reducing the time limit in existing LCO 3.6.F.6.a.2 (renumbered 4.6.F.3) for determining APRM and LPRM noise levels after a Thermal Power increase of at least 5%

from one hour to 30 minutes.

This recommendation has been evaluated and it has been determined'that the time limit for determining APRM and LPRM noise levels should remain at one hour.

At Peach Bottom noise levels are determined manually with little computer-based assistance.

Twenty-four instruments, must be observed long enough to determine a true average, data must be formally documented, gains may have to be adjusted and data may have to be normalized by mathematic computations.

At anytime during this process the operators' attention may have to be redirected to other M

more urgent tasks.

Thus, retention of-the one hour limit :is reasonable,and justified.

I The. monitoring requirements in existing LCO 3.6.F.6.a are actually surveillances and, therefore, are being redesignated as Surveillance Requirements'4.6.F.2 and 4.6.F.3.

It is proposed to decrease the time limit of existing LCO 3.6.F.2 from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to impose an additional time limit of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The requirements applicable to single loop operation shall be initiated within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (instead of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) after removal of a recirculation loop from service.

The phrase "be in effect" was changed to "be initiated" pursuant to the Staff's suggestion on June 2, 1986.

The shutdown action statement has been revised to include a time limit.

The unit shall be in Hot Shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> if LCO 3.6.F.2 is not satisfied.

It is proposed to ad'd'a time limit to existing LCO 3.6.P.4torequiret$atThermalPowerbereducedorcore flow be increased within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

3)

Pursuant to the Staff's recommendation on June 2, 1986; a reduction in the upper core flow limit of Region 1 from 45% of rated flow to 39% of rated flow is being proposed.

The remaining region from 39% to 45% has been designated as the new Region 2.

This change is reflected in the revised Figure 3.6.5 and is consistent..

i

'.s

.with General Electric.Co. SIL-380, Revision 1.

With*'

core flow greater than-45% of rated flow or Thermal Power-below the 80% rod.line (Line A in Figure 3.6.5),

SIL-380,. Revision 1-indicates that stability monitoring.

is not necessary..The Staff indicated on June 2,

1986, that. single loop operation while above Line A in Figure 3.6.5 was acceptable to a minimum of 39% of rated core flow, instead of the existing 45%. limit.

.This change permits single loop operation in the new Region.2;-

therefore, the action statement in existing LCO 3.6.F.4 has been changed to require increasing core flow to greater than or equal to 39% of rated flow.

4)

Pursuant to a recommendation of the Staff, the 5% APRM or LPRM noise level criterion of existing LCO 3.6.F.6.b, which has been renumbered as 3.6.F.5.b, has been reconsidered.

It has been' determined that the.

restriction of corrective actions to situations when the noise levels are greater than 5% of rate'd thermal power

and three times their baseline level can be changed.

It f

is proposed to revise the LCO to require corrective action if APRM or LPRM noise levels are " greater than 4%

and three times their established baseline noise levels."

Noise levels represent'the measured power oscillations inherent in the reactor power control system.

As recommended'by G.E. Company in SIL-380, Revision 1, we have become familiar with our plants' normal APRM and LPRM noise levels.

In some areas of the,

~

_]

~

e-core, noise levels are typically as low as 0.2% and in other areas.approximately 2.5%.

We believe that if low noise levels, such as 0.2%, _ triple in magnitude, no corrective action is necessary.

According to G.E.

Company SIL-380, Revision 1, during single loop operation neutron flux noise levels of 4 to 12% have.

been reported to be typical.

Based on the low magnitude of Peach Bottom noise levels, we feel that proposed LCO 3.6.F.5.b is appropriate and conservative.

5)

It is proposed to revise LCOs 3.6.F.3, 3.6.F.4 and 3.6.F.6 (renumbered 3.6.F.5) to make them easier to understand.

Presently, each LCO defines the operating region of concern prior to the action statement.

This made the-LCOs cumbersome to read and difficult to understand.

To make the LCOs briefer, Regions 1 and 2 are defined once, in LCO 3.6.F.3, and referenced in the subsequent LCOs.

It is believed that with the visual aid of Figure 3.6.5 these proposed LCOs will be easier to understand.

It is proposed to revise the wording of existing LCO l

3.6.F.6.b (renumbered 3.6.F.5.b) to conform with typical i

l Technical Specification language.

Presently, the action i

statement states "... reduce thermal power at a rate l

l which would bring the reactor to the hot shutdown condition within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> This statement is ambiguous and should be replaced with "... begin an.

orderly shutdown.and be in Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />...."

B.-

Unit 2 Revisions Unlike the Unit 3 Technical Specifications, the Unit 2 Technical Specifications do not currently contain requirements for avoiding thermal hydraulic instability.

This Application proposes the addition of monitoring and operability requirements to the Unit 2 Technical Specifications to be identical with the revised Unit 3 requirements proposed herein in Section I.A.

The following additions to the Unit 2 Technical Specifications are proposed: 1) LCO 3.6.F.3 and Figure-3.6.5; 2) LCO 3.6.'F.4; and 3) LCO 3.6.F.5 and Surveillance Requirements 4.6.F.1, 4.6.F.2 and 4.6.F.3.

Also, 4) LCO 3.6.F.2, is being revised.

Each of these items (1 through 4) is discussed below.

1)

The addition of LCO 3.6.F.3 is proposed to establish Thermal Power and core flow operating limits to avoid thermal hydraulic instability.

LCO 3.6.F.3 directs the reader to the subsequent Specifications which identify monitoring requirements when operating in the single recirculation loop mode or in a region of potential instability.

LCO 3.6.F.3 defines the Regions of potential instability.

Figure 3.6.5, which ident.ifies the Thermal Power and core flow limits and the regions of potential instability, is added as page 164d..

t 2)

The addition of LCO 3.6.F.4 is proposed 'tx) prohibit-

~

continued single recirculation loop operation below 39%

of rated core 1 flow and power above the 80% rod line 1

(Line A of Figure 3.6.5).

Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> power must be decreased or flow must be' increased to avoid Region 1..

3)

The addition of LCO 3.6.F.5 is proposed to require APRM and LPRM noise level monitoring when operating in_the regions of potential instability (low flow /high power) as. recommended by G.E. Co. SIL-380, Revision 1.--

If noise levels _ greater than 4% and three times their established baseline levels occur and are not corrected within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, this Specification requires that Hot Shutdown be. reached within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The establishment of baseline levels is required by' proposed Surveillance Requirement 4.6.F.1 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of entering a region for which monitoring is required unless baselining has been previously performed since the last refueling outage.

Proposed Surveillance Requirements 4.6.F.2 and 4.6.F.3 establish the noise level monitoring requirements.

1 4)

It is proposed to revise existing LCO 3.6.F.2 to reduce the time limit for having the requirements applicable to single loop operation in effect from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following removal of a recirculation loop from service.

In addition, a time limit of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is proposed to be added for reaching Hot Shutdown if LCO 3.6.F.2 is not j

satisfied.

i L

C.

Units.2 and 3 Revisions Concerning Natural Circulation The following proposed revisions are discussed below:-1) removal of Unit 2 Specification (Limiting Safety System Setting) 2.1.A.4 and addition of Unit 2 LCO 3.6.F.6; and 2) a conservative change to Unit 3 LCO 3.6.F.5 and renumbering Specification'3.6.F.5 as 3.6.F.6.

The revision bar on the attached _page 10 applies only to the Unit 2 Technical Specifications.

1)

It is proposed to remove Unit 2 Specification 2.1.A.4, which prohibits operation in the natural circulation mode, from page 10 and replace it with Specification 4

3.6.F.6.

The current Specification 2.1.A.4 is deficient because it lacks an action statement, and it is not actually a Limiting Safety System Setting and, thus, does not belong in this section.

LCO 3.6.F.6 is more appropriately located with the stability provisions and provides a description of action to be taken in the event no recirculation loops are operating.

This Specification requires an immediate reduction of Thermal Power followed by a reactor shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> if the mode switch is in STARTUP or RUN with no recirculation loops in operation'.

2)

The LCO discussed above for Unit 2 presently exists in the Unit 3 Technical Specifications as LCO 3.6.F.5; however, the action statement presently allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to achieve Hot Shutdown, after an immediate reduction of -

s:

. power..This' provision has been reviewed and,.in the

' absence of'a' plant-specific analysis toLjustify operation in the natural. circulation mode, it has-been ecided that the LCO should be revised to require a d

shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. - This revision strengthens -the action statement by allowing less time for,the shutdown and is clearly a conservative change.

Furthermore, it is proposed that this Specification be placed after-the LCOs for dual and single-loop operation so that the I

- format follows the logical progression towards' Reactor Recirculation System shutdown.

This revised LCO would become 3.6.F.6, as proposed for the Unit 2 Technical Specifications.

ISafety Assessment:'

The proposed revisions to the Peach Bottom Unit 2 Technical Specifications add specific power and core flow operating limits as

-well as additional monitoring and action statement requirements which are not currently-in the Unit 2 Technical Specifications.

These

. revisions will assure that plant operation'will remain within stability-limits previously found acceptable by the NRC's Staff (49 Fed.' Reg. 42829, October 24, 1984).

Replacementlof Unit 2 Specification 2.1.A.4 with Specification 3.6.F'.6, and the revision of Unit 3 Specification 3.6.F.5 (renumbered 3.6.F.6) will improve the

Technical Specifications by prohibiting continued operation in the natural circulation mode.

The proposed revisions to the Unit 3 c

4 ;

.__,__....u._._._

, -, _ ~. _, - -..

otability specifications either provide additional ~ conservatism or delete requirements as recommended by the NRC's Staff.

Significant Hazards Consideration Determination for-Section 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 (51 Fed. Reg.

7751).

An example (vii) of a change that involves no significant hazards considerations is "a change to conform a license to changes in the regulations, where the license change results in very minor changes to facility operations clearly in keeping with the-

. regulations.".

The proposed revisions to the existing Unit 3-stability specifications fit this example more closely than any of the other examples in that NRC Generic Letter 86-02 recommended the incorporation of the approved stability criteria into Technical g

l Specifications, and the NRC Staff recommended the revisions to the existing Unit 3 stability specifications.

An example (ii) of a change

- that involves no s'ignificant hazards considerations is "a change that 3-constitutes an additional limitation, restriction or control not presently included in the technical specifications, e.g., a more stringent surveillance requirement."

The proposed revision to Unit 3 Technical Specification 3.6.F.5 (renumbered 3.6.F.6) and the addition of the stability monitoring requirements to the Unit 2 Technical Specifications fit this example.

The action statement of proposed Specification 3.6.F.6 is more restrictive and the stability requirements being added to Unit 2 constitute additional restrictions not presently included in the Technical Specifications.

t 4. _ _ _ -,. _ _ _ _. _ _ _.. _

It has been determined, based on the foregoing discussions, that operation of Peach Bottom Atomic Power Station Units 2 and 3, in cccordance with these proposed revisions to the Technical Specifications, does not involve a significant hazards consideration for the'following reasons:

1)

.The. proposed revisions do not involve a significant increase in the probability or consequences of an accident previously evaluated because the revisions are consistent with the NRC-approved stability criteria and the monitoring requirements are sufficient to prevent thermal hydraulic instability.

Stability monitoring provisions decrease the probability of fuel damage by avoiding limit cycle neutron flux oscillations.

The more restrictive action statements.

decrease the possibility for instability,

11).The proposed revisions do not create the possibility of a new or different kind of accident from any accident previously evaluated because the monitoring requirements and revised action statements do not change reactor operating procedures or characteristics.

They merely serve to prevent operation in regions of potential instability, iii) The proposed revisions do not involve,a significant reduction in a margin of safety because these monitoring requirements will ensure that limit cycle neutron flux oscillations are avoided, thereby reducing the potential for a reactor power transient. -

- II. Jet Pump Flow-Indication Failures and Jet Pump Operability

.This Application also proposes revisions to the LCOs.concerning reactor recirculation jet pumps to more adequately address' flow indication failures, and revisions to the jet pump Surveillance Requirements to address single loop operation.

A brief discussion of flow indication failures is proposed for the Unit 2 and Unit 3

. bases on page 160.

A.

The existing Technical Specification LCOs do not address jet pump flow indication failure during single reactor recirculation loop operation, and the existing LCO addressing flow indication failure during two loop operation (3.6.E.3)

.is not clearly worded.

Revisions proposed to correct these deficiencies are discussed below.

1.

It is proposed that LCO 3.6.E.3 be rewritten to clearly indicate that only one flow indication failure is permissible while operating in the two-loop mode.

With two or more failures, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is allowed to correct the failure (s) before a shutdown must be initiated.

The revision also makes it clear that within "the following" 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the reactor must be in Cold Shutdown condition.

This is consistent w'ith the Licensee's interpretation of the LCO; therefore, rewording this LCO merely removes ambiguity.

2.

It is proposed that LCO 3.6.E.4 be added to address flow indication failure during single loop operation.

The 4,

~

proposed LCO 3.6.E.4 requires that a shut'down be initiated within'12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> if any flow indication failures occur while operating in single. loop.

The thermal hydraulic analysis which provides the.

justification for single loop operation does not consider a flow indication failure on any jet pump; therefore, the Technical Specifications should prohibit-continued operation in.this condition.

B.

'The existing Surveillance Requirements do not take into consideration single loop operation.

It is proposed that a new paragraph, 4.6.E.1.d,.be added to address diffuser to lower plenum differential pressure during, specifically, single' loop operation.

Proposed Specification 4.6.E.1.d is similar to existing Specification 4.6.E.1.c except that it specifies that only the jet pumps in the " operating loop" are of concern during the single loop mode.

Also, existing Specification 4.6.E.1.c is revised merely to specify that it 4

applies t'o two-loop operation.

Safety Assessment:

i-l The changes to the Jet Pump Technical Specifications provide a new LCO and a new Surveillance Requirement applicable to single-loop l

cperation.

These are improvements to the Technical Specifications because presently there is no LCO for jet pump flow indication

!~

failures during single-loop operation and Surveillance Requirement 4.6.E.1.c was ambiguous with regard to single-loop operation.

LCO,

I

3.6.E.3 was not clearly worded and is being revised for clarification.

The' technical nature of LCO 3.6.E.3 remains unchanged.

If an indication failure occurs on a jet pump, the measured total core flow accuracy may be reduced.

This is a concern because core flow is an input to the calculations of core thermal limits.

An analysis to determine whether a jet pump flow indication failure during single-loop operation results in measured core flow accuracy within the bounds of that assumed in the Peach Bottom core thermal-analysis basis calculations has not been performed.

The effect on the core thermal limit calculations is expected to be relatively small; however, it could be non-conservative.

A broken jet pump instrument line would constitute a post-LOCA leakage path out of the core shroud to the reactor annulus region; however, the magnitude of the leakage is expected to be insignificant and have minimal effect on emergency core cooling c pability.

In addition, two of the jet pump instrument lines are uned to measure reactor water level and for valve permissive signals on low pressure emergency core cooling systems.

In light of the potential adverse effects of a jet pump flow i

indication failure, LCO 3.6.E.4 is being added for the single-loop mode.

The Technical Specifications are prcEen :1y deficient in that they do not address this condition.

Pio: ae{.CO 3.6..E.4 contains the ecme action statement for single-loop as 3.6.E.3 presently contair.s for two-loop.

The rewording of the existing action statement for two-loop operation does not change its meaning, it merely makes it more clear. l

s.

The proposed changes to the Jet Pump Specifications improve

.the. Technical. Specifications by making them more complete and precise with regard to single-loop operation.

Significant Hazards Consideration Determination for Section II:

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

-7751).

An example (ii)- of a change that involves no significant hazards considerations is "a change that constitutes an additional limitation, restriction or control not presently included in the

-technical specifications, e.g.,

a more stringent surveillance requirement."

The addition of proposed LCO 3.6.E.4 fits this example.

Another example (i) of a change that inv'olves no significant hazards considerations is "a purely administrative change to technical cpecifications:

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

The proposed revisions to the other jet pump specifications and the. addition of 4.6.E.1.d are administrative changes.

The changes to LCO 3.6.E.3 and Surveillance Requirement 4.6.E.1.c merely clarify the specifications.

The addition of proposed Surveillance Requirement 4.6.E.1.d is an administrative change as well because 4.6.E.1.d is merely a " repeat" of existing Surveillance Requirement 4.6.E.1.c with clarifying words to address single-loop operation.

This is not, in effect, a technical change. _ _

[I It has been determined, based'on the foregoing discussions, thatl operation:of Peach Bottom Atomic Power Station Units 2 and 3, in cccordance with these proposed revisions to the Technical

' Specifications does not-involve a significant-hazards consideration for the following' reasons:

i)-

The proposed revisions do not' involve a significant increase in the probability or consequences of an accident previously evaluated.. The change to LCO 3.6.E.3 does not change ~the intent of the Specification; it simply makes it more understandable, which' increases the--probability of:

.conformance to the LCO.

The revisions to the surveillance requirements merely provide clarification by addressing' single loop operation and two-loop operation specifically.

-The addition of LCO 3.6.E.4 prevents continued operation of the reactor in an unanalyzed condition, thereby decreasing the probability of an accident, without affecting the consequences of an accident.

These changes are, therefore, conservative.

ii)

The proposed revisions do not create the possibility of a new or different kind of accident from any accident previously evaluated because the revisions do not adversely change allowable reactor operations.

In eff'ct, the revision of LCO e

3.6.E.3 and revisions to the surveillance requirements do not change reactor operation.

The addition of LCO 3.6.E.4 does not create any new mode of operation; rather, it prohibits an. -

g; L.

K.

unanalyzed operation which the Technical Specifications previously did not address.

lii) The proposed revisions do not involve a significant reduction in a margin of safety because the revisions clarify the specifications and reduce the possibility.of~ reactor operation in an unanalyzed condition which clearly increases the margin of safety.

i The-Plant Operating Review Committee and the Nuclear Review Board have reviewed these proposed changes to the Technical Specifications and have concluded that they do not involve an unreviewed safety question or a significant hazards consideration and will not endanger the health and safety of the public.

Respectfully submitted, PHILADELPHIA ELECTRIC COMPANY

% W Q O-L (jVice Presid#ht i j

7.

~ COMMONWEALTH OF PENNSYLVANIA ss.

COUNTY OF PHILADELPHIA J. W. Gallagher, being first duly sworn, deposes and says:

That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing Application for Amendment of Facility Operating Licenses 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.

O o

Subscribed and sworn to TA before me this/2 day of

/70 Y

Notary Public MELANIE R. CAMPANELLA Notary Public Philadelphia, Philadelphia Co.

My Commission Expires February 12,1990

f

/t

i 1-I-

CERTIFICATE OF SERVICE i.

i i

I certify that service of the foregoing Application was made upon the i}

Commonwealth of Pennsylvania, by mailing a copy thereof, via first-class mail, i

to Thomas R. Gerusky, Director, Bureau of Radiological Protection, P. 0. Box

' f-2063, Harrisburg, PA 17120; all this 12th day of January,1987.

(!

'l 1

i tb.

V1 u

vr EQ ne/J. Bradley

/

l}

Attorney for Philadelphia Electric Company l

,