ML20207P517
| ML20207P517 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/17/1986 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20207P442 | List: |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8701160210 | |
| Download: ML20207P517 (11) | |
Text
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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 Edward G. Bauer, Jr.
Eugene J. Bradley 2301 Market Street Philadelphia, Pennsylvania 19101 Attorneys for Philadelphia Electric Company t
8701160210 861024 PDR ADOCK 05000277 P
BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-277 C.
PHILADELPHIA ELECTRIC COMPANY 50-278 k
APPLICATION FOR AMENDMENT a
OF d
FACILITY OPERATING LICENSES I
DPR-44 & DPR-56 Philadelphia Electric Company, Licensee under Facility 3
Operating Licenses DPR-44 and DPR-56 for the Peach / Bottom Atomic Power 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 certain i
sections as indicated by a vertical bar in the margin of the j
attached pages 77, 77a and 78a.
The requested changes are l
intended to bring the range of a drywell temperature indicator and a drywell temperature recorder into conformance with the l
requirements of Regulatory Guide 1.97 (Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs During and Following an Accident) by changing the range of the
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' drywall tcmparatura instrumonts to 40 - 440 d3gress F.
Additional changes are also requested to clarify Table 3.2.F and to correct an error in Table 3.2.F.
1.
Currently, drywell temperature is monitored in the control room via pressure / temperature recorder PR/TR-4(5)805 (pen #1) and multi point temperature indicator TI-2(3)501.
The temperature range of PR/TR-4(5)805 is 0
- 240 degrees F and the range of TI-2(3)S01 is -150 -
+300 degrees F.
On January 16, 1984, by letter from S.
L. Daltroff, PECo, to D. G. Eisenhut, NRC, PECo committed to changing the range of the drywell temperature instruments to 40 - 440 degrees F in order to satisfy the requirementa of Regulatory Guide 1.97.
Accordingly, PR/TR-4(5)805 will be replaced with a new recorder which will provide a temperature range of 40 -
440 degrees F.
TI-2(3)S01 will be modified to meet the range requirement by installing a linearizer program board and a thermocouple signal conditione'r board which
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will give this device a range of -300 - +750 degrees F.
These boards are the only ones available from the manufacturer which will satisfy the range requirements of Regulatory Guide 1.97.
The instrument accuracy for m
the proposed range will be 1 2.625 degrees F (1 0.25%
full scale).
The instrument accuracy as currently installed is 1 1.125 degree.s F.
TI-2(3)S01 is not a safety-related device.
PR/TR-4(5)L35 is a safety-related device. ___
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~ The current Tschnical Sp:cification Table 3.2.F specifies a range of 0.- 400 degrees F for the drywell temperature-indicator and recorder.
As a result of the rar.ge change modification discussed above, ~ it is requested that the range of the drywell temperature
- devices listed in Table.3.2.F be changed to 40 - 440 degrees F.
Further, because the new range of TI-2(3)S01 will not be' identical to the proposed range in Table 3.2.F, a clarifying note (Note 12) is being added to l
Technical Specification page 78a to indicate that the new range of TI-2(3)501 (-300 - +750 degrees F) is j
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acceptable because it encompasses the proposed range of 40 -
440_ degrees F.
It is requested that these changes become effective upon completion of the modification to 1
each' device.
1 2.
In order to improve the clarity of Table 13.2.F, two new 4
l columns have been added to the proposed Table 3.2.F.
l One of the new columns lists the instruments in the l
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table by their identification numbers.
Cu'rrently, the
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identification of instruments is inferred by using the type of indication and range for each parameter specified in the table.
The addition of this column will make it easier to ensure that the minimum number of I
instrument channels are operable as specified in the E
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table.
The other new column provides a number (1 thru
]
- 18) for each of the eighteen items identified in Tiole 3.2.F.
The addition of this column will provide an easy reference method for the parameters in the table.
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cddition of both columns 10 chown on attachsd Tschnical Specificntien pIges 77 and 77a.
- 3..
An error has been identified in Table 3.2.F involving the range of the suppression chamber water level (narrow range) instruments.
Currently, the instrument range for this parameter is specified in Table 3.2.F as 0-2 feet.
In attuality, the installed range of these instruments is 13.7-15.7 feet.
(Normal suppression chamber water level is maintained at 14.6-14.9 feet.) It is requested that the required range of tne suppression chamber water level instruments specified in Table 3.2.F be changed from 0-2 feet to 13.7-15.7 feet.
This change is indicated on attached Technical Specification Page 77.
Safety Assessment Indications of plant variables are required by the control room operating personnel during accident conditions to j.
determine whether plant systems are functioning properly.
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Drywell temperature is one such variable.
Currently, drywell' temperature is monitored in the control room via a pressure / temperature recorder and a temperature indicator.
One of the proposed changes would increase the range of the recorder and the indicator so that during normal and accident conditions it will be highly unlikely that offscale readings will l
occur.
Onscale readings will allow the control room operator to effectively monitor drywell temperature at all times.
As a
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rGcult'of this ranga change-the esp 2bility to monitor drywall temperature will be enhanced.
Further, the proposed range change conforms to the drywell temperature range specified in Regulatory Guide 1.97 (Instrumentation for Light-Water-Cooled Nuclear Power
(
Plants to Assess Plant and Envirens During and Following an i
Accident).
The remaining changes proposed in this Amendment Application are of an administrative nature only.
These changes involve correction of an error and clarification of instrumentation to avoid confusion or misinterpretation.
Significant Hazards Consideration Determination Regulatory Guide 1.97 is' intended to ensure that nuclear power plants are instrumented as necessary to measure certain prescribed variables during and after a reactor accident.
This data will assist control room operators in preventing and
/
mitigating the consequences of accidents.
For each variable, the t
Guide recommends the instrument range, quality assurance requirements, and other design features.
Supplement 1 to NUREG-0737, " Requirements for Emergency Response Capability", requested implementation of the recommendations of Regulatory Guide 1.97.
I Thin Amendment Application requests changes that would conform 1
the Technical Specifications to the NRC's guidance and to Philadelphia Electric Company's commitments of January 16, 1984 (Correspondence, S. L. Daltroff, PECo, to D. G. Eisenhut, NRC, Attachment II, Variable D7).
The proposed changes to the drywell l
temperature instrument ranges specified in Table 3.2.F do not -
invdiva_o significant hazards consideration bscausa operation of Peach Bottom Atomic Power Station with these changes does not:
(1) involve a significant increase in the probability or consequences of an accident previously evaluated.
This modification merely changes the range of drywell temperature indication so that temperature excursions that could occur during-accident conditions are observable to the operator.
(2) create.the possibility of a new or different kind of accident from anyLaccident previously evaluated.
It is not possible for an instrument range change used for indication purposes only to cause a different type of accident or malfunction.
(3) involve a significant reduction in a margin of safety.
Changing the range of the drywell. temperature instruments as described in this Application will j
decrease the chances of offscale readings during potential severe transients and, therefore, will have the effect of enhancing a margin of safety.
The proposed changes to Table 3.2.F which add item numbers and instrument identification numbers to the table do not:
1 (1) involve a significant increase in the probability or consequences of an accident previously evaluated because l
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- tha cdditions are cimply administrativa changsc design =d to Gnhanca interpretation of tha Tachnical Specifications..
(2) create the possibility of a new'or different kind of
-accident from any accident previously evaluated because the additions are simply administrative changes designed to enhance ir.terpretation of the Technical l
Specifications.
l (3) involve a significant reduction in a margin of safety i
because the additions are simply administrative changes designed to enhance interpretation of the Technical Specifications.
4 The proposed change to Table 3.2.F involving the correction of the suppression chamber water level instrument range does not:
(1) involve a significant increase in the probability or 4
consequences of an accident previously evaluated because the change is simply an administrative change designed to correct an error which occurred as a result of oversight.
i (2) create the possibility of a new or different kind of i
accident from any accident previously evaluated because the change is simply an administrative change designed l-e g--+'-q,r--y-m r-T W-W-W D** - * ' -w ve-99'-au-'-T-ww w ev F w *'w=F-"4m"'+1Ne==v-*en'-TvWem=-t'**+-PMte-9-*-
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to correct an Grror which occurred as a result of an oversight.
(3) involve a significant reduction in a margin of safety because che change la simply an administrative change designed to correct an error which occurred as a result of an oversight.
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 (48 FR 14870).
One of the examples of an action involving no significant hazards consideration is a change to make a license conform 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 changes to Table 3.2.F which change the range of drywell temperature indication fit this example of an action not involving a significant hazards consideration, because they are in accordance with NUREG-0737 and Regulatory Guide'l.97.
A second example of an action involving no significant hazards consideration is a purely administrative change to the Technical Specifications.
The proposed changes to Table 3.2.F which add item numbers and instrument identification numbers to the table fit this example of an action not involving a significant hazards consideration because they are intended to enhance the Tr.chnical Specifications by clarifying the description of the instruments specified in Table 3.2.F to avoid....m.
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.h confusion or misinterpretation.
This second example also applies to the proposed change i..vulving correction of the error identified in. Table 3.2.F concerning the suppression chamber water level instrument range.
The Plant Operational 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.
1
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Respectfully submitted, PHILADELPHIA ELECTRIC COMPANY Q-e Vice~ President
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' COMMONWEALTH OF PENNSYLVANIA ss.
COUNTY OF PHILADELPHIA S..L. Daltroff, 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.
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. [ 4T f.,
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/ I Subscribed and sworn to TA before me this/7 day of 8 h
E f-Notary Public l
MELANIE R. CAMPANELIX
. Notary Public, Philadelphia, Philadelphie Co.
My Commission Espires February 12,1990 l
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