ML20209F764

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License Change Application ECR 99-01255,revising TS Sections 2.1.1.2 & 5.6.5 by Incorporating Revised SLMCPR & Deleting Previously Added footnotes.Non-proprietary & Proprietary Info Re Slmcpr,Encl.Proprietary Info Withheld
ML20209F764
Person / Time
Site: Peach Bottom Constellation icon.png
Issue date: 07/12/1999
From: Geoffrey Edwards
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20137X217 List:
References
NUDOCS 9907160123
Download: ML20209F764 (9)


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A 10 CFR 50.90

- PECO NUCLEAR ecco toe <ov comnee<

965 Chesterbrook Boulevard

. A Unit of PECO Energy Wayne, PA 19087-5691 i

July 12,1999 j Docket No. 50-278 License No. DPR-56 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

Peach Bottom Atomic Power Station, Unit 3 License Change Application ECR 99-01255

Dear Sir / Madam:

PECO Energy Company (PECO Energy) hereby submits License Change Application ECR 99-01255, in accordance with 10 CFR 50.90, requesting a change to the Peach Bottom Atomic Power Station (PBAPS), Unit 3 Facility Operating License. This proposed change will revise Technical Specifications (TS) TS 2.1.1.2 ("Reac'or Core SLs") and Section 5.6.5 (" Core Operating Limits Report"). These Sections will be revised to: 1) incorporate revised Safety Limit Minimum Critical Power Ratios (SLMCPRs) due to the use of cycle specific analysis performed by General Electric Nuclear Energy (GENE) for PBAPS, Unit 3, Cycle 13,2) delete previously added j/

footnotes which are no longer neessary, and 3) update a referencs contained in TS 5.6.5.b.2 which documents an analytical method used to determine the core operating limits.

j Information supporting this request is contained in Attachment 1 to this letter, and the j proposed pages (including marked up pages) to the PBAPS, Unit 3 TS are contained /~

in Attachment 2. Attachment 3 ("AdditionalInformation Regarding the Cycle Specific SLMCPR for Peach Bottom 3 Cycle 13," dated June 9,1999) specifies tha new SLMCPRs for PBAPS, Unit 3. Attachment 3 contains information proprietary to General Electric. General Electric requests that the document be withheld from public disclosure in accordance with 10 CFR 2.790(a)(4). An affidavit supporting this request is also contained in Attachment 3. Attachment 4 contains a non-proprietary version of the General Electric document.

9907160123 990712 PDR ADOCK 05000278 1600n 5 O

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July 12,1999 -

Page 2 We request that the amendment to the PBAPS, Unit 3 TS be approved by September 30,1999, and be made effective prior to the restart from the upcoming PBAPS, Unit 3 refueling outage which is currentif scheduled to begin in late September 1999.

If you have any questions, please do not hesitate to contact us.

Very truly yours,

b. N Y ,b=ca Garrett D. Edwards Director- Licensing

Enclosures:

Affidavit, Attachment 1, Attachment 2, Attachment 3, Attachment 4 cc: H. J. Miller, Administrator, Region I, USNRC A. C. McMurtray, USNRC Senior Resident inspector, PBkPS R. R. Janati, Commonwealth of Pennsylvania l

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i COMMONWEALTH OF PENNSYLVANIA: J l

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COUNTY OF CHESTER  :

J'. J. Hagan, being first duly sworn, deposes and says:

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That he is Senior Vice President, Nuclear Operations of PECO Energy Company; the

' Applicant herein; that he has read the attached License Change Application ECR 99 01255 for Peach Bottom Facility Operating License 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, 1

information and belief, i nior ice 3 resident .

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Subscribed and swom to I before me this /,tY ' day

.,of 1999.

l l yr . Notary Public "x < '

ll Ncnarlal Seal .

Carol A.Walton Notary Putec W 10pire. May

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3 ATTACHMENT 1 PEACH BOTTOM ATOMIC POWER STATION UNIT 3 Docket No. 50-278 License No. DPR-56 l

l LICENSE CHANGE APPLICATION ECR 99-01255 l I

" Revision of SLMCPRs" l I

Supporting Information - 5 Pages l

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Docktt N3. 50-278 4

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1 License No. DPR-56 Introduction  !

PECO Energy Company, Licensee under Facility Or . .ag License DPR-56 for the Peach Bottom Atomic Power Station (PBAPS), Unit 3, requests that the Technical Specifications (TS) contained in Appendix A to the Operating License be amended to: 1) revise TS 2.1.1.2 to  ;

reflect changes in the Safety Limit Minimum Critical Power Ratios (SLMCPRs) due to the use of cycle specific analysis performed by General Electric Nuclear Energy (GENE) for PBAPS, l Unit 3, Cycle 13, 2) delete the cyde specific footnote for the SLMCPRs contained in TS 2.1.1.2

(" Reactor Core SLs"), and delete the cycle specific footnote associated with TS 5.6.5.b.1 (" Core Operating Limits P.eport"), and 3) update a reference contained in TS 5.6.5.b.2 which documents an analytical method used to determine the core operating limits. The TS pages (including 4 marked-up pages) showing the proposed changes are contained in Attachment 2. Attachment 3 (" Additional Information Regarding the Cycle Specific SLMCPR for Peach Bottom 3 Cycle 13," dated June 9,1999) specifies the new SLMCPRs for PBAPS, Unit 3, Cycle 13.

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 Consideration and information supporting an Environmental Assessment.

Discussion and Descriotion of the Proposed Chance The proposed changes involve: 1) revising the Safety Limit Minimum Critical Power Ratio (SLMCPR) values cortained in TS 2.1.1.2 for two and single loop recirculation, 2) deleting the cycle wecific footnote for the SLMCPRs contained in TS 2.1.1.2 (" Reactor Core SLs"), and deleting the footnote associated with TS 5.6.5.b.1 (" Core Operating Limits Report"), and 3) update a reference contained in TS 5.6.5.b.2 which documents an analytical method used to determine the core operating limits.

The SLMCPR is being revised for PBAPS, Unit 3 due to the reload core design for Cycle 13. The SLMCPRs have been determined in accorc'ance with NRC approved methodology described in

" General Electric Standard Application for Reactor Fuel," NEDE-24011-P-A-13 (GESTAR-il), and U.

S. Supplement, NEDE-24011-P-A 13-US, August 1996, and Amendment 25. Amendment 25 provides the methodology for determining the cycle specific MCPR safety limits that repace the former generic fuel type dependent values. Amendment 25 is used for determining the upcoming Cycle 13, and the future SLMCPRs. Future MCPRs determined in accordance with Amendment 25 will not need prior NRC approval for each cycle unless the value changes. The NRC safety evaluation approving Amendment 25 is contained in a letter from the NRC to General Electric, dated March 11,1999 (F. Akstulewicz (NRC) to G. A. Watford (GE), " Acceptance for Referencing of Licensing Topical Reports NEDC-32601P, Methodology and Uncertainties for Safety Limit MCPR Evaluations: NEDC-32694P, Power Distn*bution Uncertainties for Safety Limit MCPR Evaluation; ard Amendment 25 to NEDE-24011-P-A on Cycle Specific Safety Limit MCPR," (TAC Nos. M97490. M99069 and M97491), dated March 11,1999).

Prior to the March 11,1999 NRC evaluation, Amendment 25 was not approved for generic use at each plant, but was approved on a cycle by cycle basis. Therefore, a footnote was added to TS 2.1.1.2 to specify that the approval of the SLMCPR was applicable only for the specific cycle. As a result of the NPC approval of Amendment 25, the footnote to TS 2.1.1.2 can be deleted.

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k Dockst No. 50-278 License No. DPR-56 The footnote contained in TS 5.6.5.b.1 can also be deleted as a resu4 of the approval of Amendment 25. TS 5.6.5.b provides the analytical methods used to determine the core operating limits. . TS 5.6.5.b.1 references the latest approved General Electric Standard Application for Reactor Fuel. Due to the use of the previously proposed Amendment 25, and the use of a then-proposed R-factor calculation methodology ("R-Factor Calculation Method for GE11, GE12, and GE13 Fuel," NEDC-32505P, Revision 1, June 1997), which was not yet approved for generic use_ by the NRC, a footnote was added on page 5.0-21 to TS 5.6.5.b.1 which stated that specific dccuments were approved in the NRC safety evaluation that support

' the license amendment to revise the SLMCPRs. The R-factor methodology was approved in an NRC safety evaluation dated January 11,1999 (Thomas H. Essig (NRC) to Glen A.

Watford (GE), " Acceptance for Referencing of Licensing Topical Report NEDC-32505P, Revision 1, R-Factor Calculation Method for GE11, GE12 and GE13 Fuel," (TAC No. M99070

- and M95081), January 11,1999). As a result of the approval of Amendment 25 and the R-factor calculation methodology, the footnote to TS 5.6.5.b.1 is no longer necessary.

As a part of the proposed changes, a reference contained in TS 5.6.5.b.2 is being updated to reflect a later revision of the analysis.. This analysis, and updated revision, is the " Maximum Extended Load Line Limit and ARTS Improvement Program Analysis for Peach Bottom Atomic Power Station Unit 2 and 3," Revision 2, March 1995 (ARTS /MELLLA). TS 5.6.5.b contains

- the analytical methods used to determine the core operating limits. Revision 1 of th6

' ARTS /MELLLA analysis was updated to Revision 2 to reflect changes in the analysis that were previously approved by the NRC as documented in a safety evaluation report dated August 10,  !

1994 (Amendment No.192 for PBAPS, Unit 2). Revising the Technical Specifications to reflect  ;

- the Revision 2 analysis is an administrative change which will ensure that the references

- contained in the PBAPS Technica' Specifications are accurate and consistent with ottu licensing documents. No technical changes are being proposed in this request as a rewit of the update in the revision.

$3fg.t,v Assessment The proposed TS changes will revise TS 2.1.1.2 to reflect the changes in the SLMCPRs due to

. the cycle specific analysis performed by GENE for PBAPS, Unit 3, Cycle 13. This change also

- proposes to delete the cycle specific footnote for the SLMCPRs contained in TS 2.1.1.2 (" Reactor Core SLs"), and delete the cycle specific footnote associated with TS 5.6.5.b.1 (" Core Operating Limits Report") A reference to an analysis contained in TS 5.6.5.b.2 (" Core Operating Limits Report")is also being updated.

The new SLMCPRs are calculated using NRC approved methodology described in " General Electric Standard Application :or Reactor Fuel," NEDE-24011-P-A-13, and ' .S. Supplement, NEDE-24011-P-A-13-US (GESTAR-il), August 1996, and Amendment 25. Amendment 25 is

used for determining the upcoming Cycle 13 SLMCPRs. Future MCPRs determined in accordance with Amendment 25 will not need prior NRC approval for each cycle unless a value changes. The NRC evaluation approving Amendment 25 is contained in a letter from the NRC to General Electnc, dated March 11,1999.

d The SLMCPRs are set high enough to ensure that greater than 99.9% of all fuel rods in the core avoid transition boiling if the limit is not violato.. Tra MCPRs are calculated to include cycle specific parametars which include: 1) the at teal core roading (GE11 and GE13 fuel), 2) conservative varia'. ions of projected control blade patte,ws, 3) ine actual bundle parameters

' (e.g;, local peaking), and 4) the full cycle exposure range. The new SLMCPRs at PBAPS, Unit 2'

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Dockst No. 50-278 License No. DPR-56 l

3, Cycle 13 are 1.09 (two-loop operation) and 1.11 (single-loop operation) as shown in Attachment 2. Additionalinformation regarding the 1.09 and 1.11 cycle spec!fic SLMCPRs for PBAPS, Unit 3 Cycle 13 is contained in the Attachment 3 letter. l l

The footnotes associated with TS 2.1.1.2' and TS 5.6.5.b.1 are no longer necessary due to the l approval of Amendment 25, and the approval of the R-factor calculation methodology.

- Therefore, these notes are be!ng deleted.

The Revision 1 ARTS /MELLLA analysis contained in TS 5.6.5.b.2 is being updated to a

. Revision 2 analysis to reflect changes that were previously approved by the NRC as documented in the safety evaluation report dated August 10,1994 (Amendment No.102 for

- PBAPS, Unit 2). This is an administrative change which will ensure that the references contained in the PBAPS Technical Specifications are accurate and consistent with other licensing documents.

Information Suooortina a Findino of No Sionificant Hazards Consideration We have concluded that the proposed changes to the PBAPS, Unit 3 TS, which will revise TS 2.1.1.2, 5.6.5.b.1, and 5.6.5.b.2 do 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 proposed TS chances do not involve a sianificant increase in the probability or consecuences of an accident previousiv evaluated.

l The derivatian of the cycle specific SLMCPRs for incorporation into the TS, and its use to determine cycle specific thermal limits, has been performed using the methodology discussed in " General Electric Standard Application for Reactor Fuel," NEDE 24011-P- (

. A-13, and U.S. Supplement, NEDE-24011-P-A-13-US, August 1996, and Amendment i

25. Amendment 25 was approved by the NRC in a March 11,1999 safety eva'uation <

report. This change in SLMCPRs cannot increase the probability or severity of an ,

accident, j The basis of the SLMCPR calculation is to ensure that greater than 99.9% of all fuel l rods in the core avoid transition boiling if the limit is not violated. The new SLMCPRs  !

preserve the existing margin to transition boiling and fuel damage in the event of a

. postulated accident. The fuel licensing acceptance critaria for the SLMCPR calculation apply to PBAPS, Unit 3, Cycle 13 in ine same manner as they have applied previously.

The probability of fuel damage is not increased. Therefore, the proposed TS changes i

do not involve a significant increase in the probability or consequences of an accident '

previously evaluated.

I in addition to the change to the SLMCPR, the footnotes to TS 2.1.1.2 and TS 5.6.5.b.1 )

are being deleted. The footnote associated with TS 2.1.1.2 was originally included to 1 ensure that the SLMCPR value was only applicable for the identified cycle. The i footnote was added to TS 5.6.5.b.1 because Amendment 25 and the R-factor <

calculation methodology were not yet NRC approved. Amendment 25 and the R-factor  ;

methodology have subsequently been approved. Therefore, inese footnotes are no longer i necessary. The foo*. notes were for information only, and have nn impact on the design or operation of the plant. The deletion of the footnotes associated with TS 2.1.1.2 and 3

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Docktt No. 50-278 License No. DPR-56 TS 5.6.5.b.1 is an administrative change that does net involve a significant increase in the probability or consequences of an accident previously evaluated.

The Revision 1 ARTS /MELLLA analysis contained in TS 5.6.5.b.2 is being updated to a Revision 2 analysis, to reflect changes that were previously approved by the NRC as documented in the safety evaluation report dated August 10,1994 (Amendment No.

192 for PBAPS, Unit 2). This is an administrative change which will ensure that the references contained in the PBAPS Technical Specifications are accurate and consistent with other licensing documents. No technical changes are occurring which have not been previously approved by the NRC. Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. The orooosed TS chances do not create the possib,!ity of a new or different kind of accident from any accident previously evaluated.

The SLMCPR is a TS numerical value, designed to ensure that transition boiling does not occur in 99.9% of all fuel rods in the core during the limiting postulated accident.

The new SLMCPRs are calculated using NRC approved methodology discussed in

" General Electric Standard Application for Reactor Fuel," NEDE-24011-P-A-13 (GESTAR-il), and U.S. Supplement, NEDE-24011-P-A-13-US, August 1996, and Amendment 25 The SLMCPR is not an accident initiator, and its revision will not create the possibility of a new or different kind of accident from any accident previously evaluated.

Additionally, this proposed change will delete footnotes contained in TS 2.1.1.2 and TS 5.6.5.b.1 as the result of the NRC approval of analysis associated with Amendment 25 '

and the R-factor methodology. The proposed change also updates the ARTS /MELLLA analysis contained in TS 5.6.5.b.2. This revision contains information which was previously approved by the NRC. Therefore, the deletion of the footnotes associated with TS 2.1.1.2 and TS 5.6.5.b.1, and the updating of the reference contained in TS 5.6.5.b.2 are administrative changes that do not create the possibility of a new or different kind of accident from any previously evaluated.

3. The proposed TS chances do not involve a sionificant reduction in a maro,in of safety.

There is no significant reduction in the margin of safety previously approved by the NRC as a result of: 1) the proposed changes to the SLMCPRs,2) the proposed change that will delete the footnotes to TS 2.1.1.2 and TS 5.6.5.b.1, and 3) updating the reference to the ARTS /MELLLA analysis contained in TS 5.6.5.b.2. The new SLMCPRs are calcu'ated using methodology discussed in " General Electric Standard Applicatica for Reactor Fuel," NEDE-24011-P-A-13 (GESTAR-II), and U.S. Supplement, NEDE-24011-P-A-13-US, August 1996, and Amendment 25. The fuellicensing acceptance criteria for the calculation of the SLMCPR apply to PBAPS, Unit 3 Cycle 13 in the same manner as they have apolied previously. The SLMCFas ensure that greater than 99.9% of all fuel rods in the core will avoid transition boiling if the limit is not violated when all uncertainties are considered, thereby preserving the fuel cladding integnty. Therefore, the proposed TS changes will not involve a significant reduction in the margin of safety previously approved by the NRC.

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Docktt No. 50-278 License No. DPR-56 Additionally, the proposed changes that delete the footnotes to TS 2.1.1.2 and TS 5.6.5.b.1, and update the revision to the ARTS /MELLLA analysis contained in TS 5.6.5.b.2, are administrative changes that will not significantly reduce the margin of

! safety previously approved by the NRC.

10f9Dnation Suonortina an Environmental Assessment i

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An environmental assessment is not required for the proposed changes in the SLMCPR limits l

'since the proposed changes conform to the criteria for " actions elig;b!e for categorical .

exclusion" as specified in 10 CFR 51.22(c)(9). The proposed changes will have no impact on l the environment. The proposed changes do not involve a significant hazards consideration as discussed in the preceding section. The proposed changes do not involve a significa'nt change in the types or significant increase in the amounts of any effluents that may be released offsite.

In addition, the proposed changes do not involve a significant increase in individual or cumulative occupational radiation exposure.

1 Additionally, in accordance with 10 CFR 51.41, a review was performed to determine the impact of the proposed administrative changes that delete the footnotes to TS 2.1.1.2 and TS 5.6.5.b.1, and update the revision to the ARTS /MELLLA analysis contained in TS 5.6.5.b.2, on  ;

the conclusions of the NRC's Final Environmental Statement for PBAPS. The considerations  ;

included in 10 CFR 51.45(b) were used in this review with the following conclusions. Since these changes are administrative only, implementation of the proposed changes has no impact  ;

on the environment. Since there is no impact on the environment, there are no adverse environmental effects that cannot be avoided. Since these changes are administratwe only and have no impact on operation of the facility nor on the environment, there is no value M considering altematives to the proposed changes. Since the operation of the facility is not affected by the proposed changes, there is no impact on the original assessment of the relationship t,etween local short term uses of man's environment and the maintenance and I enhancoment of long-term productivity. Since the operation of the facility is unaffected by the proposed changes, there is no change to the commitment of resource : and therefore, no irreversible nor irretrievable commitment of resources involved.

Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed change to the PBAPS, Unit 3 TS and have concluded that they do not involve en unreviewed safety question, and will not endanger the health and safety of the public.

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