ML20210C636
| ML20210C636 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/15/1986 |
| From: | Bauer E, Bradley E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20210C617 | List: |
| References | |
| NUDOCS 8609180389 | |
| Download: ML20210C636 (12) | |
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o BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of-Docket No. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 SECOND AMENDMENT TO JULY 31, 1979 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 8609180389 860915 PDR ADOCK 05000277 p
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e BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket No. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 SECOND AMENDMENT TO JULY 31, 1979 APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 & DPR-56 On July 31, 1979, Philadelphia Electric Company, Licensee under Facility Operating Licenses DPR-44 and DPR-56 for Peach Bottom Units 2 and 3, respectively, filed an Application for Amendment of the licenses which requested that the Technical Specifications contained in Appendix A of the Operating Licenses be amended by making certain changes relating to the large primary containment purge and vent isolation valves.
The requested changes to the Technical Specifications would have limited the use of the large containment purge and vent valves to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per year during those periods when the potential for a i;._..a_ _.
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. design basis Loss-of-Coolant Accident is present.
Subsequently, the NRC,.by correspondence' dated December 12, 1983 (J. F. Stolz, NRC, to E. G.
Bauer, Jr., Philadelphia Electric Company),
requested the licensee to modify the application to incorporate ~
additional containment purging restrictions and to conform to the Standard Technical Specifications attached to the December 12, 1983 letter.
On June 4, 1984, in response to this request, licensee submitted an amendment to the July 31, 1979 Application.
that incorporated the NRC requested changes with some minor revisions to permit the 90-hour purging restriction to be i
averaged between the two units and to carry unused purge time into the following year.
By correspondence dated November 21, 1984 (J. F. Stolz, NRC, to E. G. Bauer, Jr., Philadelphia Electric Company), the NRC
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provided examples of BWR Standard Technical Specifications containing guidance for the 90-hour purging restriction and U-requested the addition of several new specifications for containment isolation valves.
Further clarification was provided by the NRC at a February 26, 1985 meeting in Bethesda, Maryland, f
.and a December 4, 1985 telecon.
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Accordingly, Philadelphia Electric Company, Licensee under Facility Operating Licenses DPR-44 and DPR-56 for Peach Bottom Atomic Power S'tation Units 2 and 3, respectively, hereby
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amends its Application of July 31, 1979, as amended June 4, 1984, H
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by deleting the proposed Technical Specification pages 177, 178, 178a, and 202 referred to in the June 4, 1984 Application, and h
substituting therefor updated pages 177, 178, 178a, and 202, and h l t
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new page 175, which are attached hereto and incorporated herein i
by reference.
Additionally, Licensee requests that the inflatable seal replacement program as proposed in Specification 4.7.E.1 become effective during the first refueling outage commencing six months following issuance of the amendment to permit this activity to be integrated into the outage activities.
Licensee requests that the effective date of the other amendment revisions be deferred up to two months following issuance to
. accommodate revisions to any plant procedures required to implement the amendment.
Proposed revisions to the current Technical Specifications requested in the Application, as amended on June 4, 1984 and by this Amendment, are identified by a vertical bar in the margin.
A discussion of the proposed revisions to the extent that they differ.from.the previous Application, as amended on June 4, 1984, follows.
1.
The proposed Technical Specifications had previously identified "any safety-related reason" as the criteria under which containment purging is authorized.
Licensee was advised by the NRC that the specification should specify precisely what safety-related reasons will permit purging.
The NRC's position, as stated in their b
l November 21, 1984 letter, is that inerting, deinerting, and pressure, control are the three safety-related reasons for purging which require no justification from the licensee.
This Amendment deletes the phrase "any safety-related reason" (previously stated in l
Specification 3.7.E.3 of the June 4, 1984 Amendment) and
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incorporates the NRC criteria into Specification 3.7.E.2.a (page 178).
Additionally, the Bases (page 202) has been revised to provide examples of deinerting and pressurn control so as to enhance the understanding of the specification.
2.
The proposed averaging and carryover provisions for the 90-hour per year purge and vent flow path restrictions (Specification 3.7.E.2.b), as requested in the NRC's November 21, 1984, letter, have been deleted from the i
proposed Technical Specifications.
3.
A typographical error in Specification 4.7.E.2 (page 178) has been corrected in the proposed Technical Specifications.
4.
The proposed Technical-Specifications now includes the valve and penetration numbers for both the. Unit 2 and' Unit 3 flow paths (page 178a) to correct the prior omission of the Unit signations.
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An action statement has been added to the proposed Technical Specification for the reactor instrumentation line excess flow check valves (Specification 3.7.D.3) in j
accordance with the NRC guidance in tb,2 November 21, 1984 letter. ' Additionally, a standard act
- r. statement is incorporated for the containment purg / vent isolrei valve limiting conditions for operation (Specific.4L 3.7.E.3). !
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6.
A cross reference has been added to the Standby Gas Treatment System (SGTS) Limiting Conditions for Operation (Specification 3.7.B.1 on page 175) identifying the operability requirements when purging the' primary containment using the large isolation valves.
This change will identify the operability restraints requested in the NRC's December 12, 1983, letter for the Standby Gas Treatment System in both the SGTS and Purge / Vent Isolation Valve sections of the Technical Specifications.
The change enhances understanding of the operability requirements for the SGTS.
7.
Existing surveillance provisions on pages 177 and 178 I
.have~been renumbered to provide better correlation between the LCOs and surveillance requirements on these 4
pages so as to enhance the understanding of the specifications.
Safety Analysis The changes proposed in this Application, as amended, involve additional operating restrictions and surveillance requirements for primgry containment isolation valves that conform to NRC criteria identified in letters dated December 12, 1983 and November 21, 1984 (J. P.Stolz, NRC, to E. G. Bauer, Jr.,
Philadelphia Electric Company).
These additions impose specifications that (1) limit containment purging using the large L
p primary containment isolation valves to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per year; (2) specify the limiting conditions under which the large primary containment isolation valves may be used for purging; (3) establish minimum Standby Gas Treatment System operability requirements when using the large primary containment isolation valves for containment purging; (4) establish specific action statements in the event the Limiting Conditions for Operation cannot be satisfied for the primary containment isolation valves and reactor instrumentation excess flow check valves; and (5) expand the surveillance and preventive maintenance requirements for the large primary containment isolation valves.
The restrictions imposed by this Application on the opening of the large containment purge / vent valves will limit the period of time that a potential off-site release flow path exists with the reactor at power.
Consequently, the probability that a potential release path exists coincident with a breach of the primary coolant system will be reduced, providing additional assurance that a release of radioactive gases to the environment will be avoided.
Further, the added requirement that a redundant Standby Gas Treatment System (SBGTS) must be available, but not in use, during purge and vent operations, provides additional assurance that gaseous effluents will be filtered prior to release, in the event,that a ventilation exhaust pressure transient following a LOCA event had disabled the other SBGTS train.
Under this accident scenario, the available, but isolated SBGTS train, would be placed in service to replace the disabled train.
Consequently, the integrity of the exhaust system and the J
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filtration' capability of the SBGTS will be assured.
These i
operating restraints further reduce the probability of a gaseous effluent release to the environment during a major accident event.
The action statement proposed will require the plant to be shutdown if these operability requirements for the purge / vent
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valves or SBGTS cannot be met.
The additional action statements for all the primary containment isolation valves and reactor instrumentation excess flow check valves assures that the plant is not operated in a degrade mode of operation.
The action statements prescribe that i
the containment penetration with an inoperable isolation valve either be secured in the isolated condition or the plant shutdown.
In this manner, the capability of isolating containment penetrations, in the event of a breach in the primary coolant system is assured.
The other proposed changes correct typographical errors, improve the format, and add cross references.
These changes improve the ability of plant operators to understand and interpret these specifications and consequently reduce the probability of personnel error.
Significant Hazards Consideration Determination The Commission has provided guidance concerning the r
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 L
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a fii) of actions involving no significant hazards consideration is I
a change that constitutes an additional limitation, restriction or control not. presently included in the Technical l'
Specifications.
The changes proposed by this Application fit this example.
The proposed changes do not constitute a significant hazards consideration, based on the safety analysis
. presented in this Application, and since they do not:-
(1) involve a significant increase in the probability or consegaences of an accident previously evaluated because the proposed changes reduce the proba'oility of an accident occurring simultaneous with open purge and vent valves, thereby reducing the potential for.the release of radioactivi'ty.
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(2) create the possibility of a new or different kind of accident from any accident previously evaluated becauge i
al4 accident scenarios recognize operations with either the igolation valves open or closed.
The proposed change does not establish a new mode of operations for the purge and vent system, only the extent to which the system may be used.
(3)' involve a significant reduction in a margin of safety because the more conservative operability and surveillance requirements reduce the probability of an inoperable valve coincident with a plant transient.
Forther, the new action statements reduces the I
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-probability.that the plant would be operated in violation of the Limiting Conditions for Operations.
The Plant Operating Review Committee and the Nuclear
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Review Board have reviewed the 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
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Vice Presideht b
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-COMMONWEALTH OF PENNSYLVANIA :
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COUNTY OF PHILADELPHIA S. L. Daltroff, being first duly svots, deposed'acc says:
That he is Vice President of Philadelp O A Electric Company, the Applicant herein; that he has tead th*, foiogoing Application for-Amendment of Facility Operatiftg a.lecna.C and knws 1
the contents thereof; and that the statements and mAttern Act forth therein are true and correct to the best of his knoM&geir, j
information and belief.
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Subscribed and sworn to i
1 IA before me this /3 day of Arn AA.
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Notary Public t
l NELANIE R. CAIAPPNCLlA bh4 Mk. Pidade;;e;,, pt,p.e,,vhia Co.
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CEtTIFICATE OF SERVICE I-certify that service of the foregoing Amendment was made upon the-Commontaalth of Pennsylvania, by mailing a copy thereof, via first-class mail, to 1hocas k. Gerusky, Director, Bureau of Radiological Protection, P. O. Box 2063,Narrisburg,PA 17120; all this 15th day of September,1986.
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-Attorney for Philadelphia Electric Company 4
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