ML20210U407

Application for Amends to Licenses DPR-44 & DPR-56,changing Setpoints of Main Steam Line Radiation Monitors

ML20210U407
Person / Time
Site:	Peach Bottom
Issue date:	02/12/1987
From:	Bauer E, Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20210U404	List: ML20210U400 ML20210U407 ML20210U450
References
NUDOCS 8702180472
Download: ML20210U407 (14)

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 I

0702100472 070212 PDR ADOCK 05000267 PDR j

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l 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 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 sections as indicated by a vertical bar in the margin of the attached pages 37, 38, 40, 48, 61, 62, 63 and 90.

The requested changes involve increasing the setpoint of the Main Steam Line Radiation Monitors from 3 times normal full power background (NFPB) to 15 times NFPB (without Hydrogen Water' Chemistry).

The j

setpoint change is being requested to support a planned Hydrogen l

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' Water Chemistry program.

Additional' changes are also requested-to clarify Tables 3.1.1 and 3.2.A.

Discussion: -

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1.

Philadelphia Electric Company is developing a Hydrogen Water; 4

Chemistry (HWC) program to improve reactor water chemistry 4

at Peach Bottom Units 2 and 3.-

The purpose of the program j

is to reduce the effects of Intergranular Stress Corrosion-l Cracking (IGSCC).

j Intergranular Stress Corrosion Cracking of austenitic stainless steel piping in BWRs has resulted in-costly plant outages to accommodate inspections and repairs to_ primary-l coolant system piping and components.. Hydrogen. Water Chemistry, which consists of the combination of good water j

chemistry and the addition of hydrogen'to the feedwater, has l

been shown to be effective in arresting pipe cracking and pipe crack growth.

Addition of hydrogen decreases the oxidizing power of the reactor water and reduces its aggressiveness toward coolant system materials.

A by product of the oxygen suppression by hydrogen addition t

i is an increase in nitrogen carry-over in the main steam and an increase in radiation from the main steam lines caused by Nitrogen-16 (N-16).

The increase in N-16 is promoted by the chemical change that occurs in the reactor core with hydrogen addition.

The N-16 isotope is formed by a neutron-l

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.o proton reaction with the Oxygen-16 (0-16) in_the reactor

-water.

Under-_ normal chemistry conditions the majority of the N-16 forms nitrate, which-is nonvolatile.

With the more reducing core chemistry conditions of Hydrogen Water Chemistry, a greater fraction of the N-16 forms volatile compounds (ammonia, nitrous oxide) which are; swept into the steam phase.

The revised trip setpoint will permit Hydrogen Water.

-Chemistry implementation, while maintaining the capability to scram the reactor in the event of significant fuel failures.

The change will not affect the ability to detect fuel failures because the steam jet. air ejector. discharge radiation monitor (which is more sensitive to fuel' failures than the Main Steam Line Radiation Monitor and which is not affected by this change), will retain the capability to detect fuel failures and alert the plant staff.

The proposed setpoint increase to 15 times NFPB (without HWC) is intended to provide operational flexibility while avoiding unnecessary scrams.

The factor of 15 was determined to be necessary in order to provide a margin for the increased radiation levels due to Hydrogen Water Chemistry and the design of the radiation monitors.

An increase in main steam line radiation levels of as much as 5 times is possible due to Hydrogen Water Chemistry.

The current setpoint of 3 provides a margin for normal meter indication fluctuation.

The factor of 15 times NF/B t

(without'HWC) was obtained.by multiplying'the factor of 5 by 3

the current setpoint of 3. times NFPB.

l The attached Technical ~ Specification pages 38, 48, 61 and 90 indicate the proposed change involving the increase of"the trip setpoint of'the main steam line radiation monitors from

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3 times NFPB to 15 times NFPB (without HWC).

i Currently, Note 8 of Table.3.'2.A of the Technical l

Specifications requires the Main Steam Line Radiation Monitor alarm setpoint to be set at 1.5 times NFPB.

At a i

j setpoint of 1.5 times NFPB, the alarm would be up 1

l continuously during Hydrogen Water-Chemistry' implementation.

Since the alarm setpoint has no safety-related function, it is proposed that this limitation be removed to. permit the i

alarm setpoint to be adjusted based on operating experience.

The attached Technical Specification page 63 indicates the proposed change involving deletion of the requirement to set i

the Main Steam Line Radiation Monitor alarm setpoint at 1.5 i

times NFPB.

1 Because changes to the Bases on page 48 are being requested in this Amendment Application, Licensee proposes to correct an error in the Bases on page 48 involving the air ejector 4

i off-gas monitors.

The Bases state that " Discharge'of 1

i excessive amounts of radioactivity to the site environs is prevented by the air ejector off gas monitors which cause an i

j isolation of the main condenser off-gas line".

By Amendment I

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Nos. 102 and 104 to Operating Licenses for Peach Bottom Units 2 and 3, respectively, the air ejector off-gas 1

monitors isolation trip features were deleted from the Technical Specifications.

The change was one of many changes approved by these amendments to establish

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consistency in the Peach Bottom Technical Specifications with the Radiological Effluent Standard Technical Specifications.

The same amendments deleted one of the references in the Bases (page 92) to these off-gas monitor i

trips to reflect the change to the operability l

specifications.

However, we inadvertently neglected to e

request deletion of the other reference to this system (page 48).

The attached Technical Specification page 48 has been corrected to resolve this discrepancy.

2.

Licensee proposes deletion of an obsolete note from the Technical Specifications involving a one-time only hydrogen injection test performed at Peach Bottom Unit 3.

The test 4

was performed to determine the feasibility of Hydrogen Water i

Chemistry.

The note to be deleted is Note 14 of Table 3.1.1 (Unit 3 only).

This same note had also appeared previously I

as Note 10 of Table 3.2.A (Unit 3 only).

Although Note 10 i

has since been deleted from the notes to Table 3.2.A, the referenced number (10) still appears in Table 3.2.A on page 61 (Unit 3 only).

Licensee proposes to delete this reference number (10) from Table 3.2.A on page 61 (Unit 3 only), since this reference is now meaningless.

The l

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attached Technical' Specification pages 38, 40 and 61 (Unit 3 i

only) indicate.the proposed change ~ involving deletion of the obsolete note.

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3.

In order to improve the claritylof Table 3.1.1, a new column-

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has been added to the proposed' Table 3.1.1.

The new column

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provides a number for each of'the seventeen items identified in Table 3.1.1.

The addition of this column will provide an easy reference method for the parameters in the table.

The i

addition of this column is shown on attached Technical Specification pages 37 and 38.

l 4.

In order to improve the clarity of Table 3.2.A, a new-column-has been added to the proposed Table 3.2.A.

The new column provides a number for each of the twelve items identified,in-i i

Table 3.2.A.

The addition of this column will provide an-i easy reference method for the parameters in the table..The addition of this column is shown on attached Technical Specification pages 61 and 62.

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Safety Assessment:

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4 The safety function of the Main Steam Line Radiation Monitors is to detect the radiation increase in the event of a Control Rod Drop Accident (CRDA) and to close the Main Steam j

Isolation Valves (MSIVs) and shutdown the reactor on high radiation levels.

The closure of the MSIVs reduces the release of radioactive fission products to the environment.

For the i

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CRDA, the calculated dose rate at the monitors is 55 rem /hr.

Because the calculated dose rate of 55 rem /hr is approximately 4 times the proposed setpoint, the monitors will maintain the capability to close the MSIVs and scram the reactor on high radiation caused by the design basis Control Rod Drop Accident.

1 The analysis in the UFSAR, Section 14.6.2.5, assumes that the MSIVs receive an automatic closure signal 0.5 seconds after the released activity from the CRDA reaches the monitors.

Although the monitors will still isolate the MSIVs, the time f

required to reach the trip setpoint.is increased.

This delay in reaching the proposed setpoint of 15 times NFPB (without HWC) remains within the 0.5 seconds assumed for the instrument loop response time.

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The capability to monitor for fuel failures is not l

affected by this change.

The Main Steam Line Radiation Monitor's operating detection range is not changed.

The Steam Jet Air-l Ejector Discharge Radiation Monitor, which is more sensitive to fuel failures than the Main Steam Line Radiation Monitor, is not affected by this change and will be capable of alerting the plant staff to the existence of minor fuel failures which could be i

present below the proposed trip setpoint.

The remaining changes proposed in this Amendment 4

Application are of an administrative nature only.

These changes involve the addition of item numbers in Tables 3.1.1 and 3.2.A in i

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order to provide an easy reference method, and the correction.of an. error in the Bases on page 48.

Significant Hazards Consideration:

The proposed amendment involving the increase of.the trip setpoint and deleting the alarm setpoint of the Main Steam l

Line Radiation Monitors does not represent a_significant hazards

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consideration because operation of Peach Bottom Atomic Power Station with this change does not:

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i) involve a significant increase in the probability or consequences of an accident previously evaluated.

The consequences of the design' basis Control Rod Drop Accident, which takes credit for the operation of the Main Steam Line Radiation Monitors,-are not.

i significantly affected by this change since the i

expected radiation release will. remain within the bounds of the UFSAR control rod drop accident j

analysis.

No other previously analyzed accidents or-i malfunctions, as addressed in the UFSAR, are involved.

11) create the possibility of a new or different kind of i

j accident from any previously evaluated.

This

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modification merely adjusts the trip and alarm setpoints on the Main Steam Line Radiation Monitors; 1

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H no.other station instruments or equipment are

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involve a significant reduction in the margin of safety.

The Control Rod Drop Accident is the only accident which' takes-credit for the operation of the Main Steam Line Radiation Monitors.

The change-in..the trip setpoint for the Main Steam Line Radiation l

Monitors does not significantly affect _the i

consequences of the Control Rod Drop Accident.since radiation release estimates for the accident do not change as a result'of this modification from those t

evaluated in the UFSAR.

The cnange offers significant benefits that enhance the-margin of safety by reducing the potential for inadvertent scrams.

3 The~ proposed amendment involving deletion of Note 14 l

of Table 3.1.1 and the reference to Note 10 of Table 3.2.A of the Unit 3 Technical Specifications (Hydrogen Injection: Testing) does not represent a significant hazards consideration because operation of Peach Bottom Unit 3 with this change does not:

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r 1) involve a significant increase in the probability or consequences of an accident previously evaluated.

This change is merely an administrative change involving deletion of an obsolete note from the 4

i Technical Specifications.

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11) create the possibility of a new or different kind of accident from any previously evaluated.

This change is merely an administrative change involving deletion of an obsolete note from the Technical Specifications.

iii) involve a significant reduction'in the margin of safety.

This change is merely an administrative change involving deletion of an obsolete note from the Technical Specifications.

The proposed changes to Tables 3.1.1 and 3.2.A which i

add item numbers to the tables do not:

i) involve a significant increase in the probability or consequences of an accident previously evaluated because the additions are simply administrative changes designed to enhance the Technical Specifications.

11) create the possibility of a new or different kind of l

accident from any accident previously evaluated becauce the additions are simply administrative changes designed to enhance the Technical t

Specifications.

i lii) involve a significant reduction in a margin of safety because the additions are simply administrative 1 -

1 1

changes designed to enhance the Technical 4

Specifications.

l The Commission has provided guidance concerning the

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application of the standards for determining whether a significant hazards consideration exists by providing certain examples (51 FR 7751).

One of the examples of an amendment i

considered not likely to involve a significant hazards l

l consideration is a change which may result in some increase'to the consequences of a previously analyzed accident, b'ut where the i

results of the change are clearly within all acceptable criteria.

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The proposed change involving increasing the trip'setpoint and

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deleting the alarm setpoint of the Main Steam Line Radiation l

Monitors is similar to this example because the change will j

affect slightly the response time of the radiation monitors to the Control Rod Drop Accident, but the change in response time'is very small and the accident's consequences will remain within the bounds of those described in the UFSAR.

j A second example of an amendment considered not'likely to involve a significant hazards consideration is a purely

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administrative change to the Technical Specifications.

The i

l proposed change involving deletion of the hydrogen injection testing note in Table 3.1.1 and Table 3.2.A of the Unit 3 i

Technical Specifications conforms to this example.

The note is l

now obsolete since it was only used to administratively control a one-time only test.

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1 The proposed changes to Tables 3.1.1 and 3.2.A'which add item numbers to the tables also fit this second example of an action not involving a significant hazards consideration because they are intended to enhance the Technical Specifications by providing an easy reference method for the items specified in Tables 3.1.1 and 3.2.A.

The Plant Operations 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 By C/Vice President COMMONWEALTH OF PENNSYLVANIA a

ss.

COUNTY OF PHILADELPHIA i

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.

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subscribed and sworn to before me thisit day efFa.,1987 i !O IMAa+lk

//

N' Notary Public JUDITH Y. FRANKLIN i

Notary P.

. Ph;fa. Co.

My Commission Expires July 28.1987

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