ML20212J278
| ML20212J278 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 01/20/1987 |
| From: | Bauer E, Bradley E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20212J254 | List: |
| References | |
| NUDOCS 8701280125 | |
| Download: ML20212J278 (15) | |
Text
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i BEFORE THE
/UNITEDSTATESNUCLEARREGULATORYCOMMISSION i
s 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
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Attorneys for Philadelphia Electric Company l
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8701280125 870120 ADOCK05000g7 DR
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 pages 8,
- 145, 217, 219 and 222 as shown by a vertical bar in the margins of the attached pages.
The revisions requested in this submittal involve the following: _
Technical Specification Subject Page 1)
Surveillance Primary Coolant Sample 145 Requirement:
4.6.B.1 Analysis 2)
Definitions:
1.0 Surveillance Frequency 8
of the Diesel Generators 3)
Limiting Conditions Offsite Power 217, 219, for Operation:
3.9.A.1, Supply 222 3.9.B.1 and 3.9.B.2; Bases for 3.9 1)
Technical Specification 4.6.B.1 This Application proposes that the Technical Specifications be revised to require the performance of an isotopic analysis on all additional primary coolant samples required by Specification 4.6.B.1 thereby eliminating the less accurate gross measurements as presently required.
This revision is more conservative than the current requirement and is consistent with the Specification 4.4.5 of Standard Technical Specifications for General Electric Boiling Water Reactors, NUREG-0123, Revision 3.
This Application also proposes that the requirement to perform an isotopic analysis to determine dose equivalent Iodine-131 if the gross measurement exceeds 0.2_uc/gm be deleted because an isotopic analysis will be performed on every sample in accordance with this proposed revision.
Gross measurements, which are presently required by Specification 4.6.B.1, are less accurate than isotopic analyses.
An isotopic analysis, as tell as a gross measurement, has routinely been performed on each sample because an isotopic analysis is more accurate and, in recent years, the introduction of a computerized Germanium counting system has improved the process of isotopic analysis.
Isotopic analyses involve more manipulation of the computer data than gross measurements; however, the additional time required is not significant and is warranted in light of the improved results.
Safety Assessment:
The revision proposes that the more accurate isotopic analysis be performed on each additional sample rather than only those samples which exceed a gross measure of 0.2 uc/gm dose equivalent Iodine-131.
This is a more prudent practice which is consistent with the Standard Technical Specifications.
Revising the Technical Specifications to require this practice improves the Peach Bottom primary coolant chemistry surveillance program.
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Significant Hazards Consideration Determination:
l 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 FR 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."
This proposed revision to Surveillance Requirement 4.6.B.1 fits this example.
The proposed revision does not involve a significant hazards consideration for the following reasons:
i)
The proposed revision does not involve a significant increase in the probability or consequences of an accident previously evaluated because the analysis for dose equivalent Iodine-131 in the primary coolant system is improved by this revision.
Isotopic analyses, which are more accurate than gross measurements, would be performed on all additional samples taken in accordance with the Specification.
ii)
The proposed revision does not create the possibility of a new or different kind of accident from any accident previously evaluated because improving the analysis of samples does not create the possibility of any accident.
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lii)
Th2 proposed revision dons not involve a significant reduction in a margin of safety because the accuracy of the measurements will be increased without affecting the method of acquiring samples, and limiting the Specification to one method of analysis improves the understandability of,-and the likelihood of conformance with the Specification.
2)
Technical Specification 1.0, Definitions This Application also proposes that the definition of surveillance frequency on page 8 be revised by the addition of a paragraph which addresses testing of the diesel generators.. In a telephone conversation on October 25, 1985, the NRC expressed concurrence with a proposal made by the Licensee in a September 12, 1985 letter concerning this revision and recommended that an Application be submitted incorporating the provision into the Technical Specifications.
The need for this change.is demonstrated by the situation described below with regard to testing of the I
diesel generators.
Peach Bottom Unit 2 and Unit 3 Technical Specification 4.9.A.l.b requires that, "once per operating cycle the l
condition under which the diesel generator is required will be simulated and a test conducted to demonstrate that it will start and accept the emergency load within the specified time sequence...."
The frequency for conducting l lu
the test in each Operating License is once par operating cycle.. The intent is to perform the test during an extended unit outage, such as a refueling outage, since.the alignment and exercising of the associated safety-related equipment is not compatible with power operation.
The test at Peach Bottom is normally performed at the conclusion of a re. fueling' outage.- The diesel' generator test required by Specification 4.9.A.l.b was performed for Unit 2 on June 13, 1985 at the end of the pipe replacement outage.
- However, the definition of surveillance frequency in the Technical j
Specifications of each unit limits the operating cycle interval to 18 months (plus 25%).
For an' extended operating cycle, such as the recently completed Unit 3, cycle 6, a shutdown of Unit 3 would have been required before June 26, 1985 for the sole purpose of testing the same diesel generators (which had been tested 13 days earlier for Unit-
- 2) to satisfy the Unit 3 Technical Specifications.
Because j
the diesel generators are equipment common to both units,
-and emergency loads for the units are essentially identical, it was our position that the June 13, 1985 test satisfied i
the surveillance requirement of both units.
i Therefore, this Application requests that the definition of surveillance frequency in the Technical Specifications be clarified to remove any doubt as to the propriety of this interpretation regarding surveillance testing of the diesel generators.
Sefatykneancment:
The proposed change would permit deferral of a surveillance test of the diesel generators, if they had been similarly tested in accordance with the Specification for the other unit.
The change would permit only a deferral of a surveillance test and would not reduce the total number of tests performed because the next surveillance interval will commence at the end of the original specified interval.
Deferral of the testing would avoid the potential for an outage for the sole purpose of performing a test for puristic reasons and, consequently, is in the interest of minimizing reactor thermal cycles and avoiding the costs associated with periods of plant unavailability.
The surveillance schedule for equipment common to a two-unit plant results in doubling the frequency of testing of that equipment compared to the frequency of testing for a single unit plant.
Consequently, the testing frequency, with the change proposed by this Application, would remain in excess of that required for similar equipment at a single unit plant and would ensure testing of the equipment on at least an 18-month cycle.
The proposed change would reduce the need for back-to-back testing to satisfy the Technical Specifications for both units and establish uniform intervals between tests.
Significant Hazards Consideration Determination:
The proposed change does not involve a significant hazards consideration for the following reasons:
i)
The proposed revision does not involve a significant increase in probability or consequences of an accident previously evaluated because the nature and frequency of the surveillance program for the diesel generators ensure the same level of reliability, ii)
The proposed revision does not create the possibility of a new or different kind of accident from any accident previously evaluated because the change deals solely with the scheduling of a surveillance test and does not impact the method or quality of the program.
iii)
The proposed revision does not involve a significant reduction in a margin of safety because the proposed change reduces the potential for a surveillance required outage and the associated reactor vessel cyclic stresses, while retaining a level of surveillance monitoring that ensures acceptable reliability of the diesel generators.
3)
Technical Specifications 3.9.A.1, 3.9.B.1, and 3.9.B.2 During the Unit 3 Cycle 7 refueling outage, a new 230-13 KV transformer was installed between the 230 Kv.
N2wlinville Lina cnd the Unit 3 ctortup regulating switchgear (See Figure 1).
This transformer supplies voltage comparable to the existing Unit 2 and Unit 3 startup transformers.
The transformer was installed with its own load tap changer and can supply proper voltages for any required startup or shutdown conditions.
The new transformer is connected to 230 Kv line number 230-34 through a new circuit switcher.
A 33 KV outdoor circuit breaker was installed on the 13 KV side of the transformer.
The breaker is connected through a new disconnect switch to the existing Unit 3 startup transformer supply cables to the startup regulating switchgear.
Licensee proposes changes to three auxiliary electrical system Technical Specifications and the associated bases to reflect the existence of this new off-site power source as discussed individually in the following sections of this Application.
a)
Technical Specification 3.9.A.1 Licensee proposes to replace the reference to i
l "startup transformers" with "13 KV startup l
l sources".
The Specification will read "Both off-site sources and both 13 Kv startup sources and emergency transformers are available..."
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Changing the reference from the " transformers" l
l to " sources" does not change the intent of the l
l Specification because a startup transformer must
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b2 available to constitute a "cource".
Removal of.the reference to startup transformers, therefore, merely provides the flexibility to use either the original or recently installed Unit 3 startup transformer to constitute one of the two required 13 KV startup sources.
To satisfy the proposed revised Specification for "13 KV startup sources", the Unit 2 startup transformer would still have to be available to provide one source, however, either the original or recently installed Unit 3 startup transformer could be available to provide the other source (See Figure 2).
b)
Technical Specification 3.9.B.1 Licensee proposes that the reference to "one startup transformer" on page 219 be replaced with "both Unit 3 startup transformers, or the Unit 2 startup transformer...."
The intent of the Specification is to ensure that at least one off-site source is available to support the emergency loads for seven days following the loss of one of the two sources.
This revision to the Specification does not alter that intent because the change merely requires both Unit 3 startup transformers to be out-of-service in i 1
order for the Unit 3 startup source to be considered unavailable.
c)
Technical Specification 3.9.B.2 Licensee also proposes that the reference to "both startup transformers" on page 219-be replaced with "all three startup transformers".
The intent of this Specification is to ensure that if both off-site sources are not capable of supporting the emergency loads, reactor power level is reduced to 25% of the design rating.
The proposed revision does not alter that intent-because all three of the startup transformers would have to be unavailable for this situation to arise, in the absence of another failure.
Both emergency transformers being unavailable still constitutes entering the Limiting Condition For Operation of this Specification.
Safety Assessment:
The recently installed transformer supplies voltage comparable to the existing startup transformers and is, thus, a qualified alternate for the existing Unit 3 startup source.
The redundancy in offsite power supply offered by the additional transformer enhances plant reliability and safety.
The revised Technical Specifications merely account for the existence of the
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additional transformer without changing the intent of any of the requirements.
Significant Hazards Consideration Determination:
i)
The proposed revisions do not involve a significant increase in the probability or consequences of an accident previously evaluated because the two Unit 3 startup transformers are available to support the required loads of the engineered safeguards equipment in the event that one fails, thus increasing off-site power supply reliability and reducing the probability and consequences of an accident.
The new Unit 3 startup transformer was chosen and installed to provide voltages in the plant comparable or superior to that of the original transformer.
ii)
The proposed revisions do not create the possibility of a new or different kind of accident from any accident previously evaluated because the electrical power system of the plant and the recent transformer installation were designed so that any failure affecting one source does not propagate to the alternate source.
In addition, each off-site source i
alone is sufficient for safe shutdown by supplying each of the 4 KV emergency buses, and loss of all off-site power has been provided for in the station design.
The diesel generators provide sufficient power to support engineered safeguards equipment for -
one unit and the shutdown of the other, assuming loss of all off-site power and failure of one diesel generator.
iii) -The proposed revisions do not involve a significant reduction in a margin of safety because the recently installed transformer is a qualified alternate for the existing Unit 3 startup transformer, and provides additional redundancy in off-site power supply for the engineered safeguards systems.
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 l
l By
% bJ #_, A Eyce PresiddMt -.
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.
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Subscribed and sworn to 7A before me this 24 day
/7*7
/Mi
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E Notary Public MELANIE R. CAMPANCLLA Notary Public, Phhdelphu, Ph11delphia Co.
My Comrnesnon Empires Ferray 12, Inc
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