ML20212J975

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Application for Amends to Licenses DPR-44 & DPR-56, Reflecting Proposed Mods to Standby Liquid Control Sys & Revising Pages iv,115,116,117,118,119,120 & 121 to Achieve More Consistency W/Sts
ML20212J975
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 01/22/1987
From: Gallagher J
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20212J965 List:
References
NUDOCS 8701280396
Download: ML20212J975 (24)


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 1

4 i

Edward G. Bauer, Jr.

Eugene J. Bradley 2301 Market Street Philadelphia, Pennsylvania 19101 Attorneys for Philadelphia Electric Company PDR0701280396 870122 P ADOCK 05000277 PDR

. . _ . _~ - __ _.__ , , . _ _ _ . _ _ _ . _ _ _ . _ - . _ _ _ . _ _ . _ . . . _ . . . _ . - _ . . _ _ . _ . . . . . _ . _ _

BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of  :

Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANI  : 50-278 APPLICATION FOR AMENDMENT OF

, FACILITY OPERATING LICENSES i DPR-44 & DPR-56 j Philadelphia Electric Company, Licensee under

! Facility Operating Licenses DPR-44 and DPR-56 for the Peach l Bottom Atomic Station Unit No. 2 and 3, respectively, hereby I

requests that the Technical Specifications contained in Appendix A of the Operating Licenses be amended to reflect proposed modifications to the Standby Liquid Control System (SLCS) and achieve more consistency with Standard Technical Specifications by revising pages iv, 115, 116, 117, 118, 119, 120 and 121. The figures on pages 122 and 123 will be removed and the words "left l blank intentionally" will be inserted for purposes of pagination.

l Material is being placed on page 118, which is presently marked j " intentionally left blank".

l

o o The Licensee proposes to (1) remove Figures 3.4.1 and 3.4.2 because they will no longer be appropriate; (2) establish revised Limiting Conditions for Operation (LCOs) and revised Surveillance Requirements to reflect the new boron solution properties, ensure compliance with 10 CFR Section 50.62(c)(4) and achieve more consistency with the Standard Technical Specifications; and (3) correct some grammatical problems. Also, the appropriate deletions, revisions and additional discussions are proposed to be incorporated into the SLCS Bases to address the new solution properties, and some material considered inappropriate is proposed to be removed fro:n the specifications and the bases.

Pursuant to the requirements of 10 CFR Section 50.62(c)(4), Licensee plans to modify the SLCS as described in Licensee's correspondence dated June 30, 1986 to the Director of the Office of Nuclear Reactor Regulation. The modifications will be completed during the next refuel outages on each unit, scheduled to start in February, 1987 for Unit 2, and October, 1987 for Unit 3.

The existing weight percent versus volume requirement of Technical Specification Figure 3.4.1 is not applicable to the new control solution planned for the SLCS. Therefore, NRC I approval and issuance of this amendment is needed prior to startup of Unit 2 (scheduled start-up: April 24, 1987) following its Reload 7 refuel outage this year. This amendment would not take effect for Unit 3 until after the Unit 3 modification is

a ,

completed, which would be prior to startup following its next refuel outage.

A solution enriched in Boron-10 will replace the presently used control solution. The existing SLCS pumps, piping and instrumentation, including control room alarms, will remain in use with modified instrumentation setpoints to reflect the new solution properties. The tank heater, pump heat tracing and suction piping heat tracing will remain and operate automatically.

I.

SUMMARY

OF PROPOSED REVISIONS:

A. Existing LCO 3.4.A.1 states, "

... the Standby Liquid Control System shall be operable, except as specified in 3.4.B below." It is proposed that the word "below" be removed and the reference to 3.4.B be changed to 3.4.C due to renumbering. LCO 3.4.A.1 is also being renumbered 3.4.A because there is no 3.4.A.2.

Existing LCO 3.4.A.1 states that the SLCS "need not be operable when the reactor is in the Cold Condition and all control rods are fully inserted and Specification 3.3.A is met." Specification 3.3.A specifies the minimum required shutdown reactivity margin. The basis for Specification 3.4.A states "If no more than one operable control rod is withdrawn, the basic shutdown reactivity requirement for the o ,

core is satisfied and the Standby Liquid Control System is not required .... the basic reactivity requirement for the core is the primary determinant of when the Standby Liquid Control System is required." Therefore, it is proposed that Existing LCO 3.4.A.1 (renumbered 3.4.A) be revised to remove the phrase "... and all control rods are fully inserted ..." because it is an unnecessary restriction. The revised LCO states that the SLCS "need not be operable when the reactor is in the Cold Condition and Specification 3.3.A is met."

A grammatical problem in existing LCO 3.4.B.1 is being corrected. Existing LCO 3.4.B.1 states, "...

continued operation permitted provided that ....

It is proposed to insert the words "shall be" to improve the sentence; it would state, "

... continued operation shall be permitted provided that ...."

Existing LCO 3.4.B.1 is being renumbered 3.4.C due to format changes.

B. It is proposed that the requirement to functionally test each pump loop once per month be moved from existing Surveillance Requirement 4.4.A.1 to 4.4.B.3, to "line up" with the location of pump flow rate in the LCO column. Proposed Surveillance Requirement 4.4.B.3 requires that "At least once per month, each pump loop shall be functionally tested by pumping boron solution to the test tank." This requirement differs from the existing requirement, 4.4.A.1, in that the boron solution itself, instead of demineralized water, is pumped. Presently, demineralized water is pumped during the monthly test, in accordance with 4.4.A.1, instead of the boron solution because the boron could precipitate out of solution if left in the pump loop since the pump discharge piping temperature is not always maintained above the saturation temperature of the solution. This is not a concern with the new solution, however, because its caturation temperature is maintained at 43 degrees F or less (as discussed in Section I.D.4 of this Application) which is well below the minimum anticipated ambient and solution temperatures. Consequently, the requirement to flush the system piping with demineralized water after pumping boron solution in existing Surveillance Requirement 4.4.A.2.b is no longer necessary and is being removed.

Section 4.4.A has been renumbered due to the removal of material.

i C. It is proposed that existing Surveillance Requirement 4.4.A.2.b be replaced by proposed Surveillance Requirement 4.4.2.3. Existing Surveillance Requirement 4.4.A.2.b requires that the system be manually initiated, except explosive valves, and

-S-

boron solution be recirculated to the solution tank, and that a " Minimum pump flow rate of 43 gpm against a system head of 1225 psig" be verified at least once per operating cycle. Proposed Surveillance Requirement 4.4.B.3 requires that pump flow rate be checked and recorded at least once per quarter, and that the system be functionally tested by pumping boron solution at least once per month, as compared

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to the existing once per operating cycle requirement.

As discussed in Section I.D.2 of this Application, the value of pump flow rate need not be 43 gpm or greater due to the properties of the new solution. ~

The SLCS can meet its objective and satisfy the requirements of 10 CFR Section 50.62(c)(4) with the new solution at a flow rate of less than 43 gpm as long as the ratio expression of proposed LCO 3.4.A.3 is satisfied.

D. Several of the Surveillance Requirements and the types of LCOs presently contained in the section titled " Sodium Pentaborate Solution", 3.4.C and 4.4.C, are proposed to be placed in a new section titled " Normal System Requirements", 3.4.B and 4.4.B.

Consequently, it is proposed that the existing material in Sections 3.4.C and 4.4.C be removed. The revised LCOs and Surveillance Requirements reflect the new solution properties. The change in format is ,

being proposed to group all of the operability ,

requirements together (equipment and solution). The

] changes are discussed individually below. The

! proposed LCOs and Surveillance Requirements in the new " Normal System Requirements" section ensure that the SLCS is operable, as do existing Specifications j 3.4.C and 4.4.C.

] 1. Presently, LCO 3.4.C.1, by reference to Figure 3.4.1, establishes the volume and sodium pentaborate concentration limits on the control solution to ensure that sufficient Boron-10 is available for injection to meet the system's

, objectives. Similarly, proposed LCO 3.4.B.1 I

establishes the minimum mass of Boron-10 that must be available to meet the system's 1

objectives (including a 25% margin). Proposed Surveillance Requirement 4.4.B.1 requires the mass of Boron-10 to be calculated at least once per month. Proposed Surveillance Requirement

. 4.4.B.5 requires volume to be checked and
recorded at least once per day as currently required by Surveillance Requirement 4.4.C.l.

Proposed Surveillance Requirement 4.4.B.2

, requires sodium pentaborate concentration to be i checked and recorded at least once per month, or

anytime water or Boron is added to the solution, i

j as currently required by Surveillance 1

1 Requirement 4.4.C.3. These proposed i

o Surveillance Requirements, combined with proposed Surveillance Requirement 4.4.B.4 (discussed in Section I.D.3 of this Application) concerning Boron-10 enrichment, provide the data to calculate the mass of Boron-10 in the tank.

2. Proposed LCO 3.4.B.3 establishes an algebraic expression by which operability of the SLCS is determined. Because the new solution is enriched in Boron-10, a new parameter, Boron-10 enrichment, must be considered. The expression contains the three system parameters of concern:

concentration (C), f*cw rate (Q), and enrichment (E). Each of these variables is divided by its corresponding value in the criteria set forth in 10 CFR Section 50.62(c)(4) to form an expression of three ratios. 10 CFR Section 50.62(c)(4) requires a SLCS "with a minimum flow capacity and Boron content equivalent in control capacity to 86 gallons per minute of 13 weight percent sodium pentaborate solution." Natural sodium pentaborate solution is 19.8% atom Boron-10.

Therefore, the expression is a multiple of I

ratios as follows:

I C { Q hf E 13% wt. 'i 19.8% atom

' I86

\ gpm / \

If this product is equal to or greater than 1.0, the SLCS satisfies the criteria of 10 CFR Section 50.62(c)(4). For example, (1) if Q = 50 gpm and C = 9.82% weight, the criteria of 10 CFR Section 50.62(c)(4) is satisfied as long as E is equal to or greater than 45.09% atom, or (2) if Q = 40 gpm and C = 9.15% weight, the criteria of 10 CFR Section 50.62(c)(4) is satisfied as long as E is equal to or greater than 60.49% atom.

Thus, it can be seen that the individual value of C, Q or E does not, alone, determine operability of the SLCS. Rather, these variables must be considered as a group. By using the expression of proposed LCO 3.4.B.3, the conditions of the SLCS can be directly and accurately compared with the criteria of 10 CFR Section 50.62(c)(4).

3. Proposed Surveillance Requirement 4.4.B.4 is being added to ensure that the Boron-10 j enrichment of the solution is known. Proper Boron-10 enrichment is established by mixing stoichiometric quantities of borax and boric acid, both being of known Boron-10 enrichment.

Thorough mixing of the chemicals is ensured by using the " air bubbler" in the tank. Proposed Surveillance Requirement 4.4.B.4 requires that Boron-10 enrichment be calculated following each

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l Boron addition to the solution. A sample will be required to be analyzed subsequently.to provide assurance that the solution was mixed properly and has adequate Boron-10 enrichment.

, This proposed requirement combined with the proposed requirements discussed in Section I.D.1 of this Application (LCO 3.4.B.1, Surveillance Requirements 4.4.B.1, 4.4.B.2 and 4.4.B.5) concerning mass, concentration and volume ensure that sufficient Boron-10 is available to meet the system's objectives.

4. As discussed in Section I.B of this Application, solution saturation temperature is maintained well below normal ambient temperature by not exceeding 9.82 weight percent sodium pentaborate concentration as required by proposed LCO 3.4.B.2. Therefore, existing LCO 3.4.C.2 and Figure 3.4.2 which establish temperature-requirements for the solution are no longer appropriate and can be deleted.
5. The requirement to check and record solution i temperature, existing Surveillance Requirement 4.4.C.2, can be deleted because proposed Surveillance Requirement 4.4.B.2, which requires checking and recording sodium pentaborate f

concentration, assures that the eolution saturation temperature remains below normal

ambient temperature. Also, the requirement, in existing Surveillance Requirement 4.4.C.3, to check and record sodium pentaborate concentration when solution temperature is below the temperature required in Figure 3.4.2 can be deleted because Figure 3.4.2 is being removed and the monitoring of sodium pentaborate concentration is assured by proposed Surveillance Requirement 4.4.B.2.

6. Existing LCO 3.4.B.1 is renumbered 3.4.C and an action statement requiring the reactor to be in Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and a Cold Shutdown Condition within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is being added. Presently, the action statement of existing LCO 3.4.D, which requires the reactor to be in a Cold Shutdown Condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, applies to this specification.
7. It is proposed that the action statement of l existing LCO 3.4.D be revised to be more consistent with the Standard Technical l Specifications for General Electric Boiling Water Reactors, NUREG-0123, Revision 3 (Specification 3.1.5.a). Revised LCO 3.4.D l allows 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for restoring the SLCS to an l operable status before requiring a shutdown, and i

the reactor must be in Hot Shutdown within the 1

l following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. For conservatism, an I

additional restriction not included in the Standard Technical Specifications is also included in LCO 3.4.D; a Cold Shutdown Condition must be achieved within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following Hot Shutdown.

E. It is proposed that existing Surveillance Requirement 4.4.B.1 be removed to be more consistent with the Standard Technical Specifications for General Electric Boiling Water Reactors, NUREG-0123, Revision

3. This Specification requires that "When a component is found to be inoperable, its redundant component shall be demonstrated to be operable immediately and daily thereafter .... Standard Technical Specifications do not require any such accelerated testing for the SLCS. To demonstrate a redundant component operable, it must be temporarily removed from service, thereby eliminating the function of this component entirely. This is not a sensible or safe practice, especially considering that only seven days of reactor operation are permitted if the component is not restored to an operable status (existing LCO 3.4.B.1 and proposed LCO 3.4.C).

II. SAFETY ASSESSMENT The purpose of the SLCS is to provide the capability of bringing the reactor from full power to a cold, xenon-free shutdown condition assuming that none of the withdrawn control rods can be inserted. Prior to the adoption of 10 CFR Section 50.62(c)(4), the Peach Bottom SLCS was designed to meet its objective within 125 minutes or less. As the volume and concentration of the solution varied (within the required region of Figure 3.4.1) so did the time within which the SLCS could meet its objective. 10 CFR Section 50.62(c)(4) effectively requires the SLCS to meet its objective twice as fast. Rather than increase the flow i

rate capacity of the SLCS, a new solution enriched in Boron-10 is being employed because it offers several advantages: (1) required amount of solution in tank is reduced; (2) sodium pentaborate solution concentration is decreased which reduces the saturation temperature below ambient conditions while increasing the quantity of Boron-10; and (3) no major equipment changes are necessary.

To ensure that a sufficient quantity of Boron-10 is available to meet the SLC System's objective of shutting down the reactor, the variable to be monitored is being I

changed from volume of solution to actual mass of Boron-10.

This is being done because it is a more direct approach.

Accordingly, LCO 3.4.A.4 is being added establishing a minimum limit on mass of Boron-10. This quantity of Boron-10 is sufficient to meet the system's objective including

an additional 25% margin to compensate for imperfect mixing in the reactor vessel.

Because the SLCS must now satisfy the requirements of 10 ,

CFR Section 50.62(c)(4), actual pump flow rate must be considered. In addition, Boron-10 enrichment is no longer constant. Therefore, pump flow rate, Boron-10 enrichment and sodium pentaborate concentration must all be considered as a group to determine whether the SLCS satisfies the requirements of 10 CPR Section 50.62(c)(4). Because there are now three variables (instead of two: volume vs.

concentration), a graph can no longer be used. For this reason Figure 3.4.1 has been, in effect, replaced by the algebraic expression of proposed LCO 3.4.A.3 and the required minimum mass of Boron-10 in LCO 3.4.A.4.

Furthermore, it is believed that using an algebraic expression which yields a numeric answer is more accurate than visual judgement of a point on a graph. Satisfying this algebraic expression ensures compliance with the requirements of 10 CFR Section 50.62(c)(4).

The new enriched solution is made by combining natural borax and enriched boric acid in stoichiometric quantities i in demineralized water. Because the borax and enriched boric acid will have known enrichments, the resulting solution has a known enrichment which can be calculated. A l

sample of the solution is then analyzed to verify the calculated enrichment. Because Boron-10 enrichment can only be changed by the addition of chemicals containing i

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Boron, it is only necessary to check Boron-10 enrichment when Boron is added. The volume of solution available is checked daily to provide assurance that an adequate quantity of Boron-10 is maintained in the tank. The SLCS pumps are tested quarterly in accordance with the requirements of the ASME Boiler & Pressure Vessel Code,Section XI, and flow is checked and recorded in accordance with proposed Surveillance Requirement 4.4.B.3 at least once per quarter.

Sodium pentaborate solution concentration will continue to be checked monthly or anytime water or Boron is added, and will be maintained, in accordance with proposed LCO 3.4.B.2, equal to or less than 9.82% weight which corresponds to a solution saturation temperature of 43 degrees F. Therefore, compliance with proposed LCO 3.4.B.2 ensures that solution saturation temperature is maintained

, at or below 43 degrees F. The tank heater, pump heat tracing and pump suction piping heat tracing will automatically operate in the approximate range of 60 to 70 degrees F. The control room SLCS high/ low temperature alarm will have a low setpoint of 55 degrees F. The SLCS area is provided with fresh air heated to 65 degrees F using steam coils operated with a temperature controlled j valve. The heating and ventilation systems are not safety-related, but they do provide a high degree of reliability because of redundancy of key components, such as fans, steam coils and auxiliary boilers. It is, therefore, l

\ _ ._ _ - -. - -

highly unlikely that ambient temperature would fall below the solution saturation temperature. Consequently, the probability of Boron precipitating is very low.

Presently, if the SLCS is inoperable the reactor must be in a Cold Shutdown Condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with no time allowed for correcting the problem, except in the case of redundant components in which case a seven-day allowable out-of-service time is provided. Once the seven-day out-of-service time has elasped, the reactor must be in Cold Shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The Technical Specifications are more restrictive than necessary in that they do not allow time to correct the problem on an inoperable non-redundant component, and immediately put the plant "into" the shutdown action statement. Making the Technical Specifications more consistent with the Standard Technical Specifications provides an allowable out-of-service time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for non-redundant components, and a requirement to be in Hot Shutdown within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (a total of 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />). Presently, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> the reactor must

, be in Cold Shutdown, and during such an orderly shutdown, Hot Shutdown may typically be reached within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. In

.4 ition, as stated in the bases, if no more than one control rod is withdrawn the basic shutdown reactivity requirements for the core are satisfied and the SLCS is not l needed (even though it is still required to be operable by l

l the Technical Specifications for conservatism). The key 1

I __ _ _ _ _ _ _ _ _ _ . _ _ _ __ _ _ . .

concern is, thus, being shutdown, not which shutdown condition (hot or cold) is established.

f I

Removal of Surveillance Requirement 4.4.B.1, which requires accelerated testing of components when its redundant component is inoperable, is an enhancement to safety and consistent with the Standard Technical Specifications.

Accelerated testing of the remaining operable component defeats the purpose of redundancy because the component must be removed from service to be demonstrated operable.

During this period, the function provided by the component being tested (and its redundant component that is inoperable) is lost entirely. Additionally, accelerated testing increases the probability of component failure due to wear. The bases of the Standard Technical Specifications state:

"With redundant pumps and explosive injection valves and with a highly reliable control rod scram system, ,

operation of the reactor is permitted to continue for short periods of time with the system inoperable or for longer periods of time with one of the redundant components inoperable.

Surveillance requirements are established on a frequency that assures a high reliability of the system."

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Standard Technical Specitications require no accelerated testing for the SLCS. Therefore, the revised action statement constitutes a justified and safe change. In addition, the revised LCO goes beyond the Standard Technical Specification requirements by requiring Cold Shutdown to be achieved within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

III. Significant Hazards Consideration Determination:

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 (vii) of a change that involves no significant hazards considerations is "a change to conform a license 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 revisions to the SLCS LCOs and Surveillance Requirements fit this example. Another example (i) of a change that involves no significant hazards considerations is "a purely administrative change to technical specifications: for example, a change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature". The proposed correction of grammatical problems and format changes to the SLCS Specifications fit this example.

Based on the foregoing discussions, it has been determined that operation of Peach Bottom Atomic Power Station Units 2 and 3 in accordance with these proposed revisions to the Technical Specifications does not involve a significant hazards consideration for the following reasons:

i i) The proposed revisions do not involve a significant increase in the probability or consequences of an accident previously evaluated because the SLCS's capability to insert negative reactivity is enhanced by operating it with the new enriched solution. The revised Technical Specifications will ensure a level of SLCS reliability comparable to or superior to that of the existing requirements. The proposed action statements provide time restrictions for shutdown similar in effect to the existing requirements and removal of the accelerated testing requirement is an enhancement to safety.

11) The proposed revisions do not create the possibility of a new or different kind of accident from any accident previously evaluated because operating the SLCS in accordance with the revised Technical Specifications does not adversely impact any previous accident analyses. The enrichment of the SLCS solution and corresponding Technical Specification revisions do not adversely affect any other safety-related systems or the primary coolant system

boundary and, therefore, cannot create a different kind of accident.

iii) The proposed revisions do not involve a significant reduction in a margin of safety because the revised Technical Specifications provide the LCOs and Surveillance Requirements necessary to ensure that the SLCS with the new solution will perform its objective with the same or superior level of reliability. In addition, the new solution will shutdown the reactor approximately twice as quickly as the existing solution, consequently enhancing the plant's capability of responding to an ATWS event.

Removal of the accelerated testing requirement is an enhancement to safety.

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 By b CsVice President

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, h

u v Subscribed and sworn to pd before me thisd day of l >

jab l

I Notary Public f "

MELANIE R. CAMPANELLA Notary Public, Philadelphia, Philadelphia Co.

My Commission Expues February 12,1999

'l

pBAPS Unit 2 LIST OF FIGURES Figure Title Page 1.1-1 APRM Flow Bias Scram Relationship To 16 Normal Operating Conditions 4.1.1 Instrument Test Interval Determination 55 Curves 4.2.2 Probability of System Unavailability 98 Vs. Test Interval 3.4.1 DELETED 122 3.4.2 DELETED 123 3.5.K.1 DELETED 142 3.5.K.2 MCPR Operating Limit vs. Tau, P8X8R fuel 142a 3.5.K.3 Deleted 142b 3.5.1.E Kf Factor Vs. Core Flow 142d 3.5.1.F Deleted 142e 3.5.1.G Deleted 142f 3.5.1.H MAPLHGR Vs. Planar Average Exposure, 142g Unit 2, P 8X8R Fuel, Type P8DRB285, 100 mil channels 3.5.1.I MAPLHGR vs. Planar Average Exposure '

142h Unit 2, P 8X8R Fuel, Type P8DRB284 H, 80 mil & 100 mil channel & 120 mil channels 3.5.1.J MAPLHGR vs. Planar Average Exposure 142i Unit 2, P8X8R and BP8X8R Fuel, Type P8DRB299 and BP8DRB299, 100 mil channels 3.5.1.K MAPLHGR vs. Planar Average Exposure 342j Unit 2, P8X8R Fuel (Gen ric)

I 3.5.1.L MAPLHGR vs. Planar Average Exposure 142k Unit 2, BP8X8R Fuel, Type BP8DRB299H ,

--iv-1 l

. PBAPS UNIT 3 LIST OF FIGURES Figure Title Page 1.1-1 APRM Flow Bias Scram Relationship To Normal 16 Operating Conditions 4.1.1 Instrument Test Interval Determination Curves 55 4.2.2 Probability of System Unavailability vs. Test- 98 Interval 3.4.1 DELETED 122 '

3.4.2 DELETED 123 3.5.k.1 MCPR Operating Limit vs. Tau, LTA 142 3.5 K.2 MCPR Operating Limit vs. Tau, BP/P8X8R Fuel 142a 3.5.1.A DELETED 4

3.5.1.B DELETED 3.5.1.C DELETED 3.5.1.D DELETED 3.5.1.E Kf Factor vs. Core Flow 142d 3.5.1.F DELETED 3.5.1.G DELETED 3.5.1.H MAPLHGR vs. Planar Average Exposure, Unit 3 142g P8X8R Fuel (P8DRB284H) 3.5.1.I MAPLHGR vs. Planar Average Exposure, Unit 3 . 142h

' P8X8R and BP8X8R Fuel (P8DRB299 and BP8DRB299) 3.5.1.J MAPLHGR vs. Planar Average Exposure,~ Unit 3 142i' BP8X8R Fuel (BP8DRB299H) 3.5.1.K MAPLHGR vs. Planar Average Exposure, Unit 3 142j P8X8Q LTA (P8DQB326) 3.6.1 Minimum Temperature for Pressure Tests 164 such as required by Section XI 3.6.2 Minimum Temperature for Mechanical Heatup or 164a Cooldown following Nuclear Shutdown 3.6.3 Minimum Temperature for Core Operation 164b (Criticality) 3.6.4 Transition Temperature Shift vs. Fluence 164c

3.6.5 Thermal Power Limits of Specifications 164d 3.6.F.3, 3.6.F.4, 3.6.F.5, 3.6.F.6 and 3.6.F.7 1

3.8.1 Site Boundary and Effluent' Release Points 216e

, 6.2-1 Management Organization Chart 244 4 6.2-2 Organization for Conduct of Plant Operation 245 I

s l -iv-4 I

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