ML20236B135
| ML20236B135 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/10/1989 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20236B138 | List: |
| References | |
| NUDOCS 8903200364 | |
| Download: ML20236B135 (15) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 (215)8414000 March 10, 1989 l
Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555
SUBJECT:
Peach Bottom Atomic Power Station, Units 2 and 3 Technical Specifications Change Request
Dear Sir:
Philadelphia Electric Company hereby submits Technical Specifications Change Request No. 89-02, in accordance with 10 CFR 50.90, requesting an amendment to the Peach Bottom Unit 2 and Unit 3 Technical Specifications (Appendix A) of Facility Operating License Nos. DPR-44 and DPR-56.
Information supporting this Change Request ~
is contained in Attachment 1 to this letter, and the proposed replacement Technical Specification pages are contained in Attachment 2.
Supportive illustrations are provided in Attachment 3 to this letter.
This submittal requests Technical Specification changes to remove the surveillance requirement to calibrate the SRM and IRM - Detector Not in Startup Position instrument channels at Startup and Control Shutdown.
If you have any questions regarding this matter, please feel free to contact us.
Very truly yours, G. A. Hunger, Jr.
Director Licensing Section 2go K 7
Nuclear Support Division h0dl Attachments
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March 10,-1989' i
'Page 2 f.
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W. T. Russell, Administrator, Region'I,.USNRC T.:P. Johnson, USHRC Senior Resident Inspector R.-E. Martin,.P8APS Project Manager.
T. R. Gerusky, Director, PA Bureau of: Radiological Protection.
T. E.'Magette, State of Maryland J. Urban, Delmarva Power.
J. T. Boettger, Public Service Electric & Gas H. C. Schwem, Atlantic Electric
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W. Gallagher, being first duly sworn,. deposes and says:
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That he is Vice President of Philadelphia' Electric Company,.
that he has read the foregoing Application for Amendment of Facility Operating License 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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L)Vice President
-Subscribed and sworn to before-me this \\S* day naace of -Febraia r+
1989.
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b Notary Public NOTARIAL SEAL JUDITH Y FRANKUN. Notary Public CW of Philadcichia,Phila. County My Commission Expires #y 28,1991 I
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' Docket Nos.'50-277;
' 278 j
License Nos. DPR-44
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x DPR-56 i
L Philadelphia. Electric Company,1 Licensee under' Facility l
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.g Oper'ating Licenses DPR-44 and DPR-56, for the Peach' Bottom Atomic Power Station'(PBAPS) Unit'No. 2'and Unit No. 3,.respectively,.
hereby requests that the Technical Specifications contained in f l Appendix'A'to the Operating, Licenses be amended.. Proposed changes to the Technical Specifications are indicated by the' i
vertical' bars in,the margin of the revised'page 83 contained.in.
g Licensee proposesito revise the Surveillance.
' Requirements'in'Section 4.2.C, specifically Table 4.2.C, Minimum Test and Calibration' Frequency.for Control Rod Block Actuation.
I
.The' proposed changes concern the Source Range Monitor'(SRM) Land'
. Intermediate Range Monitor.(IRM) systems.
The purpose of'the
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. changes is to revise the calibration frequencies for.the SRM -
Detector.Not in Startup Position and IRM - Detector Not in Startup Position instrument channels for control-rod block actuation.
The functional test frequencies for these channels are.not affected by the proposed changes.
The current Surveillance Requirements require calibration of these Instrument channels prior to Startup or Control Shutdown.
The subject i
instrumentation is located inside Containment and not accessible for calibration during power operation.
The revised Surveillance i
Requirements proposed herein are based upon the requirements set forth.in the Standard Technical Specifications for General l
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Docket Nos. 50-277
')
50-278 License Nos.-DPR-44 DPR-56 l
l Electric Boiling Water Reactors, NUREG-0123 and the existing
.TechnicalLSpecifications for'the Limerick Generating Station.
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System Discussion l
Source Range Monitor System.
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True SRM system provides neutron flux information during j
reactor.startup'and low flux level operations.
There are four SRM channels each'of which includes one detector-that can'be i
physically positioned in.the core from the control room.
The
-detectors 1are. inserted into the core for: a. reactor startup and i
may be withdrawn-after neutron flux is. indicated on the IRMs.
j Each detector assembly consists of a miniature fission chamber operated in the pulse counting mode and attached to a low-loss quartz fiber insulated transmission cable.
The detector l
cable is connected underneath the reactor vessel to a triple-l
' shielded coaxial cable.
This shielded cable carries the pulses formed to a pulse current preamplifier located outside the primary containment.
l The detector and cable are located inside the reactor
-vessel in a dry tube sealed against reactor vessel pressure.
A remote controlled detector drive system, as shown in Illustration o.
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, J' Docket Noo, 50-277 50-278 i
License Nos. DPR-44 l
DPR-56 1 of-Attechment 3, can move the detector'along the length of the 1
dry gube allowing vertical positioning of'the chamber'at any I
point from 2 ft above the reactor (fuel): centerline to 2 ft below I
the reactor fuel region.
The detector can be stopped at any location between'the limits of-travel, but only the.end points of l
. travel-are indicated.
When a detector arrives at a travel end i
i point, the detector motion is automatically. stopped..
The detector drive system is located inside the drywell.
A detailed description of the' detector drive mechanism is provided in the section following the discussion'of the IRM system and Control j
Rod. Block Actuations.
Intermediate Range Monitor System The IRM system monitors neutron flux from the upper portion of the SRM range to the lower portion of the' power range monit' ring subsystems.
The IRM system has eight IRM channels, o
each of wnich includes one detector that can be physically positioned in the core by remote control.
The detectors are inserted into the core for a reactor startup and are withdrawn after the reactor mode selector switch is turned to "RUN".
Each detector assembly consists of a miniature fission i
chamber attached to a low-loss, quartz fiber-insulated 1
transmission cable.
The detector cable is connected underneath __ _ - _ _ _ _ _
n.
Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 k
'the reactor vessel to a triple-shielded cable which carries the pulaes generated in the fission chamber through the primary containment to the preamplifier.
The detector and cable are j
. located in the drywell, are movable in the'same manner as the SRM l
detectors, and.use the same type of mechanical drive arrangement.
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Detector Not in Startup Position - Control Rod Block Actuation d~'~ "
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.In addition to providing neutron flux level information, the SRM and IRM systems provide Upscale, Downscale, Detector -
l Not in.Startup Position, and Inoperative signals'to the reactor-li manual control' system to block control rod withdrawal under
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certain conditions.
Any one SRM or IRM channel can initiate a' j
control rod block.
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Wnen the reactor mode switch is in the STARTUP or REFUEL i
position, a control rod block will be. initiated when any SRM j
detector is not fully inserted into the core, when the SRM count I
level is below-the retract permit level, and when any IRM range j
switch is on either of the two lowest ranges.
This control rod j
block assures that no control rod is withdrawn unless all SRM j
detectors are properly inserted when they must be relied upon to provide the operator with neutron flux level information.
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Any IRM detector not fully inserted into the core will also initiate a control rod block when the reactor mode switch is
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Docket Nos. 50-277
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p 50-278 License Nos..DPR-44
.DPR-56'
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In the STARTUP or REFUEL position. 'This rod block actuation assures that no control rod is withdrawn during low neutron flux-level operations unless proper neutron monitoring capability is available.
Detector Drive System The detector insert and retract mechanism positions the in-core detection chamber in the reactor core to monitor neutron
' flux density.
The mechanism allows the detector'to be withdrawn q
from the reactor core after the flux level exceeds the monitoring channel range, thereby prolonging the useful life of the detector.
The detector insert-and-retract mechanism consists of
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.a motor. module, a detector assembly, and a dry tube.
Illustrations of the detector drive mechanism and associated' limit switches are provided in Attachment 3 of this amendment application.
I The motor module consists of~a motor, drive shaft, and limit switch, enclosed in an aluminum housing.
The limit switch, which is chainlinked to the gear motor output shaft, controls the insertion limits (FULL-IN and FULL-OUT) of the detector; the switch also provides outputs to auxiliary relays for indicators in the control room and reactor manual control circuits.
A flexible drive shaft, connected to the output shaft of the motor 4
DocketJNos. 50-277 50-278 License Nos. DPR-44 DPR-56 module,. transmits power to the-gearbox of the detector ' drive assembly.
! Calibration of the Detector Not in Startup. Position.
Instrumentation is_ currently performed as preventive maintenance during each' refueling outage.
The calibration involves' setup of-the motor module limit switches and alignment of the motor' module i
and' detector drive tube.. To set the limit switches, the full-in I
limit switch on the motor module is first arbitrarily set, andi i
the motor module is then operated in the. withdraw mode for the number of rotations corresponding to a 120 inch' stroke.
The
.1 full-out limit switch is then: set.to open at that number of rotations for the 120 inch stroke.
To align the motor module and l
drive tube, the drive tube is-first placed in the full-in
-position and'the motor module is then operated in the insert mode until the full-in limit switch opens..The flexible driveshaft from the motor module is then connected to the gearbox to complete the alignment.
l Description of Changes Surveillance Requirement 4.2.C Control Rod Block Actuation requires " Instrumentation shall be functionally tested, calibrated and checked as indicated in Table 4.2.C."
The existing Table 4.2.C indicates the calibration frequency for the SRM and IHM-Detector Not in Startup Position instrument channels l
e Docket'Nos. 50-277 50-278 License Nos. DPR-44
.DPR-56 y
to be Startup and Control Shutdown.
It'is proposed to delete the words "Startup and Control Shutdown" and replace with "N/A" for these two instrument channels.-
F i
' Safety Discussion l
The existing Surveillance Requirement for control rod block actuation instrumentation requires calibration of the SRM and IRM - Detector Not in Startup Position chann,e.ls. prior to l
Startup and Control Shutdown.
These surveillance requirements have not been met at PBAPS..The non-compliances were discovered on January 20 and 23, 1989 and reported in Licensee Event Report No. 2-89-01. dated February 22, 1989.
Calibration of these instrument ~ channels requires personnel entry into the drywell.
l This action is prohibited by the environment inside containment:
I high temperature, inerted atmosphere, and high radiation levels.
It can be demonstrated that calibration of these instrument l
channels at the existing frequency is not necessary, based upon j
the Standard Technical Specifications for General Electric j
I Boiling Water Reactors NUREG-0123, vendor recommendations, and pant' surveillance history.
Calibration of the SRM and IRM-Detector Not Full In instrument channels has been previously considered by the i
l Commission during development of the Standard Technical Specifications (STS) for General Electric Boiling Water Reactors, l'
'Dockot Nos..50-277 50-278 License Nos. DPR-44 i
DPR-56 l
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Table 4.3.6-1, Control-Rod Withdrawal. Block Instrumentation Surveillance Requirements, of the STS does not require calibration of these instrument channels.
'The Technical l
l Specifications for the Limerick. Generating Station, which uses j.
similar' General' Electric detector drive mechanisms, also does not require calibration of the SRM and IRM - Detector Not Full In instrumentation channels.
The vendor manual, General Electric GEK-13962C, Revision 6,
issued for operation and maintenance of the' detector drive mechanisms installed at Peach Bottom recommends that adjustment j
i of the detector drive be performed at each refueling outage.
I Review.of past surveillance history for the subject instrument channels for the period from 1978 to 1988 indicates the instrumentation to be highly reliable with the "as found" functional conditions remaining consistent over the period.
It is our position that functionally testing the SRM and IRM - Detector Not in Startup Position instrument channels at the frequency required by the existing Technical Specifications adequately assures the operability of the instrument channels.
l The preventive maintenance re-alignment (calibration) performed J
each refueling outage in accordance with vendor recommendations provides adequate assurance of correct instrument calibration.
Safe operation of the plant will not be reduced, by the proposed.
1
Docket Nos. 50-277 i
50-278 License Nos. DPR-44 DPR-56 changes because the SRM and IRM-Detector Not in Startup Position channels are sufficiently reliable and will continue to perform their function to initiate a control rod block when the detectors are not properly inserted.
5 Significant Hazards Consideration Determination The Technical Specification changes proposed herein do not involve significant hazards consideration for the following i
reasons.
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The proposed changes do not involve a significant increase in the probability or consequences of any accident previously evaluated.
The SRM and IRM-Detector Not in Startup Position instrument channels function to initiate a control rod block to assure that no control rod is withdrawn unless the appropriate detectors are properly inserted when
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l they must be relied upon to provide the operator with neutron flux information.
The proposed changes to delete the requirement to calibrate these instrument channels will not affect their ability to perform this function.
The performance of functional tests on the Instrument channels at the existing Technical -
d Docket'Nos.'50-277 j
50-278 j
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License Nos.'DPR-44 f
DPR-56 i
specification frequency adequately assure: the operability:of'the channels.
The preventive maintenance re-alignment (calibration) performed'each refueling
-outage in accordance with vendor recommendations provides adequate assurance of correct instrument 1
calibration.
Past surveillance data indicates that the instrumentation is highly reliable.
The proposed changes-do not affect the analyses of the abnormal
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operational transients and the design basis accidents as presented in Section 14 of the PBAPS-Updated Final Safety Analysis. Report.
The proposed changes do not change the design or operation of the detector systems; therefore, they do not increase the probability or consequences of any accident previously evaluated.
11)- The proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.
The proposed changes to delete the calibration requirement for the SRM and IRM-Detector Not in Startup Position instrument channel do not change the design or i
operation of the detector systems, and, therefore, do l
not create the possibility of a new or different kind of accident from any previously evaluated.
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. Docket Non.50-277.
g.1 50-278 3
' License Nos.D DPR-44:
~ DPR J i
Jiii) The' proposed revisions do not involve a significant.
reduction'in'a margin of safety.
i The. instrument calibration 1 frequency required by the
. existing' Technical Specification is not necessary.as; discussed in the Safety. Discussion.section of this-application.
Performance of the' calibration is~also
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proh1bited during'powercoperation'due to' conditions l'nsidercontainment'.
Preventive maintenance re-alignments :(calibrations) which are performed each refueling outage in accordance with vendor Irecommendations, adequately ensure' proper calibration of:
-theiinstrument channels; therefore, the proposedichanges-do not. involve'a significant reduction in a' margin of-
~ safety.
l Environmental Impact An environmental impact assessment is not required-for the. changes proposed.by this Application because the changes conform to the criteria for " actions eligible for categorical exclusion" as specified in 10 CFR 51.22(c)(9).
The proposed changes do not involve any systems that have a-direct I
relationship with the environment.
The Application involves no 2
significant change in the types or significant increase in the' l-I !
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-Dock'ot-Nos. 50-277!
50-278 License Nos. DPR-44 DPR-56 /
-amount's of.any effluents that may be released offsite, and there i's no significant increase in individual or cumulative
- occupational radiation exposure.
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Conclusion:==
The proposed changes were analyzed and determined to 1
have no effect upon the accident analyses. contained in Section 14-of the PBAPS Updated Final Safety Analysis Report.
In addition, a determination of No'Significant Hazards Consideration was completed.
The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes.to the Technical Specifications and have concluded that they will not
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endanger the health and safety of the public.
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