ML20096G752

Application for Amend to Licenses DPR-44 & DPR-56,consisting of TSs Change Request 92-02,re Frequency of Inspecting & Replacing MSSVs & Rvs from Every Refuel Outage to 24-month Testing Interval

ML20096G752
Person / Time
Site:	Peach Bottom
Issue date:	05/18/1992
From:	Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20096G753	List: ML20096G752 ML20096G760
References
NUDOCS 9205260245
Download: ML20096G752 (8)

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PillLADEl.I'lilA El.ECTRIC COMi%NY NUCLEAR GROUP HEADQUARTERS 955-65 CHESTERDROOK IILVD.

WAYNE, l'A 19087-3691 (215) 640-6000 NUCLEAN ENGINEERING & St.RVICES DEPAirTMENT 10 CFR 50.90 May 18, 1992 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 U.S. Nuclear Regulatory Commission Attn: Dccument Control Desk Washington,- C 2055L

SUBJECT:

Peach Bottom Atomic Power Station, Units 2 and 3 Technical Specifications Change Request 92-02

Dear Sir:

Philadelphia Electric Company (PEco) hereby submits Technical Specifications Change Request (TSCR) No. 92-02, in j

accordance with 10 CFR 50.90, requesting a change to Appendix A of the Peach Bottom Facility Operating Licenses. The proposed changes concern extending the frequency of inspecting and replacing the r

Main Steam Safety Valves (SV) and Relief Valves (RV) from every

. refuel outage to a 24' month testing interval (i.e., a maximum of 30 months accounting for the allowable grace period). This change is being requested to support a change to a 24 month fuel cycle at Peach Bottom. To analyze the offacts of the change to a 24 month fuel cycle the guidelines propagated in NRC Generic Letter 91-04,

" Changes In Technical Specitication Surveillance Intervals to Ace:ommodate a 24 - Month - Fuel Cycle" were f ollowed.

As discussed in our February 11, 1992 letter (D. R.

Helwig to USNRC)-additional requests will be u bmitted to address all of the offects of a 24 month fuel-cycle; L wever, because of -

the impact on operations and outage scheduling at Peach Bottom we are' requesting that this change be reviewed and approved-by September 1992.

Attachment I to this letter describes the proposed changes, and provides justification for the changes. Attachment 2 contains the revised Technical Specification pages.

9205260245 920518 PDR ADOCK 05000277 A ng/

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U .$ , Nuclear llegulatory Commission May 18, 1992 TSCR 892-02 Page 2 l .

If you hrve any questions regarding this matter, please contact us.

Very truly yours, h g.[ d OL

/G . J. Beck, Manager Licensing Section

Enclosures:

Affidavit, Attachment 1, Attachment 2 cc: T. T. Martin, Adlainistrator, Region I, USNRC J. J. Lya6h, USNRC Senior Resident Inspector, PBAPS W. P. Dornsife Commonwealth of Pennsylvania 1

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COUNTY OF CHESTER  :

D. R. Helwig, being first duly sworn, deposes and says  !

That he is Vice_ President of e.iladelphia Electric Company; a

the Applicant herein; that he has read the attached Technical Specifications Change Request (Number 92-02) for Peach Bottom Facility _ Operating Licenses DPR-44 and DPR-56, and knows the contents'thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, i

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ATTACilMENT 1 >

PEAC11 BOTTOM ' ATOMIC POWER STATION UNITS 2 AND 3-I Docket Nos. 50-277-  !

50-278 License Nos. DPR-44 DPR-56.

TECl!NICAL SPECIFICATION CHANGE REQUEST 92-02 l

" Change to the Frequency of Main Steam Safety and Rollof Valve Inspections and Tests" l

Supporting Information for Changes 4 Pages t

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Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 Philadelphia Electric Company (PECo), Licensee under Facility Operating Licenses DPR-44 and DPR-56 for the Peach Bottom Atomic Power Station (PBAPS) Unit No. 2 and Unit No. 3, respectively,

, requests that the Technical Specifications contained in Appendix A to the Operating Licenses be amended. Proposed changes to the Technical Specifications are indicated by vertical bars in the margin of page 147. The proposed revised page 147 for each unit are included in Attachment 2.

The proposed changes are being requested to support changing the fuel cycle at PBAPS from 18 to 24 months. In reviewing the effects of this change PECo made a conservative assumption that

- aurveillance frequencies defined as either " REFUEL OUTAGE" or "OFERATING CYCLE" were to be considered as an 18 month interval with a 25 percent grace period. In completing the analysis of the ,

l effects of changing to a 24 month cycle with a 25 percent grace period it became apparent that some changes would have a much more

. severe impact on operations and outage planning than others. The  ;

impact of this determination was discussed in our February 11, 1992 .

letter (D. R. Helwig to USNRC) and as discussed in that letter these changes were identified and labelled as PRIORITY I changes.  ;

This request includes the single PRIORITY I change identified at PBAPO. Additional offects are being evaluated and a change request which addresses those changes will be submitted by July 1992. The

- original schedule submitted in the February 11, 1992 letter i indicated that_these additional change requests would be submitted in June; however, that schedule has now been extended to July of i 1992. This change request should be considered a single change and we are. requesting that this change be reviewed and approved by September 30, 1992. This date is'being requested bt.ause the subject TS requirements have a significant impact on outage scheduling.

Description of Changes (1) The Licensee proposes a change to Section 4.6.D of the <

PBAPS TS. _This section defines the inspection and testing requirements of the Main Steam Line Safety (SV) and Relief Valves (RV). The SVs and RVs are installed at PBAPS to prevent overpressurization of the reactor coolant precsure boundary. All RVs can be manually operatod for depressurization. Five of the RVs have the additional safety-function of automatically depressurizing the reactor to permit the Low Pressure Coolant Injection (LPCI) and Core Spray-(CS) systems to

operate. In this Automatic Depressurization System (ADS) modo the five.RVs provide a backup to the High Pressure Coolant Injection (HPCI) system.  ;

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Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 The testing of the SV and RV provides assurance that if required these valves will be able to perform their design function. The current TS Section 4.6.D requires j that at least one safety valve and 5 relief valves be '

checked or replaced with bench tested relief valvos once  :

per operating cycle. The RV and SV are required to meet  !

a TS set pressure acceptance criteria of plus or mit.us one (1) percent. For performing the historical review ,

, recommended by Generic Letter (GL) 91-04 those previous tests in which the valve failed the TS limit were  ;

considered as failures. The proposed section 4.6.D will read:

"At least one safety valve and 5 relief valves shall  :

be-checked or replaced with bench checked valves  !

every 24 months. All valves will be tested every two_ cycles." (emphasis added)

L The reference to testing all valves every two cycles was reviewed under a 10 CFR 50.59 evaluation. It was ,

determined that it .is acceptable to test all valves every 54 months - two 24 month operating cycles with a single 6 month grace period. It should be noted that the reference to "two cycles" in the quoted section of TS is being interpreted as an 18 month fuel cycle. This  ;

interpretation is consistent wJth the current definition section of PBAPS TS. This and.all other references to

" cycles" will continue to be interpreted as an 18 month cycle unt.11 all of the effects of changing the def.inition  !

of cycle to 24 months have been evaluated and approved.  ;

(2) The Licensee proposes a change to Section 4.6.D.2 of the

! PBAPS TS. This section defines the-frequency to l- disassemble and LLspect a relief valve. This l survell]ance requirement is meant to detect possible deteriorations that could affect relief valve performa' O. The current Section 4.6,0.2 requires at least onu relief valve be disassembled and inspected each .

refueling outage. The proposed TS 4.6.D.2 will read:

L "At least one of the relief valves shall be L disassembled and inspected every 24 months" r l

[emphak > added)

Safety Discussion  !

l The NRC GL 91-04 provided guidelines for dctermining the safety impact of a change required to go to a 24 month fuel cycle. As recommended by the GL, PEco evaluated the- ,

effect on safety of the change in surveillances intervals  ;

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Docket Nos. 50-277 50-270 License Nos. DPR-44 DPR-56 to accommodate a 24 month fuel cycle. This evaluation concluded that this proposed amendment does nots (1) involve a significant jncrease in the probability or

! consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of i accident from any accident pt. 'tously evaluated; or (3) involve a significant reductic in a margin of safety.

, From this determination it was concluded that the effect on safety is small. In addition, PEco confirmod that the historical maintenance and survoillance data support this conclusion. F

, Specifically, the historical data is summarized below.

I Change Request (1)  ;

i A review of the ST documentation identified that a total of 6 SV tests and 30 RV tests were performed since 1987; ,

when as found data was first taken or recorded. A review of the as found data did not identify any time based failure mechanism; therefore, PECo has concluded that extending the surveillanco frequency for this TS requironent will not have an adverse effect on safety.

Change Request (2)

A review of the Surveillance test documentation identifjed that at least 9 RV disassemblies and inspections were performed for the two unitu since 1982 with no documented problems. Therefore, PECo has concluded that extending the surveillance frequency for this TS requirement will not have an adverse affect on ,

safety.

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o Significant flazards Consideration The two change requests proposed in this Application do not constitute a significant hazards consideration in that:

1) The proposed' changes do not involve a significant increase in the-probability or consequences of an ,

accident previously_ evaluated because the availability and response of the valvtv b the event of an accident is unchanged. The changes;beihy proposed do not change any of the accident precursors; therefore, the probability of an accident remains the same. The e:va11 ability of the valves to mitigate the consequences of an accident remain essentially the same. Any change in the possibility of a failure in these valves due to less frequent testing is insignificant given that the surveillance history does l not indicate any time based failure mechanism.

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Docket Nos. 50-377 '

50-270 License Nos. DPR-44  ;

DPR-56

11) The proposed;,,c,har1ges__do not create the possibility of a new or different kind of accident from any previously evaluatej because the proposed change does not make any  ;

physical changes to the plant and the extension of the '

surveillance intervn1 will not introduce any new failure mechaniums. No phy changes to the plant are being made as a roralt o.  ; request; therefore, no new accident initiators precursors are being introduced.

The only change being proposed is an extension of an existing survaillance test for the Main Steam SV and RV, The existing evaluation for PBAPS has already considered  !

the failure ot a MS RV. The extended operating time does not introduco any new accidents scenarios.

iii)-The proposed changes do not involve a significant reduction _in a margin of safety because the proposed ,

= surveillance frequency is adequate to detect SV/RV failures or aeteriorations. It can be concluded that an increase in the interval to reflect a 24 month operating cycle will have a negligible impact on the margin of safety. The ability to detect a failure or deterioration

~1n the1 performance of SV and RV is essentially unchanged by extending the surveillance frequency; therefore, the

, likelihood that these valves are available to perform their design functions is the same and the margin of safety provided by those valves is essentially unchanged.

Information Supporting _an Environmental Assessment i

AnTenvironmentaliimpact assessment .ts not required for the changes -

l proposedLby this Application because the changes conform to the criteria for " actions eligible for categorical exclusion" as

=specified in 10 CPR 51.22(c)(9). The proposed changes do not .

- involve a significant-hazards consideration as discussed in the preceding-section, The: proposed changes do not involve--a >

significant change in the types or significant increase in the amounts of any effluents that may be released offsite. In addition, the proposed changes do not involve an increase in the individual or cumulative occupational radiation exposure. ,

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Conclusion ,

The-Plant _ Operations-Review committee and--the Nuclear Review Board have-reviewed.these proposed changes and have concluded that they

- do not involve an unreviewed safety question and are not a threat to the health and safety of the_public.

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