ML20236B819

Application for Amends to Licenses DPR-44 & DPR-56,revising Tech Specs to Reflect Changes to Reactpr Water Level Instrumentation Sys.Certificate of Svc Encl

ML20236B819
Person / Time
Site:	Peach Bottom
Issue date:	10/07/1987
From:	Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20236B807	List: ML20236B804 ML20236B819 ML20236B828
References
NUDOCS 8710260366
Download: ML20236B819 (15)

Text

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i BEFORE THE UNITED STATES NUCLEAR' REGULATORY COMMISSION D

l In the Matter'of

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-Docket Nos. 50-277

> PHILADELPHIA ELECTRIC COMPANY 50-278' APPLICATION FOR' AMENDMENT OF FACILITY OPERATING LICENSES 3

'1 DPR-44 DPR-56 y

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l Edward G.

Bauer, Jr.

Eugene J..Bradley.

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1 2301 Market Street-Philadelphia, Pennsylvania 19101 Attorneys for Philadelphia Electric Company R

'l 8710260366'871019 PDR ADOCK 05000277 P

PDR s

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BEFORE THE

, UNITED STATES NUCLEAR REGULATORY COMMISSION

, In the Mat'ter'of

. Docket Nos. 50-277:

PHILADELPHIA ELECTRIC' COMPANY 50-278 T

' APPLICATION FOR AMENDMENT OF l

FACILITY OPERATING-LICENSES

.I DPR-44

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DRP-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 an amendment to the Technical Specifications contained 1

in Appendix A to.the Operating Licenses as. indicated by a bar in the margin of the attached page 77.

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The proposed changes to the Technical Specifications are

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related to modifications being made.to the Reactor. Water. Level Instrumentation System.

The modifications are being made in i 1 l

p response to NRC Generic Letter 84-23, Reactor Vessel Water Level Instrumentation in BWRs, and Post-TMI Requirements from NUREG-0737, Item II.F.2, " Instrumentation for Detection of Inadequate Core Cooling".

A previous amendment' request filed October 1986, which also proposes changes to this table, is pending.

The pending

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amendment request is not affected by this proposal.

Discussion - Category (1)

)

The Category (1) Change Requests involve increasing the I

recorder ranges of the. fuel zone and wide range reacter vessel i

level instrumentation.

These ranges are specified in the Technical Specifications solely as a means of identifying the recorders which are addressed.

These Change Requests would i

reflect the instrument ranges as they are being modified on both I

i units.

The proposed changes are listed below.

Section of Table 3.2.F Affected Proposed Changes 1

(1) Reactor Water Level Change the Recorder range from (wide range)

(-165" to +50) to I

(-165 to +60 inches).

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(2) Reactor Water Level Change the Recorder range from l

(fuel zone range)

(-325" to 0") to 1

(-325 to +60 inches).

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The new ranges encompass the original ranges.

The upper j

endpoints have been raised to +60 inches for both recorders, and j

j match the upper endpoint for the narrow range instrumentation.

j The lower endpoints have not been altered.

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Safety Significance - Category (1)

Category (1) consists of Change. Requests which request

enlarging.the wide l range and fuel zone' reactor water'1evel

' recorder ranges,. described on Table 3.2.F, to reflect plant modifications.

The affected ranges envelope the ranges currently.

specified by the. Technical. Specification, therefore, the operators' monitoring capability of the' reactor water level is not adversely impacted.

The instrumentation, whichlis part of the modification, provides the same safety. actuation functions at

.the same levels as the previous equipment.

Consequently, expanding the recorders' ranges does not impact their safety H

functions.

4 Modifying the recorders by increasing their scales to a common endpoint incorporates human factors principles, as well as practical operating' considerations.

The modification also provides on-scale indication of reactor water level during high level or normal operating conditions, as weil as the lower level ranges for which the instruments are designed.

This on-scale indication gives the operator confidence in the. indications which would result during an accident condition,.thereby providing consistency with NUREG 0737, Supplement 1 guidelines.

The Updated Final Safety Analysis Report (UFSAR) contains analyses of the four design basis accidents:

the Control Rod Drop Accident,-the Loss of Coolant Accident, the Refueling Accident and the Main Steam Line Break.

These 1 l 1

1 recorders provide information to the operator during normal operation, as well as emergency situations.

The Technical Specification, Table 3.2.F, provides the operator with.

descriptions of these instruments for identification during normal operations as well as emergency situations.

The accident I

analyses from the UFSAR do not take credit for operator action during the event.

Amending the table to accurately reflect the instrumentation will not affect the accident precursors, initial conditions, assumptions, sequences-of-events, or results of these accidents, as described in the UFSAR.

j It has been concluded that these Change Requests will i

improve Technical Specification Table 3.2.F, and will not adversely impact plant safety.

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1 Significant Hazards Consideration'- Category (1)-

The Commission has provided guidance concerning'the application of the standards for dete'rmining whether license.

amendments. involve no significant hazards considerations'by

.providing certain examples-(51 FR 7751)..One of the examples of actions involving no significant hazards consideration occurs when "The-repaired or. replacement component or system does not

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result-in a significant change in its safety function or a significant reduction in any safety: limit (or limiting condition of operation)' associated-with the component or system."

The 1

Category (1) Change Requests fit-this exampleoof anHaction not i

involving a significant hazards consideration, since the increased ranges of the recorder do not impact the accuracy of the vessel level inputs required for Emergency Core Cooling System (ECCS) initiations.

The Category-(l) Change Requests also fit another example of'an action not involving'a significant hazards consideration, an administrative change to the Technical Specifications.

61nce these ranges are listed solely as a means of instrument identification, amending the Table to reflect a plant modification fits the definition.of administrative.

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l Operation of the plant under the proposed Technical Specification

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would not:-

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(1)

Involve a significant inc'rease in the p'robability or the consequences of an accident previously evaluated.

The ranges of these, reactor water level recorders are wider than the previous ranges and includeLthe-

-upper and lower' range' limits previou' sly specified I

'in the T'echnical: Specifications.

The new range-I

upper. limits 1will' match the upper limit of the

. narrow range measurement and will. provide redundant Measurements and indication to +60. inches level.

The ranges ~are specified solely for the purpose of instrumentation identificam n.

The four design basis accidents described in the Updated' Final Safety Analysis Report are: the l

Control Rod Drop Accident, the Loss of Coolant Accident, Refueling Accident and the. Main Steam d

Line Break.

Amending Technical Specification Table 3.2.F to. reflect the larger recorder ranges which are being installed will not affect the accident precursors, initial conditions, assumptions, or sequences-of-events of these accidents, as j

I described'in the UFSAR.

It is concluded that the l

i probability-or' consequences of an accident 1

previously evaluated will not be increased by the implementation of these Change Requests.,

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OR (2)

Create the possibility of a new or different kind of accident from any accident previously evaluated.

i These Change Requests reflect the increaseL n the the range of the reactor water level recorders for the wide-range and the fuel-zone range level measurements which simply encompass the previous upper and lower range limits.

The limits are l

specified on Table 3.2.F, solely as a method of identifying the instrument.

Therefore, the possibility of a new or different kind of accident i

from any accident previously evaluated is not created.

I OR (3)

Involve a significant reduction in the margin of safety.

The recorder range changes associated with this modification will provide the operator with wile-range and fuel-zone range recorder upper limits j

which correspond to the upper range limit of the i

i narrow-range recorder.

This will provide the operator with a higher level of confidence when using these recorders.

The measurement accuracy is within the limits required by the previous range, and therefore a reduction in the margin of' safety is not involved.

Discussion - Category (2) 4 The Category (2) Change Requests are administrative in l

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nature, and incorporate human factors considerations into the instrument ranges presented on Table 3.2.F.

-The proposed changes are listed below.

Section of Table 3.2.F Affected Proposed Changes l

(3) Reactor Water Level Change the Recorder and Indicator (narrow range) ranges from (0-60") to (0 to 60 inches).

(4) Reactor Pressure Change Recorder range from (0-1500 psig) to (0 to 1500 psig).

Change the Indicator range from (0-1200 psig) to (0 to 1200 psig).

(5) Drywell Pressure Change the Recorder range from (0-70 psig) i to (0 to 70 psig).

i (6) Drywell Pressure Change the Recorder range from (wide range)

(0-225 psig) to l

(0 to 225 psig).

(7) Drywell Pressure Change the Recorder range from (Subatmospheric range)

(5-25 psia) to (5 to 25 psia).

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1 (8) Drywell Temperature

' Change the Recorder'and j

Indicator ranges from (0-400 degrees'F) ton (0 to_400 degrees F).

(9) Suppression Chamber Change'the Recorder and Indicator

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Water Temperature ranges from (30-230 degrees F).to (30 tol230 degrees F).

(10)' Suppression Chamber Change the Recorder and Indicator Water Level ranges.from (0-2 ft.) to (narrow range)

-(0 to 2 feet).

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Change Request (3) proposes that.the dashes in the ranges be replaced'by the' word "to",

and.that " inches" be spelled out, rather'than symbolized.

Change Requests-(4) through ~ (10),

also: propose ' that the ranges include ' the. word "to" rather than use a dash.

Change Request (10) additionally' requests that the I

abbreviation "ft" be spelled out to'" feet".

These changes will alleviate confusion with regard to

" dash" and "minus", since two of the ranges include negative j

values.

These changes'will provide consistency 'nd clarity for a

l the parameters included on the table.

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Safety Significance - Category (2) j l

1 Although Change Requests (3) thru (10) propose revisions to the reactor water level, reactor pressure, drywell pressures, drywell temperature, supression chamber water temperature, and l

supression chamber water level recorder and indicator ranges, these Change Requests do not alter the ranges or the instruments 6

themselves.

The ranges are specified solely as a.means of identifying the instrument which was described.

The format of I

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Table 3.2.F will be improved by employing these Category (2) 3 l

Change Requests.

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t The Updated Final Safety Analysis Report (UFSAR)

I contains analyses of the four design basis accidents: the Control Rod Drop Accident, the Loss of Coolant Accident, the Refueling Accident and the Main Steam Line Break.

The Category (2) Change Requests do not affect the accident precursors, initial l

. conditions, assumptions, sequences-of-events, or results of these accidents, as described in the UFSAR.

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It has been concluded that the administrative nature of these Change Requests do not affect the content of Table 3.2 F, plant parameters or instrumentation, and therefore, do not impact plant safety.

1 Significant Hazards Considerations - Category (2) q A second example of a change involving no significant hazards consideration, as stated in 51 FR 7751 is:

"a purely i

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administrative change to the Technical Specifications".

The Change Requests contained in Category (2) conform to this example, since they are changes in the format of the table.

Operation of the plant under the proposed Technical Specification would not:

(1)

Involve a significant increase in the probability or consequences of an accident previously evaluated. - _ - _ ________-_-__-

t x -

These Change: Requests do not involve modification

.to the; plant,'or' changes to the way~in which plant operation'is conducted.

.These Change Requests will not: affect therinstrumentation type or ranges 1

described on1 Table 3.2.F.-

The four design basis acciden'ts described.in the Updated Final Safety Analysis Report are: 'the Control Rod Drop Accident,-the Loss of. Coolant Accident, the' Refueling Accident,.and'the Main Steam Line Break. 'The administrative nature.of

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.this~categoryfof" Change 7 Requests'does not' impact the precursors, initial conditions, assumptions, or-sequences of events of these accidents.

It is, therefore, concluded that the probability or consequences of an accident previously evaluated will not be increased by the' implementation of these change requests.

OR (2)

Create the possibility of a.new or different kind of accident from any accident previously evaluated.

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i These Change Requests do not alter the' content or.

intent of the table, the ranges or the I

instrumentation.

These Change Requests alter only the form of the table.

.The spellings of abbreviations and replacing symbols.with words will j

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1 1-1 not create the possibility of,new or-different kind ~

-f of accident from'any accident previously evaluated..

OR,

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-(3)J Involve a1significant reduction in a' margin of

' safety.

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'The. proposed changesLimprove the clarity.of the l

Table.. Since these Change l Requests do not alter

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testing. action'or operating requirements of the y

i plant and incorporate : human factors principles-into t'he 'f ormat' of ' t'he L Table, the margin of safety'is.

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1 enhanced.

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Conclusion l

1 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'unreviewed safety questions or involve Significant; i

Hazards Considerations, and will not endanger the health.and safety of the public.

Respectfully submitte'd, t

PHILADELPHIA ELECTRIC. COMPANY h

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Vice~ President -,

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COMMONWEALTH OF PENNSYLVANIA

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' COUNTY.'OF PHILADELPHIA

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-J. W..Gallagher,-being first duly' sworn, deposes and says:

q That he is Vice. President of Philadelphia.Electr!c' Company,

the Applicant herein; that he has read the foregoing Application.

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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.

b G Vice President l

Subscribed.and sworn-to before me this f ay d

of Oct - 1987 ri NJJ1 YAcaA0 L/

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Notary Public-d IN -

JUDITH Notary Public, Co.d<p

,3 My Commiwon Evneras i

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I Certificate of Service i

i hereby certify that copies of the foregoing Application were served on the following by deposit in the linited States mail, first-class postage prepaid, on this 19th day of October, 1987.

Regional Administrator U.S. Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406 T.

P.

Johnson, Resident Inspector U.S. Nuclear Regulatory Commission Peach Bottom Atomic Power Station P.

O.

Box 399 Delta, PA 17314 Mr. Thomas Gerusky, Director Bureau of Radiation Protection j

De artment of Environmental Resources Fulton Bank Building, 5th F11or Third 6 Locust Streets Harrisburg, PA 17120 f

b "4 i

Eug he J4 Bradley Attorney for Philadelphia Electric Company h

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