ML19332A781

Application for Amend of Licenses DPR-44 & 56 Changing Tech Specs 3.2.F,4.2.F,6.2-2,6.3-6.5,6.14 & 6.15 in Response to TMI Lessons Learned Task Force Category a Requirements. Certificate of Svc Encl

ML19332A781
Person / Time
Site:	Peach Bottom
Issue date:	09/15/1980
From:	Bauer E, Bradley E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML19332A779	List: ML19332A778 ML19332A781 ML19332A787
References
RTR-NUREG-0578, RTR-NUREG-578 NUDOCS 8009180316
Download: ML19332A781 (8)

Text

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• BEFORE Tile UNITED STATES fiUCLEAR REGULATORY COMf!ISSION In the Matter of  :

Docket Nos. 50-277 PilIL ADELPIII A ELECTRIC COMPAf;Y  : 50-278 t

APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 6 DPR-56 Edward G. Bauer, Jr.

Eugene J. Bradley 2301 Market Street Philadelphia, Pennsylvania 19101 Attorneys for Philadelphia Electric Company u

n BEFORE Tile UNITED STATES UUCLEAR REGULATORY C0llflIS S ION In the }!a t t e r o f  :

Docket Nos. 50-277 PIIILADELPill A ELECTRIC C0!!PANY  : 50-273 3

APPLICATI0h FOR A5!END!!ENT OF FACILITY OPERATING LICENSES DPR-44 6 UPR-56 Philadelphia Electric Company, Licensee under Facility Operating Licenses JPR-44 and DPR-56 for Peach Botton Units 2 and 3,

hereby requests that the Technical Specifications contained in Appendix A'of the Operating Licenses be amended by revising certain sections as indicated by a vertical bar in the margin of attached pages 77, 78, 86, 245, and 246, and by the addition of page 263.

Correspondence from Mr. D. G. Eisenhut, Director, Division of Licensing, NRC, to All Boiling Water Reactor Licensees, dated July 2, 1980, requested the Licensee to submit a license amendment application incorporating certain Tf!I Lessons

Learne,d Category'"A" requirements. These requirements involve water level instrumentation, safety-relief valve position

, indication, diverse containment isolation valve signals, Shift Technical Advisor, system integrity measurement program, and iodine measurement capability. A model Technical Specifications accompanied the July 2, 1980 letter for the stated purposa of providing guidance in the Licenace's preparation of the amendment application.

The letter from Mr. D. C. Eisenhut requests a Table of Containment Isolation Valves which reflect the current diverse isolation signal design. The Licensee committed to adding additional containment isolation valves, and adding autountic isolation signals to existing valves in correspondence from S. L.

Daltroff to H. R. Denton, dated January 2, 1980. The modifications involve containment isolation capabilities associated with the Radioactive Gas Sample line and the Instrument Nitrogen suction line. Accordingly, the Licensee submitted an amendment application on July 16, 1980, requesting that the containment isolation valve tables 3.7.1, page 180, and 3.7.4, pages 186 and 187, be revised to reflect these modifications. The previous amendment application should provide a satisfactory response on this request and is therefore not repeated in this amendment application.

Appendix A to the Peach Botton Operating License, page 86, currently specifies surveillance requirements for the reactor water level instrumentation that is more conservative than the guidance provided in the July 2, 1980 letter and is therefore

7 left unchanged. It o u e v e r , the Licensee requests a revision to Table 3.2.F, page 77 and 78 to bring the operability requirements for the reactor water Icvel instrumentation into agrecuent with the NRC guidelines presented in the July 2, 1980 letter.

The July 2, 1980 le t t er f rom tir. Eisenhut identified main steam safety relief valve position instruuentation operability and surveillance requirements. The Peach Botton main steam systen has eleven saf ty/ relief valves and two safety valveu per unit. Each valve is lastrumented uith a primary (acoustics) and backup (thermocouple) position detector. The Licensee proposes unnthly instrument checks for both the priuary (acoustic) and the backup (thermocouple) position detectors and once per operating cycle calibration of the primary (acoustic) position detectors.

Thernocouple accuracy is not necessary for its application as a backup valve position detector due to the large increuental temperature increase associated with an open safety / relief or safety valve. Therefore, the Licensec proposes that the nurveillance requirenent for the backup (thermocouple) valve position detector be limited to a monthly instrument check and an instrument functional test once per operating cycle. The instrument functional test verifies that the thermocouple sensor responds to rising temperature.

The flodel Technical S pecifica tions require a plant shutdoun in the event that one of the twenty six safety relief j and safety valvo position detectors per unit is determined to be i I

inoperable. The Licensee believes that this requirement is excessively stringent in view of the minical safety significance

-of unavu11 ability.of these detectors, and the potentially significant adverse inpact of this requircuent on plant availability. The safety significance of the safety / relief valve and safety valve position detectors is minimal for the following reanonn:

'1. The reliability and perforaance of the sa f et y/relie f and nafety valves to independent of the operability of the valve position detectors.

2. There are many other indications of an open valve, in addition to the valve position detectors, which include the following neasured parancters: torus water temperature, torus water level,-and drywell pressure and temperature.

3. A stuck open safety / relief valve is not an event of great 31gnificance in the nWR Design as demonstrated by many reactor years of experience. A stuck open valve condition has essentially no effect on f orced or na tural circulation capabilitten. Their dischar;;en are piped to tne containment n u p p rien n i o n pool. Because of the submerged discharge, high containment pressure and temperatures are avoided, and coolant inventory conserved.

4. A atuck open safety valve will cause a rapid rise in containment pressure, promptly causing a scram and ECOS initiation. The effect of a stuck-open valve is identical to a nma11 main stcau 1Ine break. The operator han no capability of atteupting to re-seat a stuck open safety valve from the control room and his actions would be identical to those for a main stean line break.

Accordingly, the Licensee proposes, based on the above rationale, to limit the. amendment to surveillance requirements of the safety / relief and' safety valves as shown on the accompanying page 86 ofothe Technical Specifications.

The Shift Technical Advisor staffing requirements are uhown on page 245 and 246 and are consistent with NUREG 0578, TM1-2 Lessons Learned Requirements.

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i e e Adminiatrative requirements regarding system integrity measurement program, and iodine acasurenent capability are presented On the accompanying page 263.

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Pursuant to 10 CPR 170.22, " Schedule of Fees for Facility _ License Anenduents", Philadelphia Electric Company

- proposes that this Application for Amendnent be considered a Class III Amendment for Unit 2, and a Class I Amendment for Unit l 3, since the proposed changes are deemed not to involve a i

significant hazards consideration.

The Plant Operation P.eview Comnittee and the Operation and Safety 1:eview C o n nai t t e e have reviewed these proposed changes to the Technical Specifications, and have concluded that they do not involve an unrevieued safety question or a significant hazard i

l consideration; and will not endanger the health and safety of the pubile.

i l

Respectfully submitted, Senior Vice PresfAent f

I.

i Collt!O t; Ul: A LTl! OF PEtitiS Y LV AN I A  :

ss.

COUNTY OF P it I L A D E I. P III A  :

V. S. Boyer, being first duly sworn, deposes and says:

That he is Senior Vic,e President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing Application for Anendment of Pacility Operating Licenses and knows the contents thereof; and that the s t a t e ra c n t s and maLLera set forth therein are true and correct to the best of his knowledge, information and belief.

7h if T.uhscribed and sworn to before me this ll day of -

W. _

f J4 L ry Pu bli.:

.tv E IZAOCTH H Ci *R No Public, Phila , i ; a. Lo.

t asion Expiros Jan. 30,1932 a

e CERTIFICATE OF SERVICE I certify that service of the foregoing Application was made upon the ilo a r d of Supervisors, Peach Bottou Township, York County, Pennsylvania, by mailing a copy thereof, via first-class sa a i l , to Albert R. Steele, Chairman of the Board of Supervisors,

!! . D. No. 1, Delta, Pennsylvania 17314; upon the Board of

upervinorn, Fulton Townnhlp, l.ancaster County, Pennsylvania, by mailing a copy thereof, via first-class mail, to George K.

lirinton, Chairman of the lloard of Supervisors, Peach B o t t o ia ,

Pennsylvania 17563; and upon the Board of Supervisors, Drumore Township, I.ancanter County, P e c. n n y l v a n i a , by nalling a copy thereof, via first-class mail, to Wilmer P. Bolton, Chairman of the 11o a r d of Supervisors, R. D. No. 1, !! o l t w o o d , Pen.asy}vania 17532; all this 15th day of September, 1980 Eu,ene J. BrJ[Iley At orney for Philadelphia Electric Company