ML20006C422
| ML20006C422 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 01/30/1990 |
| From: | PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20006C421 | List: |
| References | |
| NUDOCS 9002080010 | |
| Download: ML20006C422 (24) | |
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ATTACMENT 1 PEACH BOTTON ATONIC POWER STATION ;
UNITS 2 AND 3 i
Docket Nos. 50-277 ,
50-278 ,
License Nos. DPR-44 i DPR-56 TECHNICAL SFECIFICATIONS CHANGE REQUEST !
No. 89-17 >
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'Ellainst4on of Accelerated Testing Requirements for Core and Containment Cooling S3 stems" -
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i Ckok),hy7 l PDC
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- Docket Nos, 50-277 i j' , 50-278 j i
License Nos. DPR-44 j DPR-56 SECTION A
Introduction:
i Licensee proposes, in SECTION B, that the requirements in Technical Specifications Section 4.5, " Core and Containment Cooling Systems Surveillance Requirements," to demonstrate that other cooling systems are operable after one cr more cooling systems are made or found to be inoperable be eliminated. These
. requirements are hereafter referred to as " accelerated testing" requirements.
Licensee proposes miscellaneous Technical Specifications administrative changes, ,
in SECTION C. Licensee proposes, in SECTION D, changes to Section 3.5 of the :
Technical Specifications to clarify the operability requirements of high pressure core cooling system,, Pages 59, 120, 125, 126, 128, 128a, 128b, 129, 130, 131, 134, 335, 126, 138, 139, 141, 205, 209, F10, 214, 216a-1, 216a-S.
240t, 254, 256, and 257 (contained in Attnhuent 2) would change as a recu'It of the proposed license amendment. The material on page 125a would be reloct'.e4 to .
A page 125, ar4 page 1254 would be deleted.
SECTION B J Description of Changes:
Currently, Peach Bottom Technical Specifications require that certain redundant core and containment cooling systems or subsystems be demonstrated to be operable (tested) during time periods when one or more core and containment cooling system or subsystem is inoperable. This application proposes that these accelerated testing requirements be eliminated. Instead, the redundant systems or subsystems will be verified to be operable by administrative 1y checking
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License Nos. DPR-44 DPR-56 i equipment status relative to operability requirements. Justification for this change is provided in the following sections of this application.
i Table 1A sunniarizes the accelerated testing requirements that Licensee i
seeks to eliminate. The Technical Specifications Sections listed in the right-hand column of the table would be deleted. The following acronyms are used in Table 1A and throughout this application:
CS - Core Spray (low pressure) i LPCI - Low Pressure Coolant Injection HPSW - High Pressure Service Water HPCI - High Pressure Coolant Injection (steam turbine driven)
RCIC - Reactor Core Isolation Cooling (steam turbine driven)
ADS - Automatic Depressurization System ECCS - Emergency Core Cooling Systems: CS, LPCI, HPCI and ADS .
Corresponding chenges to the Bues for Sections 3.5 and 4.S are also ,
Proposed to % move references to accelerated te'; ting, 6nd W clarih, on page lz 141, hw mundant sy$ttas can be " verified" to br operable when one or more caoling system is nade or found to be inoperabic. Addftionally, the reference to " quantitative reliability ana'iysis", on page 141, is being dr.leted because !
the ane. lysis was performed prior to initial plant licensing (1973- 574) and has t
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not been updated. Operat.ional experience since that time has demonstrated the acceptability of current testing intervals, as discussed further in this application, and it is no longer appropriate to cite the former reliability analysis as a basis for the testing intervals.
Attachment 2 contains the revised Technical Specification pages with i
bars in the page margins denoting changes.
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. . Docket N:s. 50-277 ,
50-278 License Nos. DPR-44
- DPR-56 I Background and Precedents for Changes:
I Peach Bottw
- Power Station Technical Specification surveillance testing requirements were established in the early 1970s when there was a lack cf nuclear plant operating history on which to base the requirements. ;
Consequently, the frequency of testing was established in a most conservative 5 fashion, and testing of operable systems during periods when a redundant system '
cr subsystem was not available was considered prudent. This was thought to be I the best way to provide confidence that systems would perform their design i function if called upon; however, the industry's perspective has changed. l Accelerated testing is no longer considered necessary to assure operability of l systemt, rather, routine testing of these systems h sufficient to assure a high ,
level of reliability and availability. Mditionally, the fact that one system ,
becomes inoperable is not alone n reason to question the operability of other systems. The nature of and cause for each condition cf inoperability should be individually evaluated to identify generic implications, if any, and then to determine whetner testing cf other systems h warranted. +
This change in perspective has been reflected in the NRC's " Standard Technical Specifications for General Electric Boiling Water Reactors (BWR/5)",
NUREG-0123 Rev. 3, which do not require accelerated testing of core and containment cooling systems. The NRC Region I Integrated Assessment Team InspectionReport(No. 50-277;278/89-81) dated March 6, 1989 states on page 81 that "...the TS for ECCS and DGs are outdated in that they require testing of systems when one component / subsystem is declared inoperable...This type of
,~ a . Dock t Nos. 50-277
testing is undesirable since it is excessive." Generic Letter 87-09 concerning ;
the applicability of Standard Technical Specifications limiting conditions for i i
operation and surveillance requirements contains a NRC Staff Position which is j applicable to the change requested herein. This Staff Position is on page 4 of Enclosure 1 to Generic Letter 87-09 and it addresses the significance of {
l surveillances not performed within the required time frame. The Staff Position ;
states: "It is overly conservative to assume that systems or components are inoperable when a surveillance requirement has not been performed. The opposite is in fact the case; the vast majority of surveillances demonstrate that systems 1
cr components in fact are operable..." 1 The NRC has licensed many facilities without accelerated tasting requirements fw core and contaitement cooling systems, including Philadelphia Electric Company's Limerick Generaling StaWn Units 1 and 2. Alse. the NRC issued L1 cense kn:ndment Hos. 107/102(datedAugust 10,1989) to CommonwewIth ;
Edison to remove mergency core crolir.g systems accelerated tastPng requiremnts ,
from the Pres-Jen Unit 2 and Unli. 3 Technical Specifications. The Dresden unitt '
are General Electric Type 4g GWRs with Mark I containments, as are both Peach Bott m units.
Safety Assessment: ,
This Technical Specification change would delete testing requirements '
which are not necessary to provide confidence that systems are operabic because (1) routine surveillance testing provides assurance of a high level of reliability, (2) Peach Bottom's routine surveillances are substantially e , - - - - ,, , -
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equivalent to those of Standard Technical Specifications. (3) accelerated tests l do not contribute any additional benefit over that provided by ASME Section XI !
testing required by 10 CFR 50.55a and other routine surveillance testing, and I i
(4) for the reasons discussed below accelerated testing could actually decrease ;
the availability of systems.
Each time a system is operated it is vulnerable to damage from human error or unpredictable plant operating occurrences, and there is always the possibility that the system will not be restore <l to the fully " stand-by" condition following test completion. Each test conducted causes component wear l and cyclic stresses on materials, which can increase the frequency of failures and increase the frequency or duration of system outeges for maintenance work, i Furthermore, when tested, systems are often lined up such that they are vulnerabl4 to failure modes to which they ere not vulnerable in their n9rmal ;
standby cotulition. Thus, lining up the redunJant systes for accelerated testing- l creates tne risk of this redundant system also falling, and in some cases the potent tal fathre of the redundant system is related to the test itself end not :
tcn Indication that the system would bwe failed if it had been necded. i The performance of accelerated tests is a burden on the operations, '
technical support and maintenance staffs. The require:aents for accelerated testing are a disincentive for removing systems from service to perform preventive maintenance that could result in a net increase in system ,
availability. Accelerated tests are required at times when the staffs' attention and resources would be more appropriately focused on resolving the problemthatbroughtabouttheneedforthetesting(orimplementingmore
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beneficialcompensatorymeasures)especiallysincethegreatmajorityof accelerated tests are completed with satisfactory results. A review of Unit 2 l
and 3 ECCS, RCIC and HPSW accelerated test results for approximately the past eight years revealed that, on the average, the system or subsystem passed the '
test 98% of the time. Several of the systems and subsystems did not fail an accelerated test during the entire period.
A review of the routine surveillance testing requirements in the Peach Bottom Technical Specifications has confirmed that Peach Botton's core and containment cooling systems are being tested at a level consistent with Standard Technical Specifications. This provides adequate assurance that the systems will be operable when required. Monthly pump and motor-operated valve cperability tests are required by Peach Botton Technical Specifications in addition to the quarterly (tSNE Section XI trsts required by Standard Technical l
Specifications. For each Surveillance floquirement in Sections 4.5.1 (ECCS).
4.7.1.1 (Residual Heat Removal Sm'vice Water) and 4.).4 (RC'C) of NUREG-0123 Rev. 3. a similar or equivalent Surveillance Requirement exists in the Petch Bottom Technical Specifications, with one minor exception, Table Ib clarifics. ;
where necessary, how Peach Bottom compares to Standard Tech.:'* cal Specification I Surveillance Requirements in Sections 4.5.1. 4.7.1.1 and 4.7.4 and explains the oneexception(ComparisonNo.8).
Significant Hazards Consideration Determination: .
1 Licensee proposes that the changes requested herein do not involve significant hazards considerations for the following reasons:
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License Nos. DPR-44 DPR-56 i
- 1) The proposed revisions do not involve a significant increase in the probability or consequences of an accident previously evaluated because the availability of core and containment cooling systems will not be I reduced, and the design and performance of the systems are not being I changed. The ECCS are provided to mitigate the consequences of a loss of coolant accident (LOCA) and RCIC is a non-safety related water injection system; therefore, their availability has no bearing on the ,
probability of occurrence of a LOCA. Reducing the testing frequency ;
will have no effect on the ability of these systems' piping and isolation valves to withstand design pressures. HPSW is provided to ;
i remove heat after a design basis event and does not contain piping connected to the reactor vessel or penetrating the primary containment; thus, HPSW has no bearing on the probability of occurrence of a design basis accident. Because only the frequency of testing these systems is being changed, not any systems themselves nor any test methods, there '
will be no hffect on accident precursors and, thus, no affect on the i probability of occurrence of previously evaluated acridents.
Because, the systems are not being changed, their ability to rarform their design functions is not adversely affected. The remaining Technical Specification surveillance requirements provide adequate assurance that the systems will be operable when required. Therefore, the consequences of previously evaluated accidents will not be increased.
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- 11) The proposed revisions do not create the possibility of a new or different kind of accident from any accident previously evaluated _
because these changes do not introduce any new modes of operation or
- testing and no physical changes are being made to the plant; therefore. '
no new or different kind of accident could be initiated. ,
iii) The proposed revisions do not involve a significant reduction in a '
margin of safety because the testing requirements that will remain in '
the Technical Specifications provide adequate assurance that the systems will be operable when needed. Since the reduction of testing may increase system availability, margins of safety may be increased. -
further, because the perfomance of the systems is not being changed, margins of safety associated with their ability to perform their design l functions will not be reduced. '
ECTIONC DescriptionofHhcellaneousAdministra1_veChgtget:
1 License Amer.dment Ho!.. 113and113(Units 2and3.respectively) replaced the section of the Technical S,)ecifications which was numbered 6.9.2 with the section that was numbered 6.9.3. However, numerous references to '
Specification 6.9.3(whichisnownumbered6.9.2)stillexistintheTechnical Specifications. These references to 6.9.3 need to be changed to 6.9.2 on pages 205, 209, 210, 214, 216a-1, 216a-5 and 240t. On page 240t there are also references to the section that was deleted by Amendments 110/113 (the former Specification 6.9.2). These references should be deleted.
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DPR-56 l Additional changes are proposed to correct inconsistencies between Technical Specifications reporting requirements and 10 CFR 50.4, " Written Communications", which became effective on January 5,1987. The regulation (10 CFR'50.4(f)) states that it supersedes and replaces any conflicting technical-specification requirements in effect on January 5,1987. Consequently, technical specification requirements to send reports to certain NRC Offices, contrary to the requirements of 10 CFR 50.4, need to be replaced with references to 10 CFR 50.4 on pages 240t, 254, 256 and 257.
License Amendment Nos. 102 and 104 (Units 2 and 3, respectively)
L renumbered the specifications in Section 3.8 of the Technical Specifications.
Apparently, at this time errors were introduced in Specification 6.9.2 (page 257), which references several specifications from Section 3.8. One of the referenced specifications, 3.8 C.6, contains no reportability requirements and, thus, is not applicable to 6.9.2. Therefore, the reference to 3.8.C.6 in 6.9.2 should be deleted. Specifications 3.8.C.5 and 3.8.E.1.b are applicable to 6.9.2 end are not seferenced. Therefore, references to Specifications 3.82C 5 and
.3.8.E.1.b should be added to 3pecification 6.9.2.
Changes are proposed to the Bases cf Sections 3.5.B and 4.5 to delete '
unnecessary and outdated information and add more appropriate and more complete information regarding Core and Containment Cooling Systems surveillances. The lastparagraphoftheBasesofSection3.5.8(ContainmentCoolingSystems Limiting Conditions for Operation, page 136) concerns pump capacity testing, and explains a contrast between pre-service pump tests and in-service pump tests.
This does not belong in the Bases for Limiting Conditions for Operation (LCOs)
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License Nos. DPR-44 {
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and no other Bas e for Section 3.5 (Core and Containment Cooling Systems LCOs) !
contain such information. Furthermore, this paragraph implies that pump motor current may be used as a test criterion, which is no longer an acceptable practice. Based on this and because the Bases for the Core and Containment l CoolingSystemsSurveillanceRequirements(Section4.5)lackacomplete discussion of the systems capacity tests Licensee proposes that the last i paragraph of the Bases for Section 3.5.B be deleted and that a new paragraph which more completely describes periodic testing of the Core and Containment
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CoolingSystemsbeaddedtotheBasesforSection4.5(page141). This new
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paragraph merely references the appropriate design basis documents and ASME Section XI plan, and clarifies the purpose of the tests.
Changes are proposed to the Bases for Sections 3.5.C (HPCI) and 3.5.0 ?
(RCIC) to clarify the RCIC operability requirements. Currently, the HPCI Bases, !
'on page 130, partially address RCIC because the systems are similar in functioa.
The Bases acknowledge that HPCI, while rer;uired to be operable when reactor pressure.is greater than 105 usig. "is not designet to operate until reactor i pressure exceeds 150 psig and is autome.tically isolated before reactor nress'.tre decreases below 100 psig.S Since the same is true of RCIC, Licensee proposes that the associated statements be extended to RCIC as well. This results in !
changes to the first and second paragraphs on page 138. This change merely provides clarifying information for RCIC identical to information currently
.provided for HPCI, and does not change the intent of the specifications. .
Licensee proposes to reinsert material into the Technical
~ Specifications Bases that was removed apparently by error. The material on page i f
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DPR-56 i
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135(Section3.5. Abases, continued)wasdeletedfromtheUnit2 Technical Specifications by Amendment No. 23 and from the Unit 3 Technical Specifications i
by Amendment No. 27; however, the associated License Amendment Applications did not request that the material on page 135 be removed and the information is i
still applicable to the Technical Specifications. Therefore, Licensee proposes that page 135 be restored in the Technical Specifications appropriately modified I to reficct the elimination of accelerated testing requirements (consistent with the proposal of Section B of this application). The manner in which Reference .
(1),"GuidelinesforDeterminingSafeTestIntervalsandRepairTimesfor !
Engineered Safeguards" was addressed on page 135 should be changed since one of the author's assumptions was that accelerated testing would be performed. When i the material on page 135 was deleted it included the following statement: "The [
method and concept are described in reference (1)". The " method" is not ;
offected by eliminating accelerated testing since it is reasonchle to conclude that redundant systems are operable without being tested. Thus, our established
- repair tines are valid. However, the auther's " concept" will no longer be fully I i
app 1'icable to Feach Bottom sirte F.eference (1) endorses accelerated testing.
Thereforer Licensee proposet that the Otses state that the repair times were i established "using the methods described in Reference (1)." References to accelerated testing that existed on this page should also be deleted and references to the Bases for Section 4.5 should be added to be consistent with Section B of this application. Also, the words, "and the diesel generators" ,
that existed in the second paragraph should be deleted because Section 3.5.A does not and is not intended to address the diesel generators.
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, , 50-278 License Nos. DPR-44 DPR-56 Changes are proposed to the Bases of the Str,ndby Liquid Control System i Technical Specifications on page 120 to reflect the recently adopted practice of nomally using pre-mixed dry sodium pentaborate to prepare the control solution
.rather than mixing borax and boric acid to create the solution. This does not l
affect the Technical Specifications for the solution; only the Bases need to be i changed to update the description of the solution preparation method. I l
License Amendment Nos. 87 for both Units added a footnote to page 125 specifying the criteria to be applied for satisfying the Core Spray pump flow surveillance pending completion of a modification to facilitate testing the #
pumps one at a time. This note should be removed since the associated ,
modification has been completed on both Units and the note is no longer needed.
i Amendment No. 91 to the Unit 3 Technical Specifications added a footnote to page 126 which temporarily extended the allowable cut-of-service time of Specification 3.5.A.S. This note should be removed since it expired on i November 24, 1982 and is no longer applicable.
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License Amendment Nos. 112 and 116 (Units 2 and 3, respectively) deleted Table 3.2.E from the Technical Specifications because it contained requirements that were redundant to the requirements of LCOs Section 3.6.C. '
However, LCOs Section 3.2.E. "Drywell Leak Detection" on page 59 still references Table 3.2.E. Licensee proposes that this error be corrected by changing the reference in Section 3.2.E from " Table 3.2.E" to "Section 3.6.C. .
Coolant Leakage". -
The following editorial changes are also proposed. ,.
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License Nos. DPR-44 DPR-56 l
Page 125:
Replace capital "P" of word " Pump" in ,
Specification 4.5.A.1(d)withalowercase i "p". ;
Page 130: Substitute " Subsystem" for "Sub-System" {
wherever "Sub-System" appears, for consistency throughout Technical Specifications. ;
Page 130: Substitute "RCIC Subsystem" and "HPCI Subsystem" for "RCICS" and "HPCIS".
respectively. in Section 3.5.0.2 because these I acronyms are not commonly used in the l
Technical Specifications. j Page 136: Replace the words "for this equipment" with .
"for two HPSW pumps" in the following ;
statement in the Bases for Section 3.5.B: f 0- " Loss of mergin should be avoided and the equipment maintained in a state of operability i so a 30-day out-of-service time is chosen for :
this equipment." This statement is currently i
vague. The proposed change merely makes it clear what "this equipment" is and achieves '
consistency with LC0 3.5.B.2.
f Page 138: Correct last phrase in Bases for Section 3.5.0 to state "an allowable repair time of 1 week 2
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DPR-56 i is specified." The Bases has always been l incorrect in stating "1 month" rather than the {
1 week to which LC0 3.5.D.2 has always limited f the repair time. l Page 138 (Unit 3 only): Correct the misspelling of the word
" considered" in the Bases for Section 3.5.E. >
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Page 141: Add the words " sound engineering" to qualify the tem " judgment" in the Bases for Section 4.5. This is supported by Section 8 of this !
i application. :
i Page 141: Correct the misspelling of the word," caused" in the Bases for Sections 4.5 I&J.
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,P_ age 210: Begin a new sentence with the words "The report shall identify..." to improve readability by eliminatirig a run-on sentence.
Attachment 2 contains the revised Technical Specification p6ges with ,
bars in the page margins denoting changes.
Sionificant Hazards Consideration Determination:
The NRC has provided guidance concerning the application of the standards for detemining whether license amendments involve significant hazards considerations by providing examples in 51 FR 7751. An example (Example 1) of a change that involves no significant hazards considerations is "a purely J
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I administrative change to technical specifications: for exagle, a change to i achieve consistency throughout the technical specifications, correction of an [
crror, or a change in nomenclature". The changes requested herein confom to .
this example. ;
i Licensee proposes that the changes requested herein do not involve l significant hazards considerations for the following reasons: f i
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- 1) The proposed revisions do not involve a significant increase in the I i
probability or consequences of an accident previously evaluated because j they do not affect operations, equipment, or any safety-related f activity. Thus, these administrative changes cannot affect the !
probability or consequences of any accident.
ii) The proposed revisions do not create the possibility of a new or !
different kind of accident from any accident previously evaluated i because these changes are purely administrative and do not affect the plant. Therefore, these changes canrot create the possibility of any l
l accident. !
i iii) The proposed revisions do not involve a significant reduction in a margin of safety because the changes do not affect any safety related :
activity or equipment. These changes are purely administrative in l
nature and increase the probability that the Technical Specifications i
are correctly interpreted by adding clarifying information, deleting inappropriate information, and correcting errors. Thus, these changes cannot reduce any margin of safety.
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.- *- 50-278 License Nos. DPR-44 DPR-56 SECTION D Description of Changes:
Licensee proposes to change the operability requirements for HPCI, RCIC and ADS to make it clear that these systems need not be operable when the reactor vessel is subjected to hydrostatic pressure, such as during required reactor vessel hydrostatic testing. This clarification is accomplished simply by adding the word " steam" to LCOs 3.5.C.1, 3.5.D.1 and 3.5.E.1. Each of these LCOs would now state that the system shall be operable whenever there is irradiated fuel in the reactor vessel and " reactor steam pressure is greater than 105 psig..."
Attachment 2 contains the revised Technical Specification pages with bars in'the page margins denoting changes.
P Safety Assessment: '
The HPCI and RCIC Systems are neithe'. intended to be operable nor .
capable of being operable without reactor steam because they use reactor steam turbine driven pumps. HPCI and RCIC are automatically isolated when reactor ;
water level is greater than +45 inches indicated level. During the reactor L
- l. vessel hydrostatic test the vessel is completely flooded (well above +45 1
inches). i ADS is intended to act in conjunction with the low pressure core standby cooling systems for reflooding the core following small breaks in the nuclear system process barrier (UFSAR Section 4.4.1). ADS uses five of the l
nuclear system safety / relief valves to relieve the high pressure nuclear steam 16- i
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- i to the suppression pool (UFSAR Section 6.4.2). When the coolant in the vessel !
is static liquid and no boiling is occurring, no high pressure relief capability {
l 1s needed.
This change does not alter, in actuality, the Technical Specification operability requirements for HPCI, RCIC and A05. Rather this change merely !
removes vagueness from the LCOs without changing the meaning or intent of the LCOs. The Technical Specifications of many BWRs state that the pressure at which these systems are required is " steam" pressure. The Technical l Specifications of Philadelphia Electric Company's Limerick Generating Station Units 1 and 2 for example, state that HPCI, RCIC and ADS need not be operable when"reactorsteamdonepressure"islessthan200psig(HPCI),150psig !
Significant Hazards Consideration Deteminatioii:
Licensee prcposes that the changes requested herein do not involve significant hazards considerations for the following reasons:
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l 1) The proposed revisions do not involve a significant increase in the probabQityorconsequencesofanaccidentpreviouslyevaluatedbecause the changes merely make the operability requirements for HPCI, RCIC and ADS more explicit and do not change the intent of the Technical 1
Specifications. Specifying " steam" pressure is consistent with the function of the systems as described in the Technical Specification '
I Bases and UFSAR. Thus, these changes do not affect any operations or plant equipment and, consequently, cannot affect the probability or j consequences of any accident.
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- 11) The proposed revisions do not create the possibility of a new or '
i different kind of accident from any accident previously evaluated '
because these changes do not introduce any new requirements, delete any .
existing requirements, or change, in actuality, any existing i requirements. Therefore, no new operational modes, y:.* any unevaluated >
activities or conditions could be introduced by these changes. No new or different kind of accident could possibly be created.
iii) The proposed revisions do not involve a significant reduction in a margin of safety because, in actuality, the Technical Specification operability requirements are not being changed. The Specification ;
affected will be interpreted after the revision exactly the same way i they are currently interpreted. Thus, the margins of safety provided by the Technical Specificalions and the systems involved are not l affected. i SECTION E Environmental Impact:
1 An environmental assessment is not required for the changes requested by this Application because the requested changes conform to the criteria for
' actions eligible for categorical exclusion" as specified in 10 CFR 51.22(c)(9).
The requested changes have been shown by this Application not to adversely affect the systems and equipment that prevent the uncontrolled release of radioactive material to the environment. The Application involves no ,
significant hazards consideration as demonstrated in the preceding sections.
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The Application involves no significant change in the types or significant ;
increase in the amounts of any effluents that may be released offsite and there '
till be no significant increase in individual or cumulative occupational i
radiation exposure. l i
SECTION F i
Conclusion:
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The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes to the Technical Specifications and determined "
that they do not involve an unreviewed safety question and will not endanger the hea),th and safety of the public. 5 t
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gr e es
Tcble 1A Page 1 cf 1 ACCELERATED TESTING REQUIREMENTS TO BE DELETED
"^ PeNorm Accelerated '!
Testing When the-Following Become Accelerated Testing Technical Specifications Inoperable: Currently Required Section and (Page No.)
One Core Spray Within 24 hrs 4.5.A.2 i Subsystem (one or two Test Operable CS 4.5.A.1(f) pumps) Subsystem and LPCI Subsystems. Test Same 4.5.A.3(e) )
Every 72 hrs :
Thereafter.
l One LPCI Pump or Within 24 hrs 4.5.A.4 One LPCI subsystem Test Operable LPCI 4.5.A.5 l Pumps / Subsystem and CS 4.5.A.1(f) l Subsystems. Test Same 4.5.A.3(e)
Every 72 hrs Thereafter.
Two HPSW Pumps Immediately and 4.5.B.2 (128)
Weekly Thereafter {
Three HPSW Pumps Immediately test 4.5.B.3 (128)
Operable HPSW pump and its Diesel Generator. Test l Operable HPSW Pump {
Weekly Thereafter. '
One Torus Cooling Immedittely Test 4.5.B.4 (128) ]
Loop Operable Torus Cooling Loop and its Diesel j Generators.
One Drywell Spray Ilmned14tely Test 4.5.B.5 (128a) -
Loop Operable Drywell Spray e Loon end its Diesel ;
- Generators.
One Torus Spray limmediately Test 4.5.B.6 (128a)
Loop Operable Torus Spray Loop and its Diesel L Generators.
L HPCI System Immediately 4.5.C.2 (129)
L_. Test RCIC and ADS Actuation Logic
- Daily Thereafter.
l RCIC System Iinnediately and 4.5.D.2 (130)
Weekly Thereafter Test HPCI. -
One ADS Valve limnediately Test 4.5.E.2 (131)
ADS Actuation Logic for Operable Valves and Test HPCI. Test Same Weekly Thereafter.
Tabla IB l
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, e Comparison No. 1 i
. STANDARD TECHNICAL SPECIFICATIONS: 4.7.4.a.1 & 4.5.1.a.1 I EQUIVALENT PEACH BOTTON TECHNICAL SPECIFICATION: 4.5.G.1 DISCUSSION: i Standard Technical Specifications require that at least every 31 days the RCIC and HPCI discharge piping be checked to verify it is filled with water. Peach Botton's Technical Specifications also require that this be done, monthly, but only when the system is aligned to the torus. This is appropriate because RCIC and HPCI at Peach :
Bottom are normally aligned to the Condensate Storage Tank (CST), the elevation of j which is above the highest point in the RCIC and HPCI discharge piping. !
Comparison No. 2 SYS1EM: RCIC & HPCI STANDARD TECHNICAL SPECIFICATIONS: 4.7.4.a.2.4.5.1.a.2.aand4.5.1.c.2.a(2)
EQUIVALENT PEACH BOTTOM TECHNICAL SPECIFICATION: Not Applicable DISCUSSION:
Because RCIC and HPCI are normally aligned to the CST which is at an elevation above !
the system piping, there is no keep filled system.
Comparison No. 3.
SYSTEM: RCIC. HPCI, CS. LPCI and ilPSW STANDARD TECllNICAL SPECIFICATIONS: 4.7.4.a.3. 4.5.1.a.3 and 4.7.1.1.a !
' EQUIVALENT PEACH BOTTOM TECilNICAL SPECIFICATI045:.4.5.D.1(c). 4.5.C.1(c). 4.5.A.1(c). >
4.5.A.3(c) and 4.5.B.1(b) ,
DISCUSSION:
Standard Technical Specifications require that at Nast every 31 days the position of l
each valve (manual, power operated or automatic) in the flow path that is not locked, sealed or otherwise secured in position be checked to verify tt.at it is in its correct position. The Peach Botton Technical Specifications go beyond that by requiring a monthly motor operated valve and pump operability test. Prior to beginning the monthly test, the systems are verified to be lined up for automatic .
operation and once the test is completed each valve in the flow path that was moved l
1s returned to its correct position. Thus, the purpose of this Standard Technical Specification is fulfilled by performance of the monthly test required by the Peach Botton Technical Specifications.
One valve in the flow path of HPCI and RCIC. however, is assured to be in its correct position without being checked monthly. HPCI injects into the reactor vessel through the 'A' feedwater line and RCIC injects through the 'B' feedwater line. The M0-29
. valve (A&B) is-in the flow path; however, this valve is opened prior to pulling any control rods in preparation for plant startup, the control switch is "mousetrapped" "
and an information tag is posted on the switch in accordance with the plant startup procedure (GP-2). During power operation this valve remains open to permit the l
normal flow of feedwater to the reactor vessel.
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Comparison No. 4 t
SYSTEM: RCIC & HPCI STANDARD TECHNICAL SPECIFICATIONS: 4.7.4.c.3 and 4.5.1.c.3 EQUIVALENT PEACH BOTTOM TECHNICAL SPECIFICATION: Table 4.2.B DISCUSSION:
Automatic transfer of RCIC & HPCI suction from the CST to torus on CST low level and I automatic transfer of HPCI suction from CST to torus on torus high level is demonstrated during the logic system functional test or the instrument functional test required by the Peach Botton Technical Specifications. This is done more frequently than required by the Standard Technical Specifications.
Comparison No. 5 SYSTEM: HPCI & LPCI STANDARD TECHNICAL SPECIFICATIONS: 4.5.1.a.2(b) and 4.5.1.c.2(b) ,
EQUIVALENT PEACH BOTTOM TECHNICAL SPECIFICATION: Not Applicable DISCUSSION:
There is no header inside the vessel for HPCI and LPCI; thus, there is no header delta P instrumentation for HPCI and LPCI. HPCI injects through a feedwater line and l
LPCI injects through a reactor recirculation line. There is only a header inside the vessel for CS. .;
IStegorisonJo. 6 1
[ SYSTEH: CS & LPCI L STANDARD TECHNICAL SPECIFICATION: 4.5.1.a.1 EQUIVALENT PEACH B0TICH TECHNICAL SPECIFICATIONS: 4.5.A.1(b) and 4.S.A.3(b)
DISCUSSION: ,
, Prior to starting-the pump during the monthly pump operability test, the operators I
verify, in accordance with the test procedure, that the piping is filled with water l by either confirming that the vent accumulator low level control room alarm is not lit or by venting water from the accumulator. The pump discharge full flow test line valve is closed prior to stopping the pump, ensuring that the system piping is left filled at the completion of the test. Thus, the purpose of this Standard Technical l Specification is fulfilled by the performance of the monthly test required by the Peach Botton Technical Specifications.
Comparison No. 7 ^
SYSTEM: CS & LPCI STANDARD TECHNICAL SPECIFICATIONS: 4.5.1.a.2(a)and4.5.1.c.2(a)
EQUIVALENT PEACH BOTTOM TECHNICAL SPECIFICATION: 4.5.G.2 DISCUSSION:
. Standard Technical Specifications require a functional test of the keep filled instrumentation at least every 31 days and a channel calibration at least every 18 months. The " standard plant" uses pressure instruments; Peach Bottom uses vent accumulator water level instruments. Peach Botton Technical Specifications require a
Tabla 18 Page 3 cf 3 functional test of the level switches once per operating cycle; however, this test'is conducted quarterly. The Peach Botton Technical Specifications do not specify a calibration frequency; however, if during the quarterly functional test the low level !
alars does not light when water is drained from the accumulator,. a maintenance l request form would be initiated and the surveillance test would be considered a !
failure. Based on operating experience, this is considered to be an acceptable '
method of surveillance which provides a high level of operability assurance.
Comparison No._8 l
SYSTEN: HPSW STANDARD TECHNICAL SPECIFICATIONS: 4.7.1.1.b and 4.7.1.1.c EQUIVALENT PEACH BOTTON TECHNICAL SPECIFICATION: NONE DISCUSSION:
Standard Technical Specifications require that water level in the intake structure
.for Residual Heat Removal Service Water Pumps (same function as Peach Botton's HPSW) be checked periodically. The Peach Botton HPSW pump bay (in the intake structure) is equipped with level-instruments that feed a control room indicator and alors. Alare panels are " walked down" during each operating shift turnover. Also, river water level is lngged each shift in accordance with Technien1 Specification 4.12.0.1.
Based on this, arvi the fact that numerous other nuclear power pir.nts that usc a
. reservoir or river for the cooling water source tio eat save such a Tocarilcal j Specification re.1uirement Philadelphia Electric Comparty does not consider such a l requirement to be necessary for Peach Bottom. Provisions are in plact to monitor 6
-inta;te structure water level.
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The ,Stknd4/d Techrdcal Spacificaticos also regJite that the "( ) bottom condititais in I the vicinity of the-intake structure be checken and that ths "( ) stage discharge '!
.reting curve in the unit vicinity" be checked.. The probless that these surveillances are intended -identif'/ would be identified by ASME Section XI testing since pump
. performance is thoroughly monitored. Removal of silt accumulated on the bottom of the intake structure is a scheduled preventive maintenance task conducted during .
refueling catages. The Technical Specifications of numerous other nuclear power plants using a reservoir or river for the cooling water source do not contain these surveillance requirements. Thus, Philadelphia Electric Comparty does not consider L
such requirements to be necessary. .
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