ML20036A248
| ML20036A248 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 04/30/1993 |
| From: | James Shea Office of Nuclear Reactor Regulation |
| To: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| TAC-M83704, TAC-M83705, NUDOCS 9305110008 | |
| Download: ML20036A248 (7) | |
Text
Docket.Nos. 50-277 April 30, 1993' and 50-278 Mr. George A. Hunger, Jr.
. Director-Licensing, MC 52A-5 Philadelphia Electric Company Nuclear Group Headquarters Correspondence Control Desk P.O. Box No. 195 Wayne, Pennsylvania 19087-0195
Dear Mr. Hunger:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION RE: APPLICATIONS TO REVISE TECHNICAL SPECIFICATIONS TO ACCOMMODATE A 24-MONTH FUEL CYCLE, PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 (TAC M83704 AND M83705)
By letters dated September 28, 1992 and October 19, 1992, Philadelphia Electric Company (PECo) requested a revision to the Peach Bottom Atomic Power L
Station (PBAPS), Units 2 and 3, Technical Specifications. The request revised surveillance intervals for numerous components and systems to 24-months (30-month maximum, including a grace period). After reviewing your submittals and your supplemental submittal dated March 16, 1993, the staff has concluded that some additional information is necessary to make a safety determination.
The additional information required is described in the enclosure.
Response to the enclosed Request for Additional Information (RAI) is requested by May 28, 1993.
This request affects fewer than 10 respondents and, therefore, is not subject to Office of Management and Budget Review under P.L.96-511.
Should you have any questions regardi g this RAI, please contact me at (301).
504-2426.
Sincerely,
/S/
Joseph W. Shea, Project Manager Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear reactor Regulation
Enclosure:
Request for Additional Information cc w/ enclosure:
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April 30, 1993' Docket Nos. 50-277 and 50-278 Mr. George A. Hunger, Jr.
Director-Licensing, MC 52A-5 Philadelphia Electric Company
.1 Nuclear Group Headquarters i
Correspondence Control Desk I.
P.O. Box No. 195 Wayne, Pennsylvania 19087-0195
~
Dear Mr. Hunger:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION RE: APPLICATIONS TO REVISE TECHNICAL SPECIFICATIONS TO ACCOMM0DATE A 24-MONTH FUEL CYCLE, PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 (TAC M83704 AND M83705)
By letters dated September 28, 1992 and October 19, 1992, Philadelphia Electric Company (PECo) requested a revision to the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, Technical Specifications. The request revised surveillance intervals for numerous components and systems to 24-months (30 '
month maximum, including a grace period). After reviewing your submittals and your supplemental submittal dated March 16, 1993, the staff has concluded that some additional information is necessary to make a safety determination. The additional information required is discribed in the enclosure.
Response to the enclosed Request for Additional Information (RAI) is requested by May 28, 1993.
This request affects fewer than 10 respondents and, therefore, is not subject to Office of Management and Budget Review under P.L.96-511.
Should you have any questions regarding this RAI, please contact me at (301) 504-2426.
Sincerely, f)a0
}
os W. Shea, Project Manager
)roject Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear reactor Regulation
Enclosure:
Request for Additional Information cc w/ enclosure:
See next page
Mr. Gev.3 A. Hunger, Jr.
Peach Bottom Atomic Power Station, Philadelphia Electric Company Units 2 and 3 cc:
J. W. Durham, Sr., Esquire Mr. William P. Dornsife, Director Sr. V.P. & General Counsel Bureau of Radiation Protection Philadelphia Electric Company Pennsylvania Department of 2301 Market Street, S26-1 Environmental Resources Philadelphia, Pennsylvania 19101 P. O. Box 2063 Harrisburg, Pennsylvania 17120 Philadelphia Electric Company ATTN: Mr. D. B. Miller, Vice President Board of Supervisors Peach Bottom Atomic Power Station Peach Bottom Township Route I, Box 208 R. D. #1 Delta, Pennsylvania 17314 Delta, Pennsylvania 17314 Philadelphia Electric Company Public Service Commission of Maryland ATTN:
Regulatory Engineer, Al-2S Engineering Division Peach Bottom Atomic Power Station ATTN: Chief Engineer Route 1, Box 208 231 E. Baltimore Street Delta, Pennsylvania 17314 Baltimore, MD 21202-3486 Resident Inspector Mr. Richard McLean U.S. Nuclear Regulatory Commission Power Plant and Environmental Peach Bottom Atomic Power Station Review Division P.O. Box 399 Department of Natural Resources Delta, Pennsylvania 17314 B-3, Tawes States Office Building Annapolis, Maryland 21401 Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Mr. Roland Fletcher Department of Environment
'201 West Preston Street Baltimore, Maryland 21201 Carl D..Schaefer External Operations - Nuclear Delmarva Power & Light Company P.O. Box 231 Wilmington, DE 19899
, (. =
ENCLOSURE RE00EST FOR ADDITIONAL INFORMATION REGARDING PROPOSED REVISIONS TO THE PEACH BOTTOM ATOMIC POWER STATION. UNITS 2 AND 3. TECHNICAL SPECIFICATIONS RELATING TO 24-MONTH OPERATING CYCLE SURVEILLANCE RE0VIREMENTS DOCKET NOS. 50-277 AND 50-278 A.
Instrument-Related Ouestions I.
Explain the relationship between the " procedure drift allowance" as referenced in the Peach Bottom submittal and the " leave alone zone" (LAZ) and design allowance / allowable value as referenced in the GE setpoint methodology.
The General Electric (GE) setpoint methodology states that the derivation of the LAZ is determined by the individual utility setpoint results.
The GE design allowance incorporates temperature, calibration, and drift errors.
It is not clear what terms are included in the Peach Bottom procedure drift allowance, provide details.
2.
Confirm that the methodology for determining a vendor (Rosemount, etc.)
24-month drift term is consistent with the GE drift methodology.
Provide details.
For example, discuss 95/95 criteria,- number of data points, length of test, methodology in determining an extended surveillance drift value, and applicability to currently installed instrumentation as appropriate.
Provide a copy or summary of any applicable vendor reports that justify a 24-month interval.
3.
Provide additional details on the impact of sensor calibration frequency on your justification of extended instrument surveillance intervals, which was based on maintaining current functional test intervals.
4.
Verify that plant procedures for the affected instrumentation have been reviewed and verified to reflect the adopted GE setpoint methodology.
(That is, verify that the surveillance procedures acceptance criteria design basis is consistent with the GE setpoint' methodology).
5.
The application of October 19, 1992, confirms that a historical review was performed for surveillance tests (ST) results. Confirm that this historical review included an evaluation of any applicable maintenance records.
(e.g., corrective maintenance, INPO reports, etc.)
6.
Describe the application of the GE methodology to instrumentation installed at Peach Bottom that was not evaluated in GE topical NEDC-31336.
(e.g., moduflash 652) 7.
For main steam temperature resistance temperature detectors, it is stated that these devices are factory calibrated devices and do not exhibit drift.
Provide surveillance test results, applicable vendor information.
and qualification data to verify the limited drift of these devices.
Is sensor drift considered in uncertainty calculation?
8.
What is the model number for the Foxboro microcomputer referenced in the submittal for reactor level monitoring.
Is it a Foxboro spec 200 micro system?
9.
In 'your application, you described that the safety relief valve position switch evaluation would not support an extended surveillance interval.
The switch position switch data was found to be consistently in the conservative direction with regards to flow. However, based on'the.
conservative direction of. the position switch the drift, the evaluation
recommended a 24-month interval.
Provide the plant-specific drift results and additional justification as to why the as-left and as-found drift value has not been incorporated into the current calibration i
surveillance and setpoint determination.
10.
For the referenced digital feedwater modification, provide information on any changes to setpoint calculations, etc., that were required to incorporate any revised instrument uncertainties.
Provide results of the l
revised setpoint calculations or any vendor recommendations on surveillance requirements or additional analysis to -support the proposed extended surveillance intervals.
11.
For the suppression pool water temperature instrumentation provide information on surveillance testing and qualified life of this instrumentation. Does a specified replacement schedule exist for the thermocouples?
- 12. The drywell pressure instrumentation drift analysis results represent only an 18-month value.
Provide details as to the method of determining the 30-month drift term based on the limited data set of the drift study.
Also confirm that a surveillance histury evaluation was performed on the plant as-left and as-found drift data.
No assessment of instrument availability was presented in the submittal.
Provide details on the stated change in calibration method for drywell instrumentation.
- 13. The instrumentation.for the seismic monitorire is new and thus, plant-specific information is not available (for Kinemetrics).
The submittal indicated that the vendor has certified that a surveillance interval of 30-months is acceptable for this instrumentation.
Provide a summary or a copy of vendor documentation (Kinemetrics and Engdahl).
14.
Describe the changes in calibration test methods (drift) for the seismic monitoring information manufactured by Engdahl.
15.
Has the revised plant as-left and as-found drift term been incorporated into the uncertainty calculation or surveillance procedure for the main turbine control valve fast closure pressure switches? Has the as-left and as-found drift value been evaluated for a 30-month surveillance interval?
16.
Provide details on the relationship of the drift of Magnetrol switches at Limerick Generating Station to the instrumentation at Peach Bottom and the applicability to a 30-month surveillance interval extension.
(Robertshaw and RCI (FCI?) installed at Peach Bottom). Was manufacturers-drift data considered in the evaluation of an extended interval?
a t
17.
Provide documentation to support a 24-month surveillance interval for proposed "NUMAC" main steam line radiation monitors.
(GE publication, test results, or revised uncertainty calculations.)
18.
Since the main steam line radiation monitors were not replaced for Unit 2 in the September 1992 outage, will the original equipment be operating on a 24-month surveillance interval? Provide additional details to justify the apparent surveillance interval increase for existing instrumentation for both Units 2 and 3.
~
19.
Provide details on the evaluation of electromagnetic interference and radiofrequency interference compatibility, susceptibility, emissions, and' site survey for the NUMAC radiation monitors, i
20.
The drywell radiation monitoring system drift evaluation contained insufficient data points to develop a 30-month drift term.
Is additional data available to support an extended surveillance interval (vendor data, similar systems)?
21.
The safety discussion on page 10 of the October 19, 1992, application states that the calibration surveillance interval for the torus' to Reactor Building vacuum breaker instrumentation will remain unchanged at 18 months (proposed TS 4.7.A.3a).
However, at the bottom of page 10, you state that the GE methodology drift analysis on the Torus to Reactor 3
Building Pressure switches (TS 4.7.A.3.a) demonstrated the surveillance interval could be extended to 24 months.
Please clarify and rejustify your intentions with respect to TS 4.7.A.3.a.
22.
For scram discharge instrumentation, the submittal references failed switches that had to be replaced. Were failed switches found during calibration or functional tests?
Is the functional test similar to the calibration surveillance?
B.
Non-Instrument Related Ouestions
- 23. TS 4.5.C.I.a requiring a once-per-operating-cycle Simulated Automatic Actuation Test does not appear to be addressed in the September 28, 1992, submittal; however, the surveillance interval for this test will be changed by a change to the TS Definition of "Once-per-cycle." Please justify extending this TS interval or provide a specific frequency for this TS item.
24.
In Section (2) " Air" of the. September 28, 1992, submittal, you describe other STs that quantitatively identify leakage rate of the safety grade pneumatic supply system.
Describe the performance and frequency of these STs or reference the corresponding TS requirements.
8 k
1 i
25.
A safety evaluation dated July 2,1984, addressed implementation of functional testing requirements.
It stated that "In order to provide assurance that the hydraulic and mechanical snubbers function reliably, a representative sample of the plant's installed snubbers will be functionally tested at least once-per-18 months during plant shutdowns.
The required sampling provides a confidence level of 95% that 90% of the plant-specific snubbers will be operable within acceptable limits."
Although GL 91-04 does not require licensees to quantify the effect of changing the surveillance interval, your application of September 28, 1992, did not make reference to any evaluation of previous ST results in justifying an extension of the surveillance interval. The lack of preventative maintenance performed on a component is not an adequate justification for extending the surveillance interval.
Provide justification for extending the snubber functional inspection interval in TS 4.11.D.4.
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