ML20045F885

Forwards Request for Addl Info Re 921015 Application to Revise TS to Accommodate 24-month Fuel Cycle.Response Requested by 930726

ML20045F885
Person / Time
Site:	Limerick
Issue date:	07/01/1993
From:	Rinaldi F Office of Nuclear Reactor Regulation
To:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
TAC-M83377, TAC-M83378, NUDOCS 9307090139
Download: ML20045F885 (7)

Text

-Docket Nos. 50-352

-July 1, 1993 and 50-353

• 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

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RE: APPLICATIONS TO REVISE TECHNICAL SPECIFICATIONS TO ACCOMMODATE A 24-MONTH FUEL CYCLE, LIMERICK GENERATING STATION, UNITS 1 AND 2 (TAC NOS. M83377 AND M83378)

By letter dated October 15, 1992, Philadelphia Electric Company (PEco) l requested a revision to the Limerick Generating Station, Units 1 and 2 Technical Specifications. A supplemental letter dated March 16, 1993; provided additional information requested during our meeting of February 25, 1993. The request revised surveillance intervals for numerous components' and systems to 24-months (30-month maximum, including a grace period). After reviewing your initial submittal and your supplemental information, the staff has concluded that some additional information is necessary to make a safety determination. The additional information required is described in the i

enclosure.

Response to the enclosed Request for Additional Information (RAI) is requested _

l by July 26, 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.

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Should you have any questions regarding this RAI, please contact me.at (301) 504-1447.

Sincerely,

/S/

Frank Rinaldi, Project Manager i

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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wasnincros, o.c. 20sss-oooi Docket Nos. 50-352 July 1, 1993 and 50-353 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

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RE: APPLICATIONS TECHNICAL SPECIFICATIONS TO ACCOMMODATE A 24-MONTH FUEL CYC LIMERICK GENERATING STATION, UNITS 1 AND 2 (TAC NOS. M83377 By letter dated October 15, 1992, Philadelphia Electric Company (PECo) requested a revision to the Limerick Generating Station, Units 1 and 2 Technical Specifications.

A supplemental letter dated March 16, 1993, provided additional information requested during our meeting of February 25, 1993.

The request revised surveillance intervals for numerous components and systems to 24-months (30-month maximum, including a grace period).

reviewing your initial submittal and your supplemental information, the staff After 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 July 26, 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) 504-1447.

Sincerely, pt Frank Rinaldi, 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:

See next page m -

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Mr. George A. Hunger, Jr.

Limerick Generating Station, Philadelphia Electric Company Units 1 & 2 cc:

J. W. Durham, Sr., Esquire Mr. William P. Dornsife, Director Sr. V.P. & General Counsel Bureau of Radiation Protection' t

Philadelphia Electric Company PA Dept. of Environmental Resources 2301 Market Street P. O. Box 8469 Philadelphia, Pennsylvania 19101 Harrisburg, Pennsylvania 17105-8469 Mr. Rod Krich 52A-5 Mr. James A. Muntz Philadelphia Electric Company Superintendent-Technical 955 Chesterbrook Boulevard Limerick Generating Station Wayne, Pennsylvania 19087-5691 P. O. Box A Sanatoga, Pennsylvania 19464 Mr. David R. Helwig, Vice President Limerick Generating Station Mr. James L. Kantner Post Office Box A Regulatory Engineer Sanatoga, Pennsylvania 19464 Limerick Generating Station P. O. Box A Mr. John Doering Sanatoga, Pennsylvania 19464 Plant Manager l

Limerick Generating Station Library P.O. Box A US Nuclear Regulatory Commission Sanatoga, Pennsylvania 19464 Region I 475 Allendale Road Regional Administrator King of Prussia, PA 19406 U.S. Nuclear Regulatory Commission Region I Mr. Larry Hopkins 475 Allendale Road Superintendent-Operations King of Prussia, PA 19406 Limerick Generating Station P. O. Box A Mr. Neil S. Perry Sanatoga, Pennsylvania 19464 Senior Resident Inspector US Nuclear Regulatory Commission P. O. Box 596 Pottstown, Pennsylvania 19464

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Mr. Craig L. Adams Superintendent - Services Limerick Generating Station P.O. Box A Sanatoga, Penn_sylvania 19464 v

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i ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED REVISIONS TO THE LIMERICK GENERATING STATION, UNITS 1 AND 2, TECHNICAL SPECIFICATIONS RELATING TO 24-MONTH FUEL CYCLE INSTRUMENTATION SURVEILLANCE REQUIREMENTS DOCKET NOS. 50-352 AND 50-353 TECHNICAL SPECIFICATIONS CHANGE REQUEST 92-03-0, OCTOBER 15, 1992 1.

Your submittal of October 15, 1992, references the establishment of an ongoing trending program and briefly describes the elements of the program.

However, you stated that the trending program "will be performed until such time as we determine that further evaluation is no longer necessary." The requirements of Generic Letter (GL) 91-04 do not provide for the discontinuing of the trending program at the licensee's discretion.

Further, continuing review of surveillance test results can provide important data for the evaluation of system performance /

surveillance intervals that are suggested by the GL and 10 CFR 50.62.

State if you plan to follow the above staff position.

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2.

You have stated that the " General Electric Instrument Trending Analysis System" (GEITAS) program referenced in your submittal is based on the drift methodology included in General Electric (GE)," Instrumentation Setpoint Methodology-Topical Report NEDC-31336." Provide a discussion of the verification and validation process utilized by GE in developing the GEITAS program for safety-related applications. 'You should include a discussion of applicable standards and guidelines, including differences from the standards used in development of the GEITAS software (GE specific and ANSI /IEEE-ANS-7-4.3.2-1982, and/or others).

3.

You have stated that you have not revised any 18-month setpoint or acceptance criteria, since the projected 30-month drift values were bounded by the existing acceptance criteria.

Further, that the GE setpoint methodology has been used only for the determination of drifts.

Provide details as to what methodology was used for the original setpoint calculations developed for Limerick. Also, discuss the compatibility of both methodologies with regard to instrument drift uncertainty.

Specifically, state if the results of the GE drift methodology is directly comparable to the existing Limerick drift allowances with regards to i

extended surveillance intervals.

4.

Confirm-thtt~the vendor's maintenance and surveillance requirements have been evaluated and found to be acceptable for a 24-month surveillance interval.

5.

In your submittal of October 15, 1992, you state that an historical search was performed on surveillance test re:ults. Confirm that the historical review also evaluated any applicable maintenance records (e.g., corrective maintenance, INP0 reports, service information letters (SIls), etc.)

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The referenced Rosemount drift report (D8900126) documenting a 30-month drift term for transmitter Models 1152, 1153, 1154, indicates that only 4 transmitters were included in the long-term testing program.

The test results show that all 4 transmitters remained bounded by the published stability specification for the 30-months criteria. The staff feels that a total of 4 transmitters does not appear to provide a large enough sample size to determine an accurate stability / drift specification for these transmitters. Discuss the validity of using these test results as being representative of the population performance of transmitter Models 1152, 1153, and 1154.

Further, discuss the applicability of the Rosemount test for evaluating the present timerick drift allowances over a 24 month-surveillance interval.

7.

You have stated that a 24-month surveillance interval for the Bailey I

instrumentation referenced under " Reactor Coolant and Containment Leakage Systems Instrumentation" and " Monitoring Instrumentation," is based on adequate performance for the 18-month surveillance interval. Discuss this

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conclusion with regards to the requirements of GL 91-04.

Based on the lack of data, it would be expected that published vendor drift specifications would be evaluated and expanded to a 30-month drift term utilizing the referenced GE setpoint methodology. Discuss why this approach was not taken for this instrumentation.

8.

You have stated that GE-NUMARC steam leak detection instrumentation is scheduled to be installed during the Winter 1992-1993 outage. Confirm that this equipment has been installed and that the justification for extending the surveillance intervals for this instrumentation remains valid.

9.

You have stated for the seismic monitoring instrumentation that a 30-month drift value is provided by the vendor (Kinemetrics: Models FBA-3, SMA-3 and TS-3, Engdahl Model PAR 400).

Provide a copy of the Vendors documentation or confirm that this information is identical to that already submitted under the parallel Peach Bottom Atomic Power Station Technical Specifications amendmer,t request.

10. You have stated that the Loose Parts Monitoring (e.g., Attachment 1, Page 25) instrumentation has a more frequent calibration check than 18 months, not including sensors. State if the sensors are currently included-4nd41e-18-month calibration. Also, describe the testing of the sensors and provide a discussion as to why they are not included, ce required, for the evaluation of a 24-month surveillance extension.

(Include vendor information and/or sensor characteristics).

11. You have stated for the reactor core isolation cooling low pressure bearing oil temperature instrumentation that insufficient data points were available for the GE drift program.

Further, historical data is identified as sufficient justification to exter.d the surveillance interval.

Discuss this conclusion with regards to the guidance given by GL 91-04. Also discuss why vendor information was not used when projecting a 30-month drift term.

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. 12. We understand that the suppression chamber water temperature indication loops have been recently installed on the remote shutdown panel, and that as a consequence, an insufficient number of data points are available to satisfy the GE drift analysis.

Further, your submittal states that to date, surveillance calibration has been satisfactory and within existing surveillance drift allowances. Discuss the reasons why vendor information was not used to determine the acceptability of a 24-month surveillance interval for this instrumentation, utilizing reference to the guidance of GL 91-04. Also, note and discuss why the referenced intervals and the limited available data for this instrumentation provide a drift value that gives adequate assurance that the representative instrument drift will remain within the tolerance limits for the entire surveillance interval.

13. The data for the downscale and high voltage trip instrumentation for the primary containment gaseous radiation monitor were not evaluated for drift using the GE drift methodology.

Based on successful calibration data over a period of 46 months you determined that a 24-month surveillance interval would be acceptable. Discuss why vendor data was not used to project a 30-month drift term for this instrumentation and how the present drift evaluation satisfies the requirements of GL 91--04.

14. You have stated in your submittal that GE NUMAC equipment is utilized for various radiation monitoring loops.

Provide documentation that supports the proposed extended 24-month surveillance interval.

State if this documentation provides for a 30-month extension for the sensor interval.

Also, if the sensor is not included in the GE documentation provide a discussion as to the acceptability of extending the sensors' surveillance interval to 24-months.

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15. You have stated that the existing Bailey recorders for the refueling and ventilation exhaust duct radiation monitoring instrumentation is being replaced with instrumentation that satisfies the drift requirements for a 30-month surveillance interval.

Provide written confirmation of the 30-month drift interval specification for this instrumentation.

16. We understand that the hydraulic control unit pressure switches were found to exceed the surveillaace test allowance for 18-months and that you addressed this problem through a TS change request revising the setpoint as suggested by GE SIL No. 429.

Currently the TS require that the pressure in tte scram accunsulators be checked every 7 days.

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pressure read by the operator independent from the pressure switch?

Provide confirmation that the appropriate procedures (indicate appropriate pages) have been revised to reflect the TS setpoint change.

17. State if the NUMAC steam detection and radiation monitoring instrumentation has been installed as a modification to the plant under the 10 CFR 50.59 process.

If these modifications have been performed, provide a copy of the applicable 10 CFR 50.59 evaluation (steam leak only).

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18. Provide the resulting drift term probability and confidence interval as determined by the GE methodology.

Identify if the probability / confidence interval is 95/95 or 95/50. Also, state if the resulting drift term, as determined by the GE drift methodology, is a two-sigma, single-sided term.

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