ML20079S086
| ML20079S086 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/29/1994 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20079S088 | List: |
| References | |
| RTR-NUREG-1433 NUDOCS 9410170152 | |
| Download: ML20079S086 (10) | |
Text
St-tion Suwart DipIrtmsnt y- -
1sCFR50.90 v
. PECO ENERGY fBon;fm<,t;;;, s,,,,,
965 Chesterbrook Boulevard Wayne, PA 19087 5691 I l
September 29,1994 l r 1et Nos. 50-277 50-278 Ut ,nse Nos. DPR-44 DPR-56 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
Peach Bottom Atomic Power Station, Units 2 and 3 Technical Specifications Change Request 93-16
Dear Sir:
PECO Energy Company hereby submits Technical Specifications Change Request (TSCR) No. 93-16, in accordance with 10CFR50.90, requesting changes to Appendices A and B of the Peach Bottom Atomic Power Station (PBAPS) Facility Operating Ucenses. T' is submittal proposes to revise the Units 2 and 3 Technical Specifications (TS), in their entirety, to be consistent with NUREG-1433, " Standard Technical Specifications General Electric Plants, BWR/4." This overall conversion to the improved Technical Specifications (ITS) includes both technically justified deviations from the NUREG, and technically justified changes from the PBAPS current TS. Included with this submittal are the following eight attachments:
- 1. Application of Selection Criteria
- 2. Unit 2 Improved Technical Specifications
- 3. Unit 3 Improved Technical Specifications
- 4. Unit 2 Improved Technical Specifications Bases
- 5. Unit 3 Improved Technical Specifications Bases
- 6. Units 2 and 3 Comparison Document
- 7. Units 2 and 3 No Significant Hazards Consideration
- 8. Deviations from NUREG-1433 (Technical Specifications and Bases)
The enclosure to this letter provides a description of each attachment, inclu ing a brief discussion of how the submittal was prepared.
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~'>(J- 941017o132 94o929 N sjM PDR ADoCK 05000277 i P PDR
. Sept:mber 29,1994 l Pag 3 2 As you know, the ITS have served as the ultimate resolution for various industry generic issues. Similarly, PECO Energy has deferred resolution of several l l PBAPS issues to the conversion to ITS. Among the many improvements )
included in TSCR 93-16 are the resolutions to four docketed commitments. '
These four issues are as follows:
. In Licensee Event Report (LER) 2-88-012, PECO Energy committed to i propose a change to the TS to eliminate the need for the drywell high i range radiation monitors to be operable when the unit is in the Cold Condition. This proposed revision to the current TS is included in TSCR 93-16.
a PECO Energy letter to the NRC dated January 29,1991 provided a l supplemental response to Generic Letter 89-19, " Request for Action Related to Resolution of Unresolved Safety Issue A-47 Safety implication of Control Systems in LWR Nuclear Power Plants." in that letter, PECO Energy indicated that if reactor vessel overfill relays and )
contacts are included in the final version of NRC-approved ITS, then l they will be added to the PBAPS current TS as part of the overall conversion. The letter further indicated that if these relays and ,
contacts are not included in ITS, then no further action will be taken. '
NUREG-1433 does not contain reactor vessel overfill protection requirements since they were considered not to meet the NRC Policy Statement on Selection Criteria. However, vessel overfill protection is l addressed, coincidentally, in TSCR 93-16 by the addition of Digital l Feedwater Control System (DFCS) instrumentation requirements. The addition of these requirements is consistent with NUREG-1433 in that NUREG-1433 includes requirements for feedwater and main turbine high water level trip instrumentation. This instrumentation is credited for the PBAPS feedwater controller failure, maximum demand event.
These requirements are implemented through the use of DFCS l instrumentation, which also provides reactor vessel overfill protection.
In a letter dated June 23,1993, PECO Energy committed to add a surveillance requirement (SR) to operate the Standby Gas Treatment System every 31 days. PECO Energy indicated that this SR is included in NUREG-1433, and would be added to the current TS as part of the overall conversion to ITS. Accordingly, TSCR 93-16 contains SR 3.6.4.3.1, which incorporates this commitment.
In a letter dated July 1,1993, PECO Energy committed to include a requirement to perform a modified performance test of the station betteries as part of our conversion to ITS. This modified performance
[
test was described in a draft revision to IEEE Standard 450, dated May 5,1993. This commitment is included in SR 3.8.4.8 oi TSCR 93-
! 16.
l L
. Sept:mber 29,1994 Pcge 3 -
PECO Energy has conducted an extensive interdisciplinary review of the proposed PBAPS Units 2 and 3 Improved ~Iechnical Specifications and Bases to i ensure they accurately reflect the plant, the Updated Final Safety Analysis Report (UFSAR), and other pedinent documentation. j There are two outstanding open items relative to this submittal. The firct open item involves proposed Specification 5.6.6 which discusses the requirements for a Pressure and Temperature Limits Report (PTLR), and includes the references l to the analytical methods used to determine the limits. The analytical methods have been submitted to the NRC by General Electric Repod SASR 88-24, -,
i December 1991 (Unit 2), and SASR 90-50, June 1990 (Unit 3); however, a final Safety Evaluation Report (SER) approving the analytical methods has not been ,
issued. The NRC has issued amendments to the PBAPS Technical Specifications updating the P/T limit curves, which were developed using these documents. Therefore, the approval date listed in proposed Specification 5.6.6.b has not been provided, and issuance of an SER accepting the analytical r methods is needed for issuance of this amendment. The second open item ?!
involves proposed SR J.7.2.2 for the normal heat sink. Calculations confirming the adequacy of the 95* F temperature limit are being completed. Any changes to the proposed ITS resulting from these calculations will be communicated to the NRC.
t included in TSCR 93-16 are a number of new surveillance requirements which ,
have not been performed at PBAPS. PECO Energy intends to treat these new ,
surveillance requirements as being " met" at the time of implementation of the new Technical Specifications, with the first test to be performed within the >
required frequency from the implementation date. Any revisions to the UFSAR necessitated by the conversion to the improved Standard Technical Specifications will be submitted in accordance with the requirements of :
implementation of the proposed amendments is tentatively scheduled for the fourth quarter 1995. This date is based on the training schedules for both licensed and nonlicensed personnel, the timing of implementation with respect to refueling outages, the licensed operator examination schedules, and the time required for procedure revisions and development of new programs. PECO Energy will inform the NRC when ITS implementation actions are complete. The ,
implementation date of fourth quarter 1953 is also predicated on NRC issuance of an SER in the second quarter 1995. ;
PECO Energy Company requests to meet with you at your earliest convenience to discuss a review schedule and the contents of this submittal package.
Very truly yours, )
G. A. Hunger, J o1' Director - Licensing
. Sept:mber 29,1994
- Pag 3 4 Enclosure Attachments: 1. Application of Selection Criteria
- 2. Unit 2 Improved Technical Specifications
- 3. Unit 3 Improved Technical Specifications
- 4. Unit 2 Improved Technical Specifications Bases
- 5. Unit 3 Improved Technical Specifications Bases
- 6. Units 2 and 3 Comparison Document
- 7. Units 2 and 3 No Significant Hazards Consideration
- 8. Deviations from NUREG-1433 (Technical Specifications and Bases) cc: T. T. Martin, Administrator, Region I, USNRC W. L Schmidt, USNRC Senior Resident inspector, PBAPS R. R. Janati, Commonwealth of Pennsylvania
COMMONWEALTH OF PENNSYLVANIA :
t
- ss.
COUNT / OF CHESTER : ,
1 W. H. Smith, Ill, being first duly sworn, deposes and says: -
That he is Vice President of PECO Energy Company; the Applicant herein; that ,
he has read the foregoing letter and enclosure transmitting Technical Specifications Change Request (Number 93-16) for Peach Bottom Facility Operating Licenses DPR- ;
44 and DPR 56, 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 i
belief.
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Vice President ;
i Subscribed and sworn to o :
bei e me this O day off f '#" 1994.
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oL Notary Public Erb A. $,k p,g D '
xP e J YdIq95 e 1 m n - ,-
, ENCLOSURE PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS SUBMITTAL The Peach Bottom Atomic Power Station (PBAPS) Conversion to improved Technical Specifications (ITS) submittal consists of nine documents. These nine documents are contained in 15 volumes. Below is a listing of the attachments and a brief description of the volume contents. In addition, a brief explanation of how the material was prepared and the designations utilized are included.
ATTACHMENT 1 - APPLICATION OF SELECTION CRITERIA (Volume 1) 7 This volume provides a discussion of how the NRC Final Policy Statement was applied to the current Units 2 and 3 Technical Specifications. Also included is a matrix that :
cross references the following documents: 1) the current Technical Specifications (CTS); 2) the Standard Technical Specifications, or STS Rev. 4; 3) the proposed Technical Specifications, where applicable; and 4) the Final Policy Statement Selection criteria. For the current Technical Specifications that do not meet any of the criteria and are not retained in the ITS, an explanation of why each Specification does not meet the selection criteria is provided (Appendices A and B). These Specifications are proposed to be relocated to licensee-controlled documents.
ATTACHMENT 2 - UNIT 2 TECHNICAL SPECIFICATIONS (Volume 2)
ATTACHMENT 3 - UNIT 3 TECHNICAL SPECIFICATIONS (Volume 3)
These volumes contain the proposed Technical Specifications for Units 2 and 3 in the NUREG-1433 format. The current Specifications requirements that are to be relocated are not included in these volumes.
ATTACHMENT 4 - UNIT 2 TECHNICAL SPECIFICATION BASES (Volumes 4 and 5)
ATTACHMENT 5 - UNIT 3 TECHNICAL SPECIFICATION BASES (Volumes 6 and 7) l These volumes contain the proposed Technical Specifications Bases for Units 2 and 3. i information regarding the basis for each Specification, as well as details of what l comprises OPERABLE subsystems, is provided. j ATTACHMENT 6 - UNITS 2 AND 3 COMPARISON DOCUMENT (Volumes 8,9 and 10) i l
These volumes contain annotated copies of the CTS to show the disposition of the existing requirements into the iTS. Also contained in these volumes are discussions of each of the proposed changes. The pages are in ITS order, e.g., ITS 3.5.1 (ECCS-Operating) contains all appropriate pages that address current ECCS requirements in 3
the CTS, as well as the LPCI swing bus requirements in CTS Section 3.9 since the 1 LPCI swing bus requirements will now reside in ITS Section 3.5.
1
ENCLOSURE PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS SUBMI' ITAL The CTS pages reflect all issued Amendments as of September 1,1994 and TSCRs submitted as of September 1,1994. Exceptions to this are TSCR 93-02 (MCPR-RPT) and TSCR 90-03 (Instrumentation Allowed Outage Times and Surveillance Test interval Extensions). TSCR 93-02 was not included in the ITS submittal, even though submitted before September 1,1994, due to the delay in implementation of the associated Adjustable Speed Drive (ASD) modification at PBAPS. It is anticipated that upon resolution of issues associated with ASD, the ITS submittal would be revised to include the MCPR-RPT requirements proposed in TSCR 93-02. TSCR 90-03 is included in the ITS submittal, even though it was submitted after September 1,1994, since this change is an integral part of the changes for the ITS Instrumentation section and was planned to be submitted in parallel with the ITS.
Each CTS page is annotated with the ITS Specification number at the top of the page, reflecting the ITS location of the CTS requirements. Items on the CTS page that are located in ITS Specifications other than that referenced at the top of the CTS page, ;
have the appropriate location noted adjacent to the items. Where the ITS requirement differs from the CTS requirement, the individual details of the CTS being revised are l annotated with alpha-numeric designators which relate to an appropriate Discussion of !
Change (DOC). The DOC provides a concise justification for the change outlined. !
The DOCS associated with each ITS section are located after the marked-up CTS pages. The alpha-numeric designators also relate to the no significant hazards consideration (NSHC) evaluations contained in other volumes of the submittal. ,
The current PBAPS Technical Specifications Bases pages are not individually )
annotated, since they are being replaced in their entirety. However, so that all current 1 Technical Specifications pages can be accounted for, a page has been inserted behind the last DOC. This page details which CTS pages have not been included since they contain either CTS Bases pages or pages that indicate " intentionally left blank."
Current Technical Specifications pages containing requirements in more than one ITS Specification are repeated in the appropriate section(s). In this instance, portions of a single CTS Specification may relate to more than one ITS requirement, and as such, the requirement is contained within several ITS Specifications. For these CTS requirements, the CTS page is repeated for each ITS Specification, and may have l differing alpha-numeric designators (with corresponding different DOCS), e.g., Units 2 l and 3 CTS 3.5.B requirements are located in three ITS LCOs (3.6.2.3,3.6.2.4 and 3.7.1). Thus, the appropriate CTS pages are found in all three ITS sections of the CTS markups.
The alpha-numeric designators relating to the CTS changes are numbered sequentially within each letter category and within each ITS Specification. The changes for each CTS are separated into the following categories:
ENCLOSURE PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3
. IMPROVED TECHNICAL SPECIFICATIONS SUBMITTAL Designator Cateaorv A ADMINISTRATIVE - associated with restructuring, interpretation, and complex rearranging of requirements, and other changes not substantially revising an existing requirement.
M MORE RESTRICTIVE - changes to the CTS being proposed in converting to the ITS, resulting in added restrictions or eliminating flexibility.
R RELOCATED - specific requirements that do not meet the NRC Final Policy Statement selection criteria. These changes also include relocation of detail (such as details of system design and function, procedural d,etails or methods of conducting a surveillance) and alarm or indication - only instrumentation.
L LESS RESTRICTIVE - proposed changes where requirements are relaxed or eliminated, or new flexibility is provided. Each Less Restrictive change or group of changes has a corresponding unique NSHC, while there is a single NSHC for each of the other categories.
ATTACHMENT 7 - UNITS 2 AND 3 NO SIGNIFICANT HAZARDS CONSIDERATION (Volumes 11 and 12)
These volumes, containing the 10CFR50.92 required NSHCs, show that the proposed changes do not contain any significant hazard considerations. Many of the proposed changes are grouped together based on similarities; e.g., requirements that are administrative, certain types of less restrictive changes, more restrictive changes, and requirements proposed to be relocated.
The NSHC volumes are arranged by ITS Chapter and Section order. Generic NSHCs have been written for all categories of changes except Category "L". The NSHCs for each ITS Chapter and Section are ordered as follows: A, M, R, and L. Additionally, generic Environmental Assessments are located at the end of the NSHCs for each ITS Chapter or Section.
Each NSHC or category of NSHCs is annotated to correspond to each labeled DOC addressed in the NSHC. The NSHCs are provided in ITS order, consistent with the CTS markup and DOCS. For instance, an "L " change noted in the CTS markup for 3
ITS LCO 3.5.1 is labeled "L, Labeled Comment / Discussion for ITS 3.5.1" and is located in the NSHC section for ITS Section 3.5.
ENCLOSURE PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS SUBMITTAL ATTACHMENT 8 - UNIT 2 AND 3 DEVIATIONS FROM NUREG-1433 (Volumes 13,14 and 15)
These volumes contain a copy of NUREG-1433 (Specifications and Bases) annotated to compare the NUREG to the proposed PBAPS Improved Technical Specifications.
The annotations include any deviations made in either Unit's proposed Specifications.
The justifications for each deviation from the NUREG are found at the end of each Chapter or Section (e.g., justification for deviations for Section 3.1 Technical Specifications are found at the end of Section 3.1 Technical Specifications). A deviation affecting only one Unit is indicated beside the deviation (e.g., Unit 2 only).
For the purposes of determining deviations from NUREG-1433, the NUREG is considered to be NUREG-1433, dated September 28,1992, as modified by all generic changes submitted as of June 30,1994, whether or not they have been accepted, consistent with the generic change Matrix Rev.11 A dated June 10,1994.
There are three types of deviations identified -- Bracketed, Generic and Plant Specific.
The plant-specific deviations regarding items in brackets are annotated by a "B," the deviations due to generic changes in the NUREG are annotated by a "O," and the plant-specific deviations are annotated by a "P." The bracketed and plant-specific deviations cover all deviations that have not been submitted as a generic change.
Each type of deviations (bracketed, generic, and plant specific) is numbered sequentially.
All generic changes, accepted and pending, adopted by PBAPS are indicated on the applicable pages and annotated with a "C". The discussion of the origin of the generic change (e.g., NUREG change package BWR 18, item C1) is included in the Justification for Deviation section.
The PBAPS rationale for not adopting certain generic changes is based on plant-specific factors, that are annotated in the Deviation from NUREG-1433. These annotations follow one of the following formats:
- a. A non-adopted generic change that is small (i.e., a few words) and does not make the markup too difficult to read is annotated and lined out. A "P" designator is placed beside the line-out. The Justification for Deviation identifies the generic change package and the PBAPS rationale for not adopting the j change. !
l
- b. A large generic change is annotated by indic8 ting the NUREG change package number (e.g., Note added by BWR-18, item C1). The change is lined out, and a "P" number is placed beside the line out. The Justification for Deviation identifies the generic change package and the PBAPS rationale for not adopting the changa.
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ENCLOSURE PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS SUBMITTAL
- c. If the generic change is made to a section that has been deleted entirely (e.g., '
an LCO, ACTION, SR, or the applicable Bases), the deviation is identified in the markup near the lined-out section with words similar to "also modified by BWR-18 Item C1." The "P" deviation states the reason the original NUREG requirement was not adopted, and thus, did not adopt the generic change.
(The entire requirement is being deleted; thus, it appears unnecessary to state that a change to the NUREG is a'so not adopted.)
In addition, generic changes that have been proposed by the industry or NRC, and rejected by the other organization, yet are still being carried as "open" in the generic change matrix, have not been included in the NUREG markup.
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