ML20082B212

Revised Page 4 to TS Change Request 90-03

ML20082B212
Person / Time
Site:	Peach Bottom
Issue date:	03/23/1995
From:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20082B204	List: ML20082B203 ML20082B212
References
NUDOCS 9504050061
Download: ML20082B212 (1)

Text

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1

' Dock ,3 Nos. 50-277

.;- J.; 50-278 )

License Nos. DPR-44 i DPR-56

• - In addition to verifying the applicability of the Licensing Topical Reports to PBAPS, the PECO Energy evaluation concluded that AOT and STI extensions were justified for PBAPS instrumentation not specifically addressed but similar to instrumentation in the Licensing Topical Reports. The Low Pressure Coolant injection (LPCI) System Bus Power Monitor, Core Spray _i System Bus Power Monitor, Automatic Depressurization System (ADS) System Bus Power L l Monitor, High Pressure Coolant injection (HPCI) System Bus Power Monitor, and, Reactor Core i isolation Cooling (RCIC) System Bus Power Monitor have an indication only function and are i e included in Reference 3 but only for the BWR 5 analyses. The Core Spray Sparger to Reactor )

Pressure Vessel d/p and LPCI Cross-Connect position indication are also indication only l functions. AOT and STI extensions are justified for these instruments because the redundancy - 1 in this instrumentation is either comparable to or more extensive than the redundancy of the instrumentation analyzed in the Licensing Topical Reports In addition, loss of the function for this indication only instrumentation has a less significant impact on plant safety than loss of an -

RPS or Emergency Core Cooling System (ECCS) function.

Similarly, the Reactor Low Pressure instrumentation (50 s Ps 75 psig), Core Spray Pump Start Timers, LPCI Pump Start Timers, HPCI Turbine High Flow Time Delays, and RCIC Turbine High Flow Time Delays are not specifically addressed in References 2 through 8. PECO Energy determined that AOT and STI extensions are justified for these instruments because: the redundancy in this instrumentation is either more extensive or comparable to the redundancy of 4

instrumentation analyzed in the Licensing Topical Reports; and, the instrumentation used for these functions is either the same or similar instrumentation to that analyzed in previous analyses. The primary difference is the function performed by the actuation instrumentation, .

which is not considered in the analyses in References 2 through 8. This approach for justifying l AOT and STI extensions for instruments not specifically addressed in the Licensing Topical l Reports is consistent with the approach used in References 7 and 8.

The 10CFR50.59 Safety Evaluation supporting the proposed changes also verified that the proposed changes will not have any affect on the timeliness of the identification and/or correction of instrument setpoint errors resulting from drift. The bases for this conclusion is the STI that wRl be extended are for the performance of instrument Channel Functional Tests.

Instrument calibration frequencies are not affected. Instrument Channel Functional Tests are defined in the PBAPS Technical Specifications as "the injection of a simulated signal into the channel to verify its proper response including, where applicable, alarm and/or initiating action."

During the performance of instrument channel functional tests, the instrument functions; e.g.,

alarms and/or trips, are verified but instrument setpoints are not verified, Instrument setpoints

, are verified during instrument Channel Calibrations which are required by Technical Specifications to be performed at a specified frequency, typically at intervals greater than once per quarter. PBAPS instrument setpoints are established based on the calibration interval required by PBAPS Technical Specifications and are not dependent on the assumption that the setpoint will be verified between required calibrations.

Although verification that instrument setpoints are within TS limits is not performed during Channel Functional Tests at PBAPS as was assumed in the SERs for References 2 through 8, verification that instrument setpoints are within limits is performed during instrument Channel Calibrations which are typically performed at intervals greater than once per quarter at PBAPS. l The proposed changes do not make any changes to the frequency for performing Instrument Channel Calibration surveNiance tests.

950'4050061 950323 PDR P

ADOCK 05000277 PDR

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