ML20082C001
| ML20082C001 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/30/1995 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20082C005 | List: |
| References | |
| NUDOCS 9504060119 | |
| Download: ML20082C001 (6) | |
Text
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i PECO ENERGY ecco c" <av c -re"v -
Nuclear Group Headquarters 965 Chesterbrook Boulevard Wayne, PA 1908M691 1
March 30,1995 l
Docket Nos. 50-277 50-278
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- U. S. Nuclear Regulatory Commission j
ATTN: Document Control Desk i
Washington, DC 20555 i
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Subject:
Peach Bottom Atomic Power Station, Units 2 and 3 j
FacIlty Operating License Change Request 93-13, Supplement 1 Re%ronce Letter from G. A. Hunger, Jr. (PECO Energy) to NRC dated November 17,1994.
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Dear Gir:
1 The referenced letter transmitN PECO Energy Company's License Chal%e Request (LCR) 93-j 13 requesting changes to App ndix A of the Peach Bottom Atomic Power Station (PBAPS)
FacIlty Operating Licenses.
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The proposed changes to the Technical Specificat'ons (TS) were requested to support i
Modifications 5384 and 5386, which upgrade the PBAPS Main Stack and Vent Stack Radiation i
Monitoring Systems.
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PECO Energy met with the NRC on February 23,1995 to discuss the proposed modifications and the associated LCR 93-13. At the conclusion of the meeting, the NRC requested that PECO j
Energy submit specific information presented at the meeting. This information is provided in l. Also included, as Attachment 2, is a revision to the originally subrnitted Discussion of Changes (item 2(c)), and its associated Safety Discussion (Change Request 2).
i Revisions to these sections were necessary to include the new allowable value for the " Main i
Stack Monitor, Trip Level Setting." We have concluded that this revision does not affect the l
conclusions previously submitted regarding a finding of No Significant Hazards Consideration or an Environmental Assessment Finally, the most current marked up Technical Specifications pages are included as Attachment 3.
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If you have any questions concoming this submittal, please contact us.
i Sincerely, 7.
. G. A. Hunger, Director - Licensing 1
Enclosures:
Affidavit, Attachment 1
i cc:
T. T. Martin Administrator, Region 1, USNRC l
W. L Schmidt, Senior Resident inspector, PBAPS, USNRC i
C 60 WhJanati, Conenwealth of Penns%tania
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9504060119 950330 PDR ADOCK 05000277 P
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i COMMONWEALTH OF PENNSYLVANIA
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i COUNTY OF CHESTER l
1 W. H. Smith,111, being first duly swom, deposes and says:
That he is Vice President of PECO Energy Company; the applicant herein; that he has read the attached License Change Request (LCR) 9313 Supplement 1, for changes to the Peach Bottom Facility Operating Ucenses DPR-44 and DPR-56, and knows the contersts thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, infamation and belief.
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Vice President Subscribed and swom to before me this b
day of 1995.
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Erica A.Santart. Notary Put$c TredyrmTwn,Chemer MyComrmsionEqxesMy10
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ATTACHMENT 1 PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-58 Facility Operating License Change Request 93-13, Supplement 1
" Main Stack and Vent Stack Radiation Monitoring System Upgrades
- Information Presented at the February 23,1995 Westing
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Peach Bottom Atomic Power Station, Units 2 and 3 AdditionalInformation Regarding LCR 93-13 Main Stack and Vent Stack Radiation Monitoring System Upgrades Electromannetic/ Radio-freouency Interference (EMI/RFI) Considerations A discussion regarding EMI/RFI was presented. PECO Energy stated that EMl/RFI performance has been concluded to be acceptable based on a comparison of vendor test results against plant sp3cific EMl/RFI mapping and consideration of location unique EMI/RFI influences. The lowest margin between test and mapped data was 12 db.
In addition, PECO Energy retained an independent EMl/RFI consultant to review the design of the fabricated equipment. Based on their recommendations, modifications were made to the vendor's standard design to improve its EMI/RFI performance The modified design has been subjected to more aggressive EMl/RFl susceptibuity testing (per EPRI TR 102323) than the original design and improvements have been noted.- Test anomalies were reviewed and determined to be acceptable for our installations.
Software Safeguards in the original submittal PECO Energy stated that the new radiation monitoring systems will have -
safeguards to prevent inadvertent changes to the software and systems parameters. During the February meeting, the NRC questioned what type of safeguards were in place and how they were controlled.
Changes to the new system's software are controlled through the use of keylocks. Access to the keys is controlled by PBAPS Administrative procedures.
Validation and Verification (V&V)
In the original LCR 93-13 submittal, PECO Energy stated that the vendor utRized methods and techniques endorsed by ANSl/IEEE-ANS 7.4.3.2 (1982), and ANS 10.4 (1987) for V&V of the new radiation monitoring equipment During the February meeting, PECO Energy stated that in addition to the vendor's program, which is overseen by their QA organization, PECO Energy personnel performed an independent assessment of the vendor's program. As a result of that assessment, it was concluded that the vendor maintains an ANSI /ANS 10.4 a posteriori V&V program.
Software Common Mode Falure The NRC questioned whether software common mode faHures were considered. PECO Energy stated that due to the fact that both the Main Stack and Vent Stack radiation monitoring systems are a single train design, a software common mode faHure is not a concern.
Environmental Odalification The NRC questioned whether PECO Energy had considered environmental qualifications other than EMI/RFI for the new equipment.
PECO Energy responded by stating that the new equipment is located in a mud environment. The environmental conditions present in the area where the equipment wNI be installed are contained in the new equipment specification (NE-125). The vendor is required to provide a Certificate of Conformance stating that the equipment meets the specification.
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ATTACHMENT 2 l
j PEACH BOTTOM ATOMIC POWER STATION 1
UNITS 2 AND 3 1
Docket Nos. 50-277 50-278 j
i License Nos. DPR-44 i
DPR-56 1
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Facility Operating License Change Request j
93-13, Supplement 1 a
" Main Stack and Vent Stack 2
j Radiation Monitoring System Upgrades
- Revision to Originally Submitted j
Discussion of Changes and Safety Discussion m
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Revision to Discussion of Chances l
Revise item 2) (c) as follows:
column for the " Main Stack Monitor," to read:
l Revise the ' Trip Level Settirp" Cl/cc" i
" Upscale, s 2.0x10' p 1
1 Revision to Safety Discussion. Chance Reauest 2:
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Currently, the Trip Level Setting for the Malq Stack monitor is expressed in counts per seconds (CPS).
As a result of modification 5386, the Trip Level Setting for the Main Stack monitor will be expressed in pCl/cc. The new allowable value of 2.0 x 10-2pCl/cc, which is used as the basis for the instrumert setpoint, is based on PECO Energy calculations. The engineering unit change from CPS to pCl/cc is
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justified because it is a more direct method for determining the level of radiation..The changes associated with the system description provide clarity when interpreting TS. Therefore, because these changes provide clarity and aid the operators in determinirg actual radiation, they are considered to be l
enhancements to safety.
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