ML20082C078
| ML20082C078 | |
| 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) |
| References | |
| NUDOCS 9504060148 | |
| Download: ML20082C078 (4) | |
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Station Support Department 10CFR50.90 f
PECO ENERGY is: a,Te:s,,
965 Chesterbrook Boulevard Wayne, PA 19067-5691 March 30,1995 Docket Nos. 50-277 50-278 Ucense 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 Supplement 2 to TSCR 93-16 Conversion to Improved Technical Specifications
References:
(1)
Letter from G. A. Hunger, Jr. (PECO Energy) to USNRC dated September 29,1994 (2)
Letter from J. W. Shea (USNRC) to G. A. Hunger, Jr. dated January 31,1995
Dear Sir:
In Reference (1), PECO Energy Company submitted Technical Specifications Change Request USCR) 93-16, requesting changes to Appendix A of the Facility Operating Licenses for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. This TSCR proposed an overall conversion of the current PBAPS Technical Specifications US) to the improved Technical Specifications (ITS), as contained in NUREG 1435, " Standard Technical Specifications, General Electric Plants, BWR/4."
In Reference (2), the NRC requested further Information regarding a proposed modification to ITS Limiting Condition for Operation 3.0.5. In the enclosure to this letter, this request is restated followed by our response, if you have any questions, please contact us.
Very truly yours, o
G. A. Hunger, r.,
Director - Licensing Affidavit, Enclosure cc:
T. T. Martin, Administrator, region I, USNRC W. L. Schmidt, USNRC Senior Resident inspector, PBAPS R. R. Janati, Commonwealth of Pennsylvania 9504060148 950330 PDR ADDCK 05000277 T li P
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COMMONWEALTH OF PENNSYLVANIA ss.
COUNTY OF CHESTER W. H. Smith,111, being first duly sworn, deposes and says:
That he is Vice President of PECO Energy Company; the applicant herein; that he has read the attached Technical Specifications Change Request (TSCR) 93-16, Supplement 2, for changes to the Peach Bottom Facility Operating Ucenses 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 belief.
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V Vice President Subscribed and sworn to before me this dd day of N 1995.
8 D M Notary POblic 1
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Enclosure Peach Bottom Atomic Power Station, Units 2 and 3 Response to NRC Request for Additional Information NRC Request:
Improved Technical Specifications (ITS) Limiting Condition for Operation (LCO) 3.0.5 is a new requirement not contained in the Peach Bottom Atomic Pcmer Station (PBAPS) current technical specifications. ITS LCO 3.0.5 would allow equipment previously declared inoperable to be retumed to service under administrative controls to allow certain actions. These actions include demonstration of operability of the equipment being returned to service, demonstration of operability of other equipment, or demonstration that variables are within Ilmits. The proposed ITS LCO 3.0.5 is consistent with NUREG-1433 LCO 3.0.5 with one exception. NUREG-1433 does not currently allow equipment to be administratively returned to service to verify that variables are within limits. The addition of this allowance to all of the standard technical specifications (STS) NUREGs was previously proposed by the various owners groups and rejected by the NRC staff. The staff's reason for rejecting the proposed change was that the owners groups did not address the specific appilcations where such an allowance would be used or needed. Similarly, PECO Energy Company (PECO Energy) did not address such specific applications in their ITS submittal. The Bases for both NUREG-1433 and the PBAPS ITS discuss specific examples of when the allowance of LCO 3.0.5 would be needed to demonstrate the operability of the equipment being returned to service or to demonstrate the operability of other equipment.
However, when PECO Energy added the additional allowance to LCO 3.0.5 to demonstrate variables that are within limits, no additional Bases were added to provide a specific example of when this allowance would be needed. Please provide specific examples of when the allowance to verify that variables are within limits would be needed Once this information is received from PECO Energy, additional consideration of this specific change to the NUREG-1433 version of LCO 3.0.5 will be pursued on a generic basis. The results of the generic determination will then be applied to the PBAPS ITS.
PECO Energy Response:
LCO 3.0.5 and the associated Bases were proposed to be revised to provide the allowance for returning inoperable equipment to service in order to verify variables are within Technical Specification (TS) limits.
It w t iecognized that this change was rejected on a generic basis and that no plant-specific uniqueness justnes the change. However, PECO Energy submitted the change for consistency with the other sectans of the ITS. The Bases of LCO 3.0.2 refers to Inoperable systems and components and variables not being within limits as failures to meet the LCO which requires the Required Actions of the associated Con.'Itlons to be met. LCO 3.0.2 states that exceptions to this are provided in LCO 3.0.5. As currently writ:ea 5 NUREG-1433, LCO 3.0.5 is only applicable for Inoperable systems or components. However, t 00 : 15 states that it is an exception to LCO 3.0.2 for the system retumed to service under aamir.tt,trative control to perform required testing. Required testing can include not only the performance of systems testing, but the performance of tests that confirm variables are within required limits. Additionally, in the ITS if a variable cannot be verified due to an inoperable Primary Containment isolation Valve (PCIV) (which is closed in accordance with Required Actions of Specification 3.6.1.3),
Note 1 to the ACTIONS of Specification 3.6.1.3 allows the PCIV to be reopened. Therefore, the LCO 3.0.5 allowances in NUREG-1433 are inconsistently appfled and are inconsistent with the allowance of Note 1 to the ACTIONS of Specification 3.6.1.3.
Two examples of when the proposed modification to LCO 3.0.5 would be needed are as follows.
Example 1:
To meet current TS Surveillance Requirement (SR) 4.6.B.1 and ITS SR 3.4.6.1, a sample of reactor water needs to be taken and tested every 7 days and verified to be within required TS limits for Reactor
- Coolant System (RCS) Specific ActMty. This sample is normally taken from the Reactor Water Cleanup (RWCU) influent line. However, when RWCU is out of service due to regeneration of a domineralizer or maintenance work, this sample needs to be taken from the Reactor Recirculation sample line. This sampic line has two primary containment isolation valves (AO-242 39 and AO-242-40). Occasionally, one of these valves may be inoperable due to extended stroke time or other reasons, yet the valve can still be stroked. Under these conditions, the inoperable valve is opened under the administrative control along with the other operable in-line valve to get the appropriate sample as required by TS. Once the sample is taken, the Inoperable valve is returned to the closed position.
Example 2:
improved Technical Specification 3.4.5, "RCS Leakage Detection Instrumentatk n," requires the continuous sampling of the containment atmosphere. When this limiting condition cannot be met, grab samples of the containment atmosphere are required to be taken every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. At PBAPS, under these conditions a grab sample must be taken via the Containment Atmosphere Dilution (CAD) sample lines. In accordance with procedure, a sample must be taken from a CAD line currently not being used to monitor containment H and O concentrations. In the event that a primary containment isolation 2
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valve was inoperable in each available CAD sample line, one line would need to have its inoperable valve unisolated for 15 minutes under administrative control in order to obtain a representative sample of the containment atmosphere.
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