ML20083B969

Discusses Util Submittal of TSs Change Request 93-16,which Requested Changes to App a of Facility License for Plant. Forwards Info Provided During 950410 Conference Call

ML20083B969
Person / Time
Site:	Peach Bottom
Issue date:	05/08/1995
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9505150032
Download: ML20083B969 (9)

Text

__-_ _____ - - -_ - __-_-____- __________-_ - ____-_-___ __ _

Station Support Department -

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PECO ENERGY Somaf=:::,,e,,

965 Chesterbrook Boulevard l

Wayne, PA 19087 5691 May 8,1995 Docket No. 50-277 50-278 j

Ucense Nos. DPR-44 l

DPR-56 l

l U.S. Nuclear Regulatory Commission t

Attn: Document Control Desk i

Washington, DC 20555 l

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SUBJECT:

Peach Bottom Atomic Power Station, Units 2 and 3 Supplement 5 to TSCR 93-16 Conversion to improved Technical Specifications l'

REFERENCES:

1)

Letter from G. A. Hunger, Jr. (PECO Energy) to USNRC dated September 29,1994 2)

Letter from G. A. Hunger, Jr. to USNRC dated March 3,1995

Dear Sir:

In Reference 1), PECO Energy Company submitted Technical Specifications Change Request (TSCR) 93-16, requesting changes to Appendix A of the Facility Operating Ucenses for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. This TSCR proposed an overall conversion of the current PBAPS Technical Specifications (TS) to the Improved Technical Specifications (ITS), as contained in NUREG 1433,

" Standard Technical Specifications, General Electric Plants, BWR/4."

Reference 2 is Supplement 1 to Reference 1.

By conference call on April 10,1995, PECO Energy provided follow-up information to a previously submitted response (Reference 2) to an NRC request for additional information regarding ITS Section 3.3. The information addressed NRC questions which were transmitted to PECO Energy via facsimile on March 29,1995. At the conclusion of the call, the NRC requested that PECO Energy formally submit the follow-up information. Accordingly, attached is the information provided during the call. The NRC follow-up question, (along with its Reference 2 designation), is restated below followed by the PECO Energy response.

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PDR ADOCK 05000277 i

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May 8,1995 Page 2 l

l if you have any questions concerning this submittal, please contact us.

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Sincerely, t

u $ 5Sffon G. A. Hunger, Jr.,

Director - Licensing Affidavit, Attachment cc:

T. T. Martin, Administrator, Region I, USNRC W. L Schmidt, Senior Resident inspector, PBAPS, USNRC l

R. R. Janati, Commonwealth of Pennsylvania l

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COMMONWEALTH OF PENNSYLVANIA

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l COUNTY OF CHESTER W. H. Smith, Ill,' being first duly sworn, deposes and says:

That he is Vice President of PECO Energy Company; the applicant l

herein; that he hes read the attached Ucense Change Request (LCR 93-16, Supplement 5) for changes to the Peach Bottom Facility Operating Ucense DPR-44, 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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. Vice President [/

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Subscribed and sworn to i

before me this day of M' 1995.

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1 Attachment j

i Response to Questions Regarding improved

, i Technical Specifications Secten 3.3 l

1 NRC Question 2Al-1 (PECO Energy Response A-1.c, p. 2)

The required RPS response time testing of the Current Technical Specifications (CTS), from the opening of the sensor contact up to-and including the opening of the trip actuator contacts, is not carried over to the ITS. While the NUREG-1433 definition of RPS l

Response Time and the associated test requirements differ (from 1

the point the process exceeds the trip setpoint to the de-1 energization of the scram pilot valve solenoid), excluding any RPS response time testing from the ITS does not appear acceptable.

l This issue requires further discussion between PECO and the NRC staff.

i PECO Energy Response to NRC Question 2Al-1 The basis of the current RPS response time test requirement (from -

l UFSAR Section 7.2.3.9) is to confirm the system electrical

-l characteristics regarding response time are maintained consistent with the original design. The current RPS response time j

requirements apply to all RPS functions that have calibration requirements, even those that are not credited in the safety analysis as providing a scram. Additionally, the current RPS response time test acceptance criteria for the RPS functions is $50 milliseconds. Typical BWR RPS response time acceptance criteria from the safety analysis for the various RPS functions range from j

0.06 seconds to 1.05 seconds. Therefore, it is concluded the existing PBAPS RPS response time requirements verify design requirements, not analysis assumptions.

The NRC evaluation of BWR Owners Group Ucensing Topical Report NEDO-32291, " Systems Analyses for Elimination of

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Selected Response Time Testing Requirements," forwarded to the BWR Owners Group in a letter dated December 28,1994, from B.

A. Boger (NRC) to R. A. Pinelli (BWR Owners Group) states the following with regard to the intent of the response time tests in Technical Specifications:

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,"The intent of these tests is to ensure that changes in response time of instrumentation beyond the limits assumed in safety analyses are detected, and combined with instrument calibration, to ensure that the instrument is operating correctly. The response time tests do not demonstrata that the instrument response time design value is met, bu'. rather that die specified performance requirements of the TSs are satisfied."

The response time performance requirements specified in the Standard Technical Specifications (STS) are the limits assumed in the safety analyses. Since the RPS response time requirements specified in the current PBAPS Technical Specifications are design values, these requirements do not meet the intent of the STS response time testing requirements. Further, PECO Energy in the development of the PBAPS ITS has tried, to the extent practical, to

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maintain in the Technical Specifications only those requirements which are derived from safety analysis assumptions. Since the i

existing RPS response time requirements do not verify safety

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analysis assumptions and do not meet the intent of the STS response time testing requirements, the relocation of current PBAPS response time requirements is considered to be consistent with the purpose of Technical Specifications as published in the NRC Final Policy Statement on Technical Specifications improvements.

NRC Ouestion 2Al-2 (PECO Energy Response A-1.u, pp. 8 & 9) l The subject change is identified as a relocation of the 92-day logic system functional test to procedures. The response to our previous question reads as if the 92-day requirement is being eliminated. Please explain the status of the 92-day requirement in the conversion to ITS. Will procedures implement the testing every 92 days in addition to the refueling based testing?

PECO Energy Response to NRC Ouestion 2Al-2 The 92 day ADVS-RPT l_ogic System Functional Test (which i

excludes recirculation pump trip) was added to the CTS to address an issue in the NRC Safety Evaluation Report (SER) dated 12/21/88 regarding PBAPS Units 2 and 3 compliance with the ATWS rule for the ARI and RPT Systems. The stated NRC concern was that, for the trip units and logic, a once per operating cycle functional test frequency had not been accepted. In this 2

s SER, the NRC provided draft model Technical Specifications for the ARl/ATWS-RPT Instrumentation which recommended a "once per quarter" test frequency for the functional test of the instrument

i channel and the actuation logic.

PBAPS chose to implement this requirement as a' 3 month logic '

l system functional test that excluded actuation of the end device.

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However, the intent of the requirement, as stated in the NRC SER,

. was to perform a functional test of the trip units and the actuation l

logic. At PBAPS, separate tests are performed for the Channel '

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Functional Test and the 92 day Logic System Functional Test of ARl/ATWS-RPT Instrumentation. As part of the current PBAPS

-l Channel Functional Test for ARl/ATWS-RPT instrumentation, 1

actuation of the trip units and logic is performed and is considered l

to be required by the definition of Channel Functional Test.

.i" The proposed PBAPS ITS Frequency for the Channel Functional Test of the ATWS-RPT Instrumentation is once per 92 days. As a result, no additional requirement (the 92 day Logic System Functional Test) is required in the PBAPS ITS to satisfy the intent of the NRC requirement to functionally test the. trip units and actuation logic on a 92 day frequency. The requirement in SR l

3.3.4.2.3 of NUREG-1433 (Calibrate the trip units once per 92 -

i days) is similar to the PBAPS CTS requirement in that it provides

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additional requirernents for the trip units with a frequency of 92 days. However, the basis for the requirement of NUREG-1433 SR l

3.3.4.2.3 is different. SR 3.3.4.2.3 was derived from the requirements imposed for the GE Analog Transmitter Trip j

Systems,. The requirement of SR 3.3.4.2.3, as stated in the Bases 1

of NUREG-1433, provides a check of the actual setpoint at the trip unit. This requirement is essentially a'setpoint verification that is :

1 performed when a Channel Functional Test is performed on the channel.

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This method of setpoint verification, currently performed as part of the Channel Funct!onal Test for the ARl/ATWS-RPT Instrumentation, has been successfully utilized at PBAPS for a number of years. No additional Technical Specification requirements for setpoint verification were required by the NRC during the licensing of the PBAPS ARl/ATWS-RPT Instrumentation.

In addition, the ITS definition of Channel Functional Test is interpreted to require that verification of the trip unit setpoint is within the Allowable Value since the Channel Functional Test requires a demonstration of Operability. The PBAPS ITS Frequency for the Channel Functional Test of the ATWS-RPT 3

6 Instrumentation is proposed to be once per 92 days. Therefore, the requirements of NUREG-1433 SR 3.3.4.2.3 are not necessary to ensure the trip unit setpoint is verified once per 92 days.

Foxboro electronic trip units from the reactor level compensation instrumentation are used in the ARl/ATWS-RPT Instrumentation.

Foxboro electronic trip units from the reactor level compensation instrumentation are also used by ECCS Instrumentation, RCIC Instrumentation, PAM instrumentation, and Remote Shutdown instrumentation. No requirements regarding 92 day Logic System Functional Tests of trip units and logic for instrumentation, other than ARl/ATWS-RPT Instrumentation, were imposed to assure OPERABluTY of instrumentation.

In addition, a review of the test history of the 92 day Logic System Functional Test for ARl/ATWS Instrumentation was performed.

This review included all tests performed on both units since the testing requirements were imposed in March 1989. The results of this review were that no failures associated with the trip units or actuation logic were identified.

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As a result of the discussions above, it is concluded the proposed relocated requirement (the 92 day ATWS-RPT Logic System Functional Test that excludes recirculation pump trip) is not necessary to assure OPERABluTY of the ATWS-RPT Instrumentation and may be relocated to procedures controlled by 10CFR50.59.

NRC Ouestion 2Al-3 (PECO Energy Response A-8, p. 22)

In response to NRC Ouestion A-8, PECO Energy stated that the following instrument functions have not had a drift analysis completed:

a. MSIV Closure

b. Turbine Stop Valve Closure

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c. HPCI Pump Discharge Flow

d. Core Spray Pump Discharge Flow

e. LPCI Pump Discharge Flow

f. HPCI Steam Une Flow

g. RCIC Steam Une Flow

h. RWCU Flow 4

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With no drift analysis completed, on what basis is'the acceptability ~

of tho' allowable value for these function' ?

s PECO Energy Response to NRC Ouestion 2Al-3 Items a. & b. utilize NAMCO limit switches to generate the -

associated trip function. Items c. through h. utilize Barton 1

differential pressure switches to generate the associated trip functions. The Allowable Values established in the ITS for these j

trip functions are acceptable for the following reasons-l 1.

Both the NAMCO limit switches and i e Barton j

differential pressure switches are mechanical devices.

During switch calibration the actuation point is set 3

and then tightened in place by a mechan

• cal locking mechanism. As such, these devices do not experience drift similar to what may be experienced l

in an electronic device.

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We have not experienced any unusual problems with these devices during calibration or functional tests.

The acceptance criteria for calibration is more -

restrictive than the Allowable Values established for ITS. Hence we.have a high degree of confidence that the Allowable Values established for ITS are 4

acceptable.

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Historically, calibration of the NAMCO limit switches l

(items a. and b.) has been performed once per l

operations cycle. The limit switches have been _

functionally tested on a more frequent periodicity to-verify switch actuation and valve position indication.

l Historically calibration of the Barton differential pressure switches (items c. through h.) has been performed at a frequency of at least once per i

operations cycle. The differential pressure switches are functionally tested on a more frequent periodicity during either system or switch functional testing to verify actuation of the associated trip functions.

Hence, we have a high degree of confidence that unacceptable trends in switch performance will be identified in a timely manner.

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Calibration failures are monitored in the Instrument Surveillance Program at PBAPS to identify unacceptable trends in calibration failures. If I

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i unacceptable trends are identified, investigative actions are completed to identify the' root cause of

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the trends. Corrective actions appropriate to address the root cacse are identified and implemented. Hence we are confident that unacceptable trends in calibration failures will be i

identified and appropriate corrective action taken to address the root cause of the trend.

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