ML20083B991
| ML20083B991 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/04/1995 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-NUREG-1433 NUDOCS 9505150049 | |
| Download: ML20083B991 (16) | |
Text
Ctation Support Department
- 'I I*
t PECO ENERGY n= e"~ ce-Nuclear Group Headquarters 965 Chesterbrook Boulevard Wayne, PA 19087-5691 May 4,1995 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Sut$act:
Peach Bottom Atomic Power Station, Units 2 and 3 Supplement 4 to TSCR 93-16 i
Conversion to improved Technical Specifications
References:
(1)
Letter from G. A. Hunger, Jr. (PECO Energy) to USNRC dated l
September 29,1994 i
Dear Sir:
In Reference (1), PECO Energy Company submitted Technical Specifications Change Request (TSCR) 93-16, requesting changes to Appendices A and B 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 (TS) to the improved Technical Specifications (ITS), as contained in NUREG 1433, " Standard Technical Specifications, General Electric Plants, BWR/4."
j Enclosed is our response to additional questions regarding ITS Sections 2.0,3.1,3.4, and 3.5.
If you have any questions, please contact us.
Very truly yours, l'
.a. Lpp.
G. A. Hunger, Jr.,
Director - Ucensing JLP/bgr Affidavit, Enclosure cc:
T. T. Martin, Administrator, Region I. USNRC W. L Schmidt, USNRC Senior Resident inspector. PBAPS R. R. Janati, Commonwealth of Pennsylvania 9505150049 950504 t
PDR ADOCK 05000277
=
P PDR 120020 i
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l COMHONWEALTH OF PENNSYLVANIA ss.
COUNTY OF'CHESTER.
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W.-H. Smith, III, 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 response to-
-l questions regarding Technical Specifications Change Request (TSCR 93-16, Supplement 4) for changes to the 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 belief.
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Vice Presideht s.
Subscribed and sworn to i
before me this day of 7f) 1995.
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Notary Public NotardSeaf Erica A Santsi.NowyPLhic Tredrnn kg. Chests County My Corrrr.astr.ExpresJA 10,1995 l'
PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 RESPONSES TO NRC QUESTIONS REGARDING IMPROVED TECHNICAL SPECIFICATIONS SECTIONS 2.0, 3.1, 3.4,
& 3.5 l
ITS SECTION 2.0 l
l NRC Question 1:
Is the plant document sited in the relocation discussion controlled by 10CFR50.597 i
PECO Energy Response regarding ITS 2.0, DOC R :
2 As stated in the 10CFR50.92 evaluation for Discussion of Change R3 for ITS 2.0, the licensee controlled document (in this case plant procedures) containing the relocated requirements will be maintained using the provisions of 10 CFR 50.59.
NRC Question 2:
Why is the TS requirement to notify the NRB within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a SL violation and to submit an LER on the violation to the NRB being relocated from the TS to plant procedures?
PECO Energy Response regarding ITS 2.0, DOC R :
2 The requirement to notify the NRB within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a safety Limit violation and to submit an LER on the violation to the NRB was relocated from the Technical Specifications to procedures based on approved generic change BWOG-09, C26, I
Revision 1.
This generic change to the ITS NUREGs deleted the offsite review notification and review requirements since ITS Chapter 5.0 no longer lists the offsite review function.
NRC Question 3:
What NRC approved safety analysis supports the ITS proposed change in required reactor vessel water level (378 inches above Level 0 in CTS versus 366 inches above Level 0 in ITS)?
PECO Energy Response regarding ITS 2.0, DOC L :
1 NEDC-32163P," Peach Bottom Atomic Power Station Units 2 and 3 SAFER /GESTR-LOCA Loss-of-Coolant Accident Analysis," dated January 1993, demonstrates, in the event of a LOCA with reactor vessel water level at the top of active fuel, the ECCS subsystems are capable of reflooding the core to the top of active fuel while maintaining peak clad temperature less than the acceptance criteria specified in 10CFR50.46.
A reactor level of 366 inches above reactor vessel 0 is equivalent to the top of active fuel (TAF).
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j PEACH BOTTOM ATOMIC POWER CTATION, UNITS 2 AND 3
-RESPONSES TO NRC QUESTIONS REGARDING' IMPROVED TECHNICAL SPECIFICATIONS SECTIONS 12.0,.3.1, 3.4,
& 3.5 j
ITS SECTION 3.1
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NRC Question ITS LCO 3.1.1, DOC Rg:
I Provide additional information on.the controls that will be i
placed on the details of the methods used to perform the l
Surveillance, after the details are' relocated to licensee j
controlled documents.-
i i
PECO Energy Response regarding ITS LCO 3.1.1, DOC R3 As stated in the 10CFR50.92 evaluation for Discussion of for ITS 3.1.1, the licensee controlled document change Rt (in this case plant procedures) containing the relocated j
requirements will be maintained using the provisions of 10 l
CFR 50.59.
NRC Question ITS LCO 3.1.2, DOC R :
3 Provide additional information on the controls that will be l
placed on the details of the methods used to perform the f
Surveillance, after the details are relocated to the Bases-and procedures.
l PECO Energy Response regarding ITS LCO 3.1.2, DOC Rt As stated in the 10CFR50.92 evaluation for Discussion of Change R3 for ITS 3.1.2, the licensee controlled document (in this case Bases and procedures) containing the relocated i
requirements will be maintained using the provisions of 10CFR50.59.
Further, the Bases Control Program in
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Specification 5.5.10 provides additional requirements for
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control of changes to the Bases.
NRC Question ITS LCO 3.1.2, DOC Ig:
Provide additional information correlating the time difference between full power month and 1000 MWD /T.
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PECO Energy Response regarding ITS LCO 3.1.2, DOC Ig:
l The Reactivity Anomaly Surveillance is currently required to
{
be performed every full power month.
As a result, the surveillance is performed every 31 days during normal power operation.
At approximately 22 MWD /T average core exposure per day, a Surveillance Frequency of 1000 MWD /T average core exposure is equivalent to approximately 6.5 weeks.
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PEACHLBOTTON' ATOMIC. POWER STATION, UNITS 2 AND 3' l
RESPONSES TO NRC QUESTIONS REGARDING IMPROVED TECHNICAL i
SPECIFICATIONS SECTIONS 2.0, 3.1, 3.4, & 3.5 1
NRC Question ITS LOO 3.1.3, DOC M :.
[
i ITS 3.1.3 DOC Ma states that with a_ stuck control rod (not l
fully inserted) the reactor must be in Cold Shutdown (Mode 4), in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in accordance with existing Specification j
3.3.2.a.
Specification 3.3.2.a states " reactor shall be
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brought to a shutdown condition within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />."
i Specification 3.3.2.a does not require that the reactor be brought to Cold Shutdown.
Provide' additional information to j
clarify this discrepancy.
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'PECO Energy Response regarding ITS LCO'3.1.3, DOC Ms Current Technical Specification (CTS) 3.3.A.2.a does state the reactor shall be brought to a shutdown condition within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in the event of a stuck rod.
However, for the purposes of justifying the change this was conservatively assumed to be the cold shutdown condition consistent with 4
the shutdown requirements specified in CTS 3.3.A.2.f for inoperable control rod separation requirements not being met.
NRC Question ITS LCO 3.1.3, DOC Ig:
Provide additional information describing how indication of i
a flux level change on nuclear instruments can demonstrate i
. control rod motion but does not demonstrate that a control 1
rod is coupled.
If sufficient friction is present to; uncouple the control rod from its drive, the rod would not follow the drive as it is being withdrawn.
PECO Energy Response regarding ITS LCO 3.1.3, DOC Ig:
As stated in the comment, if sufficient friction is present to uncouple the control rod from its drive, the control rod would not follow the drive being withdrawn.
In this case, the lack of neutron flux level change, if discernible, would be indicative of an uncoupled rod.
However, this is not a positive check that the-control rod is uncoupled since if sufficient friction is not present an uncoupled rod would follow the drive being withdrawn.
SR 3.1.3.5 verifies a control rod does not go to the withdrawn overtravel-position.
The overtravel feature provides a positive check of coupling integrity since only'an uncoupled control rod can go to the overtravel position.
This verification is required to be performed any time a control rod is withdrawn to the full out position or prior to declaring a control rod operable after work on the control rod or Control Rod Drive System that could affect coupling.
As a result, SR 3.1.3.5 provides adequate assurance that the control rods are 3
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o PEACH' BOTTOM ATOMIC POWER STATICN, UNITS 2 AND 3 f
RESPONSES TO NRC QUESTIONS REGARDING IMPROVED TECHNICAL
- SPECIFICATIONS SECTIONS 2.0, 3.1, 3.4,
& 3.5 l
PECO Energy Response regarding ITS LCO 3.1.~3, DOC Ig(cont'd)
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t coupled.
NRC Question ITS LCO 3.1.7, DOC Rz:
{
Provide additional information on the controls that will be placed on the details of the methods used to perform the i
Surveillance, after the details.are relocated to plant i
procedures.
PECO Energy Response regarding ITS LCO 3.1.7, DOC R :
2 As stated in the 10CFR50.92 evaluation for Discussion of I
Change R for ITS 3.1.7, the licensee controlled document (in this case plant procedures) containing the relocated i
requirements will be maintained using the provisions of 10 CFR 50.59.
l NRC Question ITS LCO 3.1.7, DOC Ig:
Provide additional information to clarify the following points in this DOC:
Item 1.
"The boron concentration limit of 9.82% weight was l
originally selected to enspre that the corresponding could be met with requiring heat tracing (i.e., normal area
. {
saturation temperature (43 F) including a 10 F margin temperature would be, sufficient to-maintain'SLC System temperature above 53 F)."
t Is the intent.of this statement trying to convey the fact i
that the correpponding saturation temperature (43 F) l including a 10 F margin could be met without requiring heat t
tracing?
Item 2.
"However, it is recognized that with the SLC System temperature above 53 F,
increased boron concentration may still not result in boron precipitation."
Is the intent of this statement trying to convey the fact that with the SLC System temperature above 53 F,
increased boron concentration may still result in boron precipitation?
PECO Energy Response regarding ITS LCO 3.1.7, DOC In:
Item 1.
The intent of the statement is that the corresponding boron saturation temperature (43*F) including a 10*F margin for a boron concentration limit of 9.82% weight can be met without requiring l
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PEACH BOTTOM ATOMIC POWER STATION,. UNITS 2 AND 3 RESPONSES TO NRC QUESTIONS REGARDING IMPROVED TECHNICAL SPECIFICATIONS SECTIONS 2.0, 3.1, 3.4,
& 3.5 PECO Energy Response regarding ITS LCO 3.1.7, DOC Ig (continued) heat tracing since the normal area temperature is
> 53*F.
Item 2.
The intent of this statement is that if boron concentration is above the boron concentration limit of 9.82% weight and SLC System temperature is > 53'F, then boron precipitation would still not result provided SLC boron concentration and temperature are within acceptable limits of Technical Specification Figure 3.1.7-1.
NRC ITS LCO 3.1.3 Non-Bracketed Plant Specific Change Ps:
Provide additional information to explain the following statement:
"However according to Section 1.3, Completion Times," the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> clock of Required Action A.2 does start."
Required Action A.2 has a completion Time of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and does not appear to meet the criteria of Section 1.3 for an extension.
Furthermore Bases B 3.1.3 describes the Completion Time of Condition A.2 as "MUST be disarmed in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />."
PECO Energy Response regarding ITS LCO 3.1.3, Non-Bracketed Plant Specific Change Pe-The Required Action A.2 referred to in the Discussion of Change Pe to NUREG-1433 is NUREG-1433's Required Action A.i of Specification 3.1.3 which is the PBAPS's Required Action A.3 of Specification 3.1.3.
The Completion Time of these Required Actions is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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- PEACH BOTTON ATOMIC POWER-STATION,-UNITS'2 AND'3
' RESPONSES TO NRC QUESTIONS REGARDING IMPROVED TECHNICAL SPECIFICATIONS. SECTIONS 2.0, 3.1, 3.4,
& 3.5-1 1
ITS SECTION-3.4 NRC Question 1:
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Provide documentation that changes to Technical Specification Bases are controlled by the facilities procedure that implements 10CFR50.59 requirements.
I PECO Energy Response regarding ITS LCO 3.4.1,. General:
j
~ Technical Specification Bases are controlled by the Bases l
Control Program in Specification 5.5.10.
Specification l
5.5.10.b states, " Licensees may make changes to Bases-without prior NRC approval provided the changes do not involve either of the following:
j A. change in the TS incorporated in the license; or l
A change to the UFSAR or Bases that involves an i
unreviewed safety question as defined in 10 CFR 50.59."
i NRC Question 2.
Discussion of the change has stated " Experience has
}
E determined that the weekly sampling required by proposed SR 3.4.6.1 and the requirements for monitoring main steam line and off-gas radiation levels is sufficient to ensure RCS i
specific activity ~ levels are not exceeded."
Also, Table I on page 145a of CTS requires continuously monitoring Stack Gas and Steam Line gross activity, j
4 Provide documentation as to why it is not necessary to retain.
the monitoring of main steam line and off-gas radiation-levels as part of Technical Specifications.
y PECO Energy Response regarding ITS LCO 3.4.6, DOC R :
3 1
Monitoring of main steam line and off-gas radiation levels f
are retained as part of Technical Specifications as follows:
Main Steam Line radiation monitoring requirements are provided in Technical Specifications by Function 11 i
(Main Steam Line-High Radiation) of Reactor Protection I
System Instrumentation Table 3.3.1.1-1 and by Function l
1.d (Main Steam Line Isolation - Main Steam Line-High i
Radiation) of Primary Containment Isolation L
Instrumentation Table 3.3.6.1-1.
Offgas radiation monitoring requirements are provided in Technical Specifications by Specification 3.7.5,
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offgas."
The combination of these Technical i-t h~
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PEACH BOTTOM ATOMIC POWER STATION, UNITS 2-AND 3 RESPONSES TO NRC QUESTIONS REGARDING IMPROVED TECHNICAL SPECIFICATIONS SECTIONS 2.0, 3.1, 3.4,
& 3.5 PECO Energy Response regarding ITS LCO 3.4.6, DOC R (Continued) 3 Specification requirements and the requirements of SR 3.4.6.1, RCS specific activity verification, provide adequate assurance that RCS specific activity will be maintained within required limits.
The other requirements specified in Table I of CTS 4.6.B are not necessary for assuring RCS specific activity is within required limits.
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NRC Question 3:
Section 5.6.6, Reactor Coolant System (RCS) Pressure and Temperature Limits Report (PTLR), of the ITS does not specify temperature limits for reactor vessel head bolting studs being under tension.
It also does not specify temperature limitations for starting recirculation pumps.
i Item 1.
Provide documentation that temperature requirements for reactor vessel head bolting studs being under tension i
are going to be contained in the PTLR.
Item 2.
Provide documentation that temperature limitations y
associated with starting recirculation pumps are going to be contained in the PTLR.
PECO Energy Response regarding ITS LCO 3.4.9, DOC R :
2 Item 1.
The temperature requirements for reactor vessel head bolting studs being under tension are to be contained'in the PTLR as specified in SR 3.4.9.5, SR 3.4.9.6, and SR 3.4.9.7.
Item 2.
The temperature limitations associated with starting recirculation pumps are to be contained in the PILR as specified in SR 3.4.9.3 and SR 3.4.9.4.
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PEACH ~ BOTTOM ATOMIC POWER STATION,. UNITS 2 AND 31 t"
RESPONSES TO NRC QUESTIONS REGARDING IMPROVED TECHNICAL i
SPECIFICATIONS' SECTIONS 2.0, 3.1, 3.4,
& 3.5 l
'. NRC Question 4:
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Provide documentation that changes to UFSAR are-controlled l
by the facility procedure for implementing itCFR50.59 1
requirements.
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LPECO Energy Response regarding ITS'LCO-3.4.9, DOC ' R :
10CFR50.59 provides the process'for making changes'to the.
l SAR.
At PBAPS, the SAR as-described in 10CFR50.59 includes the UFSAR.
PECO Energy Procedure LR-C-13, 10CFR50.59 Reviews,. requires 50.59 Reviews to be performed for. changes j
in the facility or procedures as described in the SAR which would or do make information in the SAR inaccurate or i
incomplete or which would or do violate a commitment stated in the SAR.
i NRC Question 5:
This change allows for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to comply with the LCO l
for reasons other than Thermo-hydraulic instablility.
The i
second part of the LCO for operation in single. loop requires-that RPS setpoints be adjusted for the Average Power Range Monitors Flow Biased High Scram.- It would appear that Action l
D.1 would allow up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to reset the APRM Flow Biased High Scram setpoints.
ITS section 3.3.1.1 requires l actions
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which are more restrictive than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to be taken if an
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instrument is determined to be inoperable.
i Provide information on what the time limits will be i
resetting the APRM Flow Biased High Scram.
l PECO Energy Response regarding ITS LCO 3.4.1, DOC Ig:
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Required Action D.1 of Specification 3.4.1 allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> i
to satisfy the LCO.
This would allv; 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to-i recalibrate the APRM Flow Biased High Scram setpoints if the i
unit was going to' stay in single loop operation.
- However, once the LCO is satisfied for either single loop or two loop l
operation, any subsequent calibration problems associated with the APRM Flow Biased High Scram channels would require entry into the applicable conditions of Specification
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3.3.1.1,
" Reactor Protection System Instrumentation."
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similar rationale holds true for the power distribution limits specified in the LCO.
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PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 l
l RESPONSES TO NRC QUESTIONS REGARDING IMPROVED TECHNICAL SPECIFICATIONS SECTIONS 2.0, 3.1, 3.4,
& 3.5 I
NRC Question 6:
Provide documentation of the current instrument check performed by CTS Table 4.2.E and why this instrument check is not a valid Channel Check as defined in the ITS.
I PECO Energy Response regarding ITS 3.4.5, DOC L :
1 There is only one equipment drain sump flow integrator and f
only one floor drain sump flow integrator.
The equipment drain sump collects identified leakage and the floor drain f
sump collects unidentified leakage.
Since the two types of leakage are different, comparing the indication of two integrators during a CHANNEL CHECK would not be a valid demonstration of OPERABILITY.
In addition, the readings of i
these two integrators could not be compared to any diverse instruments since the two integrators are the only means available to quantify leakage based on a meter reading.
NRC Question 7:
CTS 3.6.E.1 requires that "...the reactor shall be in a Cold Shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" and ITS section 3.4.2 a requires "Be in MODE 3" in "12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."
Placing the reactor in Cold Shutdown required temperature to be reduced to less than i
212 F if a Jet Pump was inoperable.
MODE 3 requires plant shutdown but does not require reduction in temperature.
Provide documentation that reduction in temperature is no longer required if a jet pump has been determined to be l
PECO Energy Response regarding ITS 3.4.2, DOC M :
3 In the CTS, the Applicability of the Specification 3.6.E,
" Jet Pumps," is whenever the reactor is in the startup or I
run modes (mode switch position as defined in CTS 1.0).
CTS 3.0.A states action requirements are applicable during the operational conditions of each specification.
As a result, to place the plant in a non-applicable condition in the case of a shutdown required by Specification 3.6.E, the mode switch can be placed in shutdown or refuel without requiring temperature to be reduced to S 212*F.
Placing the mode switch in shutdown is equivalent to MODE 3 in ITS.
As a result, temperature reduction is not required by the CTS if 1
a jet pump is inoperable.
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PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 RESPONSES TO NRC QUESTIONS REGARDING IMPROVED TECHNICAL SPECIFICATIONS SECTIONS 2.0, 3.1, 3.4,
& 3.5 NRC Question 8:
CTS section 4.C.2 required that drywell atmosphere i
radioactivity levels shall be monitored and recorded at least once per day.
The proposed change is performance of a CHANNEL CHECK.
Provide documentation that the proposed CHANNEL CHECK will monitor drywell atmosphere radioactivity l
levels or provide documentation that will identify where the requirement to monitor drywell atmospheric radioactivity levels on a daily basis.
PECO Energy Response regarding ITS 3.4.5, DOC M :
4 The performance of a CHANNEL CHECK of the primary containment atmospheric monitoring system will require the instrumentation readings to be observed (monitored).
NRC Question 9:
Provide documentation that RCS pressure and temperature are going to be monitored periodically during rod withdrawal to criticality.
PECO Energy Response regarding ITS 3.4.9, DOC M2 The Frequency of SR 3.4.9.2 requires RCS pressure and temperature to be verified to be within limits once within 15 minutes prior to control rod withdrawal for the purposes of achieving criticality.
This SR was added consistent with the requirements of NUREG-1433.
In addition, the Frequency of SR 3.4.9.1 requires RCS pressure and temperature to be verified to be within limits every 30 minutes during RCS heatup operations.
NRC Question 10:
CTS 3.6.F.2 required action be taken in accordance with CTS section 3.5.I and 3.5.K.
These items were not included in the change indicated on the marked-up page of CTS.
Provide documentation indicating the disposition of these requirements in the conversion to ITS, PECO Energy Response regarding ITS LCO 3.4.1, DOC At CTS 3.6.F.2 specified requirements applicable to single loop operation identified in other CTS sections to be initiated.
CTS 3.5.I contain the requirements for AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR) and CTS 3.5.K contains the requirements for MINIMUM CRITICAL POWER RATIO (MCPR).
These specifications do not contain specific actions relative to 10
1 PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3.
l RESPONSES TO NRC QUESTIONS REGARDING IMPROVED TECHNICAL SPECIFICATIONS SECTIONS 2.0, 3.1, 3.4,
& 3.5 PECO' Energy Response regarding ITS LCO 3.4.1, DOC A (continued) 3 single loop operation.
However, they do-contain: references to the COLR for the applicable limits.
Revision'A to TSCR 93-16-(PBAPS ITS Submittal) will add APLHGR requirements to the. single loon operation portion of LCO 3.4.1.
MCPR "j
requirements for single loop operation as proposed in LCO 3.4.1 of TSCR 93-16 are not impacted by' Revision A.
r NRC Question 11:
l
- Provide additional documentation that indicates what the applicability will be for performance of the' surveillance 3.4.9.3.
PECO Energy Response regarding ITS LCO 3.4.9, DOC Bn:
SR 3.4.9.3 is required to be met at any reactor steam dome pressure when the unit is in MODES 1, 2,
3, and 4.
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PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND'3:
RESPONSES TO NRC QUESTIONS REGARDING IMPROVED TECHNICAL SPECIFICATIONS SECTIONS 2.0,~3.1, 3.4,-&L3.5 l
ITS SECTION 3.5
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NRC. Question 1.
ITS section 5.5.11, Safety Function Determination Program (SDFP),- indicates-that it is implemented upon entry into LCO 3.0.6.
ITS D 0 3.0.6 states "When a support system LCO is not met due to a support system LCO not being met,..." TS Bases for 3.0.6 also indicates that it.only applies to systems with an LCO specified in TS.
This only applies to support systems that have their own LCO.
The licensee is proposing to relocate these requirements'outside of Technical Specifications.
LCO 3.0.6 would not be entered if compartment cooler was-inoperable so credit cannot be taken i
for performance of Specification 5.5.11.
Provide clarification of the justification for relocation of i
the requirements to ot'er licensee controlled documents.
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PECO Energy ResponF5 regarding ITS LCO 3.5.1, DOC R5 The basis for relocating the requirements of Specifications j
3.5.H and 4.5.H, Engineered Safeguards Compartments Cooling and Ventilation, is that these compartment coolers are l
support systems for HPCI, RCIC,=LPCI, and CS Systems.
These j
compartment coolers are not necessary to be included in the Technical Specifications to assure the supported systems are l
The' definition'of OPERABILITY suffices since it 1
requires these coolers to be OPERABLE for the HPCI, RCIC, LPCI, and CS Systems to be considered OPERABLE.
Discussion for ITS 3.5.1 will be revised.
of Change R3 NRC. Question 2:
{
Proposed ITS SR 3.5.3.5 will allow initiation of the RCIC'
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system due to an actual signal be used to satisfy the surveillance.
The requirement to " include automatic restart on low water level" is proposed to be relocated to the bases for SR 3.5.3.5.
An automatic restart on low water level signal will not always occur when RCIC is started due to an actual signal.
Provida documentation that explains how this requirement is satisfied if an automatic restart does not occur on an actual i
initiation.
PECO Energy Response regarding ITS LCO 3.5.3, DOC R2 If the actual initiation does not satisfy all the requirements of the SR, including those items in the Bases 12 i
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g" PEACH BOTTOM ATOMIC POWER STATION,-UNITS 2'AND 3
. RESPONSES TO NRC QUESTIONS REGARDING IMPROVED TECHNICAL I
SPECIFICATIONS SECTIONS 2.0, 3.1, 3.4,
& 3.5 i
PECO Energy Response regarding ITS LCO~3.5.3, DOC.Rg (continued):
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of the'SR, then the actual' initiation cannot be. credited
,j with' satisfying the entire SR..
In order to satisfy.the-entire SR in this situation, the requirements not satisfied-l would have1to be tested separately and in such a manner that adequate overlap exists between the requirements satisfied by'the actual initiation and the requirements being tested separately.
l URC Question 3:
l This question is~similar to the previous question.- Proposed i
ITS SR 3.5.3.5 will allow initiation of the RCIC system due to an actual signal be used to satisfy the surveillance.
l The requirement to " verify automatic-transfer from CST to Suppression Pool on low CST water level" is proposed'to be relocated to-the bases for SR 3.5.3.5.
Aa automatic transfer from CST to Suppression Pool on.'.ow CST water level will not always occur when RCIC is started due to an actual r
signal.
Provide documentation that explains how this requirement-is satisfied if an automatic restart does not occur on.an 1
actual initiation.
PECO Energy Response regarding ITS LCO 3.5.3, DOC Ra:
I If the actual initiation does not satisfy all the requirements of the SR, including those items in the Bases of the SR, then the actual initiation cannot be credited with satisfying-the entire SR.
In order to satisfy the entire SR in this situation, the requirements not satisfied would have to be tested separately and in such a manner that adequate overlap exists between the requirements satisfied by the actual initiation and the requirements being tested i
separately.
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-l PEACHLBOTTOM ATOMIC' POWER. STATION, UNITS 2 AND 3 RESPONSES.TO NRC-QUESTIONS REGARDING IMPROVED TECHNICAL SPECIFICATIONS SECTIONS 2.O, 3.1,-3.4,
&_3,5 NRC.Questionf4:
This question is similar the questions concerning RCIC.
1 Nun basis for SR 3.5.1.10 state "This SR'also ensures-that the HPCI' System will. automatically restart-on an RPV_ low water-i
~ level _(Level-2) signal received subsequent to an RPV high water level (Level 8) trip and_that the suction is automatically. transferred from the CST to the suppression.
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pool.
On automatic initiation the functions do not always occur.
Provide documentation that explains how this requirement is j
satisfied if an automatic restart does not occur on an a
actual initiation.
l PECO Energy Response regarding ITS LCO 3.5.1, DOC A :
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If the actual initiation does'not satisfy all the-requirements of the SR, including those items in the Bases of the SR, then the actual initiation cannot be credited l
with satisfying the entire SR.
In order to satisfy the entire SR in this situation, the requirements not satisfied would have to be tested separately and in such a manner that l
adequate overlap exists between the requirements satisfied
.i by the actual initiation and the. requirements being tested j
separately.
l NRC Question 5:
Provide additional documentation that all types of I
degradation that would prevent a CS pump from achieving its l
required' flow rate at the required pressure will be able to be determined by verifying flow at a lower-pressure is consistent with the pump curve.
Provide documentation that the proposed baseline will provide sufficient accuracy to assure that acceptance criteria can be met by measuring flow and lower pressures.
Provide documentation concerning potential for damage to CS valves if throttled to achieve required pressure.
PECO Energy Response regarding ITS LCO 3.5.1, DOC An:
The Note to SR 3.5.1.7, which allows the use of pump curves to determine equivalent values of flow rate and test pressure for the core spray pumps, is consistent with the current licensing basis allowance for core spray pump testing provided in the CTS Bases for Specification 4.5.
This allowance was added to the CTS Bases in Amendments 195 and 199, dated September 16, 1994.
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