ML20086G685
| ML20086G685 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 07/10/1995 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9507170057 | |
| Download: ML20086G685 (2) | |
Text
_ _ _ _ _ _ - _ _ -
Ctatirn Supp2rt Esp;rtment "4..
a.
V PECO ENERGY
- l.f=v3;::L, 965 Chesterbe Boulevard j'
Wayne, PA 19087-5691 July 10,1995 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
_ Peach Bottom Atomic Power Station, Units 2 and 3 Implementation of TSCR 90-03
Dear Sir:
The purpose of this letter is to identify an administrative error associated with our submittal of Technical Specifications Change Request (TSCR) 90-03, and request NRC concurrence with our proposed corrective action. TSCR 90-03 was submitted to the NRC on September 26,1994 and approved by the NRC on June 6,1995 by issuance of Amendment Nos. 203 and 206 to Facility Operating Ucense Nos. DPR 44 and DPR-56 for Peach Bottom Atomic Power -
Station (PBAPS), Units 2 and 3. These amendments were implemented on June 28,1995.
TSCR 90-03 included numerous changes to the PBAPS TS to extend the surveillance test intervals and allowed out of service times for instrumentation associated with various systems. Included in these changes was a change to relocate Note 4 of Table 4.1.2 to'another location in the TS. Note 4 read,
" Response time is not a part of the routine instrument channel test but will be checked once per operating cycle." Because this note actually contained a surveillance requirement, it was considered more appropriate to relocate it to the Surveillance Requirements (SR) section of the TS.
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Page 2 Accordingly, this note was relocated to SR 4.1.A. As indicated in TSCR 90-03, this was intended to be an administrative change, with no change of intent.
However, the note was relocated to read, "The RPS response time of each reactor trip function shall be demonstrated to be within its limits once per operating cycle." As written, the requirement to perform response time testing now applies to all Reactor Protection System (RPS) trip functions, rather than exclusively to those listed in Table 4.1.2. The following six RPS trip functions are not listed in Table 4.1.2: Mode Switch in Shutdown, Manual Scram, RPS Channel Test Switch, IRM Inoperative, APRM Inoperative and APRM Downscale.
PECO Energy's proposed action is to correct this error as part of our overall conversion to the Improved Technical Specifications. TSCR 93-16, which requested this conversion, was submitted September 29,1994. A revision to Section 3.3.1.1 "RPS Instrumentation" of TSCR 93-16 was submitted on July 7, 1995. This revision eliminates the requirement to perform response time testing on the subject six RPS trip functions. The license amendments associated with TSCR 93-16 are expected to be implemented during the Fourth Quarter of 1995.
The timing of the implementation of TSCR 93-16 with respect to the implementation of TSCR 90-03 results in the new SR for the six RPS trip i
functions to be in effect for approximately six months. Current TS define the term "once per cycle" to be "at least once every 732 days." Our interpretation of current TS would not require any response time testing of the subject six RPS trip functions to be performed since the SR will be deleted before it becomes due. Please note that this interpretation acknowledges that PBAPS, Unit 3 will have a refueling outage during the approximate six-month period when the new SR is in effect.
PECO Energy has concluded that this corrective action maintains compliance with TS, minimizes the administrative burden associated with processing a separate TSCR, yet does not result in any unnecessary testing of the subject six RPS trip functions. Your written concurrence with our proposed corrective action is requested by August 31,1995.
We apologize for any inconvenience associated with this issue.
Very truly yours, bfo G. A. Hunger, Jr.
Director - Licensing cc:
T. T. Martin, Administrator, Region I, USNRC W. L Schmidt, USNRC Senior Resident inspector, PBAPS