ML20087E882

Forwards Implementation of New SR Associated W/Conversion to Improve TS

ML20087E882
Person / Time
Site:	Peach Bottom
Issue date:	08/04/1995
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20087E887	List: ML20087E882 ML20087E888
References
NUDOCS 9508150003
Download: ML20087E882 (3)

Text

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965 Chesterbrook Boulevard Wayne, PA 19087 5691 August 4,1995 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 i

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U. S. Nuclear Regulatory CGTM 'Fi [

Attn: Document Control Desk  ;

Washington, DC 20555 ,

SUBJECT:

Peach Bottom Atomic Power Station, Units 2 and 3 Implementation of New Survellance Requirements Associated with Corwersion to the Improved Technical Specifications.

REFERENCE:

Letter from G. A. Hunger, Jr. (PECO Energy Company) to U. S. Nuclear Regulatory Commission (USNRC) dated September 29,1994

Dear Sir:

in the above reference letter, PECO Energy transmitted Technical Specifications Change Request (TSCR) 93-16 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. This TSCR proposed an overall conversion from the PBAPS existing custom Technical Specifications to the improved Technical Specifications (ITS) as contained in NUREG 1433, " Standard Technical Specifications General Electric Plants, BWR/4."

As part of the overall conversion, PECO Energy is volunteering to adopt numerous new Surveulance Requirements (SRs). The purpose of this letter is to inform the NRC of PECO Energy's approach to implementing these new Surveillance Requirements, and to request NRC written concurrence with this approach.

The new SRs are grouped into two categories. Category A SRs are those SRs in the PBAPS ITS which are new, in their entirety, as compared to the PBAPS current TS (CTS). .The Category A SRs are listed in Attachment 1. PECO Energy proposes that these Category A changes are assumed to be performed and met, in accordance with ITS SR 3.0.1, upon implementation of the ITS. Accud;i, gly, the initial due date for each Category A SR will be determined based on 1) the

ITS implementation date,2) the ITS frequency of the SR and 3) ITS SR 3.0.2.

Category B SRs are those SRs which include an additional feature or revision to an existing SR in the PBAPS CTS and as a result are more restrictive. The Category B SRs are listed in

Attachment 2. PECO Energy proposes that these additional features or revisions of existing SRs are assumed to be performed and mot, in accordance with ITS SR 3.0.1, upon implementation of the ITS. Acced;i,gly, the due date for each Category B SR wtl be determined based on: 1) the last completion date of the associated CTS SR,2) the iTS frequency of the SR and 3) ITS SR 3.0.2.' 1 1000'9 9508150003 950004 7 DR ADOCK 0500 a 1

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August 4,1995 Page 2 PECO Energy has concluded that the approach discussed above will maintain compliance with the ITS and will afford us the flexibility needed to implement the numerous new SRs which we have volunteered to include as part of our overall conversion. We request that you provide your written concurrence with this approach by September 8,1995.

If you have any questions, please do not hesitate to contact us.

Very truly yours,

.h. ,o G. A. Hunger, Jr.,

Director -IJcensing MCK/bgr o.inc\pb\wpat\mck\sunw.tr G

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ATTACHMENT 1 Category A New Surveillance Requirements I

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