ML20090C872
| ML20090C872 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/25/1992 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20090C863 | List: |
| References | |
| NUDOCS 9203050235 | |
| Download: ML20090C872 (4) | |
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SAFETY EVALVATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REL ATfD TO AMENDMENTS NOS.166 AND 170 TO FAtlllTY OPERATING LICENSE NOS. OPR-44 AND DPR 56 PHILADELPHIA ELECTRIC COMPANY PUBLIC SERVICE ELECTRIC AND GAS COMPANY DJLMARVA POWER A@ LIGHT COMPANY ATLANTIC CITY ELECTRIC COMPANY PEACH BOT. TOM ATOMIC POWER STATION. UNIT NOS. 2 AND 3 DOCKET N05. 50-277 AND 50 278
1.0 INTRODUCTION
By letter dated December 19, 1991, the Philadelphia Electric Company (PECo),
Public Service Electric and Gas Company, Delmarva Power and Light Company, and Atlantic City Electric Company (the licensees) submitted a request for changes to the Peach Bottom Atomic Power Station, Unit Nos. 2 and 3, Technical Specifications (TS).
The requested changes would revise the TS definition of Surveillance Frequency.
Specifically, the proposed changes define each of the surveillance intervals used throughout the Peach Bottom Atomic Power Station, Unit Nos. 2 and 3 TS in common units of hours and days.
In addition, the proposed changes revise the reference date from which subsequent surveillance tests are scheduled when the actual interval exceeded the specified interval by up to 25% of that specified.
Finally, the proposed changes remove a definition of the operating cycle that was stated in units of months since it is now defined in units of days.
PECo proposed the changes to facilitate implementation of a new surveillance test scheduling and tracking system, referred to as the Plant Information Management System (PIMS) Surveillance Test Module. As documented in Inspection Reports 50-277/90 01, 50-278/90-01, 50-277/91-23 and 50-278/91-23, the licensee has had difficulty in completing some TS required surveillance tests within their required periodicity.
Discussion In their submittal of December 19, 1991, the licensee proposed four specific changes to the Technical Specification 1.0 definition of Surveillance Frequency.
The first change (Change Request (1)) adds a tabular list of the various surveillance intervals used throughout the TSs and define the intervals in units of hours and days.
The licensee included the applicable surveillance intervals from Table 1.1 of NUREG-0123, Revision 3, " Standard Technical Specifications for General Electric Boiling Water Reactors."
In addition, the licensee defined other intervals that are used in ti.e Peach Bottom TSs but that are not listed in Table 1.1 of NUREG-0123.
These were included for completeness and to avoid misinterpretation.
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The second change (Change Request (2)) deletes a sentence defining the length of an " operating cycle" as an interval not to exceed 18 months.
The table included in the first change defines an " operating cycle" as 550 days.
This change eliminates conflicting requirements since a month is defined as 31 days and 18 months would constitute 558 days.
The third change (Change Request (3)) deletes a requirement in the definition of Surveillance Frequency that in cases where the elapsed interval has exceeded 100% of the specified interval, the next interval shall commence at i
the end of the original specified interval.
This requirement results in scheduling completion of subsequent tests on the same periodic basis as would have been used if the surveillance had been performed within the specified j
interval.
This has the 'ffect of limiting the mpeated use of the provision for extending surveillance intervals.
Because the NRC has concluded in Generic Letter 89-14 that a similar requirement in the standard technical specifications is not necessary, the licensee has proposed Change Request (3).
This change will allow the scheduling of each subsequent surveillance test based upon the date that the prior surveillance test was actually performed and this is consistent with the process used by the PIMS Surveillance Test Module.
The fourth change (Change Request (4)) deletes a requirement from the current definition which reads: "When a test is deferred under this provision, the next surveillance interval shall commence at the end of the original specified interval." This sentence is deleted from the paragraph in the definition that l
addresses testing of the common diesel generator related equipment.
This deletion is proposed for the same reason as Change Request (3) and allows surveillance tests to be scheduled based on the date of the last completed test.
2.0 EVALUATION Change Request (1) provides a table that specifically defines, in terms of hours and days, the surveillance intervals used throughout the Peach Bottom Technical Specifications.
By providing a more precise definition of the intervals, the possibility of non-conservative interpretations is reduced.
The majority of the intervals defined in the table are taken from Table 1.1 of NUREG 0123, Revision 3. " Standard Technical Specifications for General l
Electric Boiling Water Reactors" (STS).
The remaining intervals in the table, which are used in various places throughout the Peach Bottom Technical Specifications, are included so as to eliminate confu:, ion and to avoid misinterpretation.
Because the proposed change is consistent with NUREG-0123, the staff finds the proposed change acceptable.
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4 Change Request (2) deletes the portion of the current definition which reads:
"The operating cycle interval as pertaining to instrument and electrical surveillance shall not exceed 18 months.
Because the table in change request (1) provides a precise definition of the operating cycle interval, the staff finds the proposed change acceptable.
Change Request (3) deletes the requirement that subsequent surveillance tests be scheduled based on the last scheduled interval.
Deletion of this requirement will allow tests to be scheduled based on the date of the last completed test.
Generic Letter 89-14 concluded that there was safety benefit, in some instances, in invoking the twenty-five percent extension provision that the benefit to safety and would exceed any safety benefit derived from limiting use of the twenty-five percent allowance to extend a surveillance.
On the basis that Generic' Letter 89-14 supports the use of the twenty-five percent' interval extension in circumstances _where it benefits safe plant operation and allows scheduling of surveillance tests based on the date of the last completed test, the staff finds the proposed change acceptable.
Change Request (4) addresses the paragraph in the definition which addresses surveillance testing of the shared EDG's.
The TSs allow the EDG testing required once per opt rating cycle to be deferred until the next refueling outage provided that the equipment had been similarly tested and met the surveillance requirem!nt of the other unit.
Change Request (4) deletes the requirement to schedule EDG testing based en previous schedules.
This change is similar to that fo,* Change Request (3) and on the basis of the evaluation presented for Change Mquest (3), the staff finds Change Request (4) acceptable.
3.0 STATE CONSULTATION
in accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments.
The State official had no comments.
i 4.0 DEJRONMENTAL CONSIDERATIONS The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements.
The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.
The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has~been no public comment on such finding (57 FR 714). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environment al assessment need be prepared in connection with the issu6 ace of the amendr.cnts.
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5.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal r.ontributor:
J. Shea, NRR Dated:
February 25, 1902
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