ML20135G491
| ML20135G491 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/12/1985 |
| From: | Cooney M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8509190301 | |
| Download: ML20135G491 (4) | |
Text
PHILADELPHIA ELECTRIC COMPANY 23O1 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 l
(zis) s41-so20
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Seotember 12, 1985 n cv..
Docket Nos. 50-277 50-278 Mr. John F.
Stolz, Chief Operating Reactors Branch #4 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555
SUBJECT:
Technical Specifications for Common Equipment Peach Bottom Atomic Power Station
Dear Mr. Stolz:
This letter provides a follow-up on a matter discussed with Mr. Gears, NRC Project Manager, on June 7, 1985 regarding the testing schedule for the diesel generators.
It also addresses our desire to base testing intervals for plant equipment on the refueling outage schedule rather than a calendar interval.
Common Equipment Surveillance Testing Peach Bottom Unit 2 and Unit 3 Technical Specification 4.9.A.1.b requires that, "once per operating cycle the condition under which the diesel generator is required will be simulated and a test conducted to demonstrate that it will start and accept the emergency load within the specified time sequence...."
The frequency for conducting the test in each Operating License is once per operating cycle.
The intent is to perform the test during an extended plant outage such as a refueling outage since the alignment and exercising of the associated safety-related equipment is not compatible with power operations.
The test at Peach Bottom is normally performed at the conclusion of a refueling outage.
However, the definition of surveillance frequency in the Technical Speci fications of each License limits the operating cycle interval to 18 months (plus 25%).
For an hM 2
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F Mr. John F.
Stolz September 12, 1985 Page 2 cycle, a shutdown would have been necessary for the sole purpose of performing this test.
The diesel generator test required by Specification 4.9.A.l.b was performed for Peach Bottom Unit 2 on June 13, 1985 at the end of the recently completed pipe replacement outage.
The due date for the test of the same diesel generators in order to comply with the Unit 3 Technical Specifications was June 26, 1985, based on an 18-month interval plus the 25% extension permitted by the Technical Specification.
Since the diesels are equipment common to Unit 2 and Unit 3, and emergency loads for the units are essentially identical, we believe that the June 13, 1985 test satisfies the surveillance requirement of both units.
This matter was discussed beforehand with T. P.
Johnson, Resident Site Inspector, who agreed with this interpretation.
Philadelphia Electric Company agreed to repeat the diesel generator test at the end of the Unit 3 refueling outage which began July 14, 1985.
The situation described above resulted from the extended operating cycle on Unit 3 and the back-to-back refueling outages on Units 2 and 3.
It is our belief that the definition of surveillance frequency could be revised in the Technical Specifications to address this condition, and offer for your consideration the following.
"A surveillance requirement for equipment common to both units may be deferred beyond the calculated calendar due date until the next refueling outage, provided the equipment has been similarly tested and meets the surveillance requirement for the other unit.
Operating Cycle Surveillance Intervals In addition to the diesel generators, the 18-month criterion for operating cycle surveillance intervals impacts other equipment, and negates the intent that these tests be performed during a refueling outage.
Since the start of commercial operations in 1974, both Peach Bottom units have averaged approximately 22 months por operating cycle.
This has resulted in shutting down a unit for the sole purpose of performing a variety of surveillance tests.
Usually these outages have occurred several weeks or months prior to the start of a scheduled refueling outage.
The benefits associated with these surveillance required outages do not appear to justify the additional transients and accelerated equipment wearout associated with the shutdown /startup transient, nor are these outages cost-beneficial since most of the testing can be
Mr. John F. Stolz September 12, 1985 Page 3 performed in parallel with refueling / major maintenance outages.
Additionally, the 18-month limitation encourages testing with the unit at power, with a risk for causing an inadvertent transient.
Further, the 18-month limit frequently results in the use of the 25% extension provision in the Technical Specification.
- However, since the next surveillance interval must commence at the end of the original calendar specified interval, additional testing is usually performed for the sole purpose of extending the calendar due date to the next scheduled outage to avoid a surveillance required outage.
This practice results in excessive testing and accelerated equipment wearout.
The solution to this problem is to change the requirement for once-per-operating cycle surveillance from a time-related standard to an event-related standard.
The following proposed revision to the definition of surveillance frequencey is offered for your consideration:
Current definition:
"The operating cycle interval as pertaining to instrument and electrical surveillance shall not exceed 18 months.
These specified time intervals may be exceeded by 25%.
In cases where the elapsed interval has exceeded 100% of the specified interval, the next surveillance interval shall commence at the end of the original specified interval."
Proposed definition:
" Surveillance frequencies specified as once-per-operating cycle shall be performed at least once during the period between the startup following a refueling outage and the startup following the subsequent refueling outage."
The proposed revision recognizes the possibility of a longer time period to complete an operating cycle and minimizes the potential for surveillance-required outages.
Further, the proposed revision in the definition of operating cycle surveillance would have avoided the issue regarding the need to shutdown Unit 1 to test the common diesel generator as discussed at the beginning of this letter.
These suggestions are offered for your consideration in the interest of estabitshing surveillance intervals that are compatible with expected plant power cycles.
The changes would reduce potential. power perturbations and avoid licensing activities associated with the unending requests for surveillance schedule relief.
These proposals are consistent with the intent of the surveillance program, and the NRC's policy on scram
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Mr. John F. Stolz September 12, 1985 Page 4 reduction and excessive testing.
Minimizing the potential for surveillance outages will improve plant availability, reduce total plant radiation exposure, and minimize personnel work stress associated with periods of extensive plant outages.
We would appreciate your comments on this matter before we initiate a license amendment request.
Should you require any additional information, pleane do not hesitate to contact us.
Very truly yours, ff$
M.
J.
Cooney cc:
T. P. Johnson, Resident Site Inspector u