ML20136B653

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Forwards Response to Request for Addl Info Re Facility Operating License Change Request 93-18,requesting Replacement of Source Range & Intermediate Range Monitors W/ New Wide Range Neutron Monitoring Sys
ML20136B653
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 02/28/1997
From: Hunger G
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9703110076
Download: ML20136B653 (5)


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st tion Cupport D pirtment

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~Q 10 CFR 50.90

' PECO NUCLEAR nc%c-965 Chesterbrook Boulevard A Unit of PECO Energy Wayne, PA 19087 $691 February 28,1997 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 Response to Request for AdditionalInformation Regarding Facility Operating License Change Request 93-18, " Wide Range Neutron Monitoring System."

Dear Sir; By letter dated January 17,1995, PECO Energy Company submitted License Change Request (LCR) 93-18, requesting changes to Appendix A of the Peach Bottom Atomic Power Station (PBAPS) Facility Operating Licenses. The proposed changes were submitted to support PBAPS Modification P00271, which will replace the Source Range and Intermediate Range Monitors with a new WKje Range Neutron Monitoring System (WRNMS).

By letter dated October 31,1996, the NRC requested additionallnformation to complete their review of LCR 93-18. This letter provides the requested additionalinformation. In the attachment to this letter, each NRC question is restated, followed by the PECO Energy response.

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

Very truly yours,

. h. f* .

G. A. Hunger, Jr.,

Director- Ll:ensing

Enclosures:

Affidavit, Attachment cc: H. J. Miller, Administrator, Region I, USNRC t W. L. Schmidt, USNRC Senior Resident Inspector, PBAPS R. R. Janati, Commonwealth of Pennsylvania ,00 f 9703110076 970228 PDR ADOCK 05000277 P PDR n lpppsppupppu

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' ' February 26,1997 Page 2 bec: W. T. Henrick, Public Service Electric & Gas R.1. McLean, State of Maryland j J. A. Isabella, Atlantic Energy j A. F. Kirby, Ill, Delmarva Power & Light Company l D. M. Smith - 63C-3 j G. R. Rainey - 63C-3 j D. B. Fetters 62C-3 T. N. Mitchell- PB, SMB4 9  ;

M. E. Wamer - PB, SMB3-2A l G. D. Edwards PB, A4-1S D. B. Warfel- PB, SMB3-1 M. P. Gallagher - PB, SMB4 2 T. J. Niessen - 63C-3 J. B. Cotton - 638-1 3 M. A. Alderfer- PB, CR-41 s G. J. Lengyel/DJF PB, A4 SS D. L. Keene - PB, SMB3-2 P. J. Davison - PB, SMB2-2 ,

V. M. Nilekani - 638-3  ;

3 M. J. Leahy - PB, SMB3-1 j M. G. Wiwel - PB, SMB2-2 '

J. F. Carolan 638 3 PBAPS ISEG PB, SMB4-6 M. A. Christinzlano/AEC 62A-1 l R. A. Kankus - 63C-5 l; Commitment Coordinator- 62A 1 Correspondence Control Desk- 618-3  ;

DAC - 61 B-5 )

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1 COMMONWEALTH OF PENNSYLVANIA  :

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COUNTY OF CHESTER  : ,

1 D. B. Fetters, being first duly swom, deposes and says:

That he is Vice President of PECO Energy; the Applicant herelp: 1iat he has read the ,

enclosed response to the NRC Request for Additional Information regarding License Change Request 93-18 for Peach Bottom Atomic Power Station, Units 2 and 3, Facility Operating License Nos. 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, infortnation and belief.

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_n Vice President Subscribed and swom to before me thisO ay of -

1997 jt4 %k Not ry Public

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. . ATTACHMENT l l

NRC QUESTION 1 The licensee has proposed to increase the surveillance interval for the existing SRs  ;

3.3.1.1.11 and 3.3.1.2.7 from 6 to 24 months. The licensee justifies this, in part, by using the WRNMS estimated drift effects for 24 months in the normal NRC-approved, setpoint l methodology when calculating WRNMS setpoints. '

Amendments Nos.179 and 182 to Facility Operating License Nos. DPR-44 and DPR-56 (PBAPS Units 2 and 3) result in TS surveillance Intervals of 24 months being defined as operating cycle or refueling cycle, and allows a 25-percent grace period beyond the 24 months (i.e.,30 months) unless otherwise specified in the TS. In Generic Letter (GL) 91- l 04, " Changes in Technical Specification Surveillance Intervals to Accommodate a 24-month Fuel Cycle," dated April 2,1991, the staff requires that the licensee account for the maximum of 30 months in considerations regarding a 24-month fuel cycle.

Has the licensee used the estimated drift effects for 30 months when calculating the WRNMS setpoints? If not, please account for the maximum 30-month surveillance interval in associated setpoint calculations and revise the proposed TSs if necessary.

PECO ENERGY RESPONSE TO QUESTION 1 The WRNMS setpoint calculation prepared to satisfy the 24-month surveillance requirement is based on an allowance for the estimated drift effects for 30 months.

Therefore, the proposed TS changes do not require revision.

NRC QUESTION 2 in the October 19,1992, application to revise TS instrument surveillance intervals to 24-months, the licensee committed to establish a program for monitoring and assessing the effects of increased calibration intervals on instrument drift. The purpose of this monitoring program is to provide a means to verify the assumptions made in the setpoint methodology with regard to instrument drift. This monitoring also provides a method to determine the adequacy of a surveillance interval. The licensee's drift trending program commits to evaluate a reduction in surveillance interval for any calibration surveillance that fails to prove satisfactory.

Has the licensee included the above two surveillance requirements in that monitoring program or has the licensee provided other means for monitoring and assessing the effects of the proposed increased calibration intervals?

PECO ENERGY RESPONSE TO QUESTION 2 In the October 19,1992 app. cation to revise TS instrument surveillance intervals to 24 months, PECO Energy provided a summary description of the program for monitoring and assessing the effects of increased calibration surveillcoce intervals on instrument drift and its effects on safety. This summary declared the following: 'PECO's program will review each calibration surveillance that does not meet the leave 6?one criteria (i.e., no recalibration or adjustment required) of the calibration surveillance test. Based on the results of that review a decision on the appropriate calibration interval will be made. Such a decision will consider such things as shortening the surveillance test (ST) interval, changing the setpoint of the instrument or leaving the surveillance interval at thirty months."

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. The two surveillance requirements, SRs 3.3.1.1.11 and 3.3.1.2.7, are addressed by surveillance monitoring, assessment of results, and the corrective action process. The 1 surveillance monitoring activity considers surveillance test results which are unsatisfactory or require recalibration. Therefore, failures which may have been caused by instrument .i drift would be identified for further assessment by plant staff. A range of corrective actions, including reducing the surveillance interval, would be considered when deciding on the appropriate resolution of the problem.

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