ML20217G748
| ML20217G748 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/20/1998 |
| From: | Geoffrey Edwards PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20217G751 | List: |
| References | |
| NUDOCS 9804020507 | |
| Download: ML20217G748 (14) | |
Text
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- c a [/ 4-A 10 CFR 50.90 x
w PECO NUCLEAR-nm ~~ c-965 Chestertrook Boulevard d
. wayne, PA 19087,5691 -
_.A Unit of PECO Energy _
March 20,1998 Docket Nos. 50-277 50-278 License Nos.- DPR-44 DPR-56.
U.S. Nuclear Regulatory Commission m
' Attn: Document Control Desk ~
- Washington, DC 20555
Subject:
Peach Bottom Atomic Power Station, Units 2 and 3 License Change Application ECR 97-02809
Dear Sir / Madam:
- PECO Energy Company (PECO Energy) hereby submits License Change Application ECR 97-02809, in accordance with 10 CFR 50.90, requesting a change to the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 Facility Operating Licenses. This proposed change will revise the Technical
- Specifications (TS) to incorporate an End-of-Cycle Recirculation Pump Trip (EOC-RPT) System at PBAPS, Units 2 and 3.
Information supporting this request is contained in Attachment 1 to this letter, and the marked up pages showing the proposed changes to the PBAPS, Units 2 and 3 TS are contained in Attachment 2. We request that this amendment to the PBAPS, Units 2 and 3 TS be approved by September 21,1998 for implementation during the upcoming PBAPS, Unit 2 outage currently scheduled to begin in October 1998, and for the PBAPS, Unit 3 outage currently scheduled to begin in October,1999.
In a letter dated March 15,1995 (letter from J. W. Shea (U. S. Nix: lear Regulatory Commission (USNRC)) to PECO Energy Company), the USNRC provided a summary of a February 7,1995 meeting between the USNRC and PECO Energy regarding recirculation pump trip design requirements. In that
-letter, the staff had additional questions regarding the Adjustable Speed Drives (ASDs) that were originally intended to be installed as a part of this modification.
These questions were forwarded to PECO Energy for response, in the event that PECO Energy would choose to resubmit a licensing application for the ASD and EOC-RPT; As discussed in the attached application, the ASDs have been et...Jnated from the EOC-RPT System design. Therefore, no response to these
- questions is provided.
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March 20,1998 Pag 3 2 eliminated from the EOC-RPT System design. Therefore, no response to these questions is provided.
d you have any questions, please do not hesitate to contact us.
Ve truly obL /s,f, &
I arrett D. Edwards Director - Licensing
Enclosures:
Affidavit, Attachment 1, Attachment 2 cc:
H. J. Miller, Administrator, Region I, USNRC A. C. McMurtray, USNRC Senior Resident inspector, PBAPS R. R. Janati, Commonwealth of Pennsylvania i
' COMMONWEALTH OF PENNSYLVANIA:
ss.
COUNTY OF YORK T. N. Mitchell, being first duly sworn, deposes and says:
That he is Vice President of PECO Energy Company; the Applicant herein; that he has read the attached License Change Application ECR 97-02809, for Peach Bottom Facility Operating Licenses 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, information and belief.
Vice President Subscribed and sworn to before me this 19th day of
- March, 1998.
1me /
NclM 4
Notary Public
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ATTACHMENT 1 PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 LICENSE CHANGE APPLICATION ECR 97-02809
" End-of-Cycle Recirculation Pump Trip System" Supporting Information - 10 Pages
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. Docket Nos. 50-277 50-278-License Nos. DPR-44 DPR-56 i
introduction PECO Energy Company, Licensee under Facility Operating Licenses DPR-44 and DPR-56 for the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, requests that the Technical Specifications (TS) contained in Appendix A to the Operating License be amended to incorporate new TS Section 3.3.4.2, "End of Cycle Recirculation Pump Trip (EOC-RPT) instrumentation," and the associated Bases.
Additionally, the Table of Contents for the TS and Bases are being revised, and a proposed new definition for the End-of-Cycle Recirculation Pump Trip (EOC-RPT)
System is being added to Section 1.1 (" Definitions"). The TS and Bases pages showing the proposed changes are contained in Attachment 2. This License Change
. assessment of the proposed changes, information support,oposed changes Application provides a discussion and description of the pr ing a finding of No Significant Hazards Consideration, and information supporting an Environmental Assessment.
Dim _ies!on and Description of the Proposed Chance PECO Energy Company proposes to install an EOC-RPT System at PBAPS, Unit 2 during the upcoming 2R12 refueling outage currently scheduled to begin in October, 1998, and at PBAPS, Unit 3 during the 3R12 refueling outage currently scheduled to begin in October,1999. As a part of this modification, a new TS Section 3.3.4.2, "End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation," and associated Bases will be added to the current TS. Additionally, the Table of Contents for the TS and Bases are being revised, and a proposed new definition for the EOC-RPT System is being added to Section 1.1 (" Definitions"). This newts section and Bases are based on the EOC-RPT System TS contained in NUREG-1433, " Standard Technical Specifications, General Electric Plants, BWR/4," Revision 1, April 1995. The NUREG-1433 Standard Technical Specifications have been modified for PBAPS, Units 2 and 3 based on the plant design, and the current licensing basis. Additionally, the NUREG-1433 Bases have been modified for PBAPS, Units 2 and 3 based on the plant design, the current licensing basis, and to include minor editorial clarifications. contains the TS and Bases pages showing the proposed changes. A summary of the proposed changes is as follows:
' 1. A proposed definition for the EOC-RPT System response time has been added to Section 1.1 (" Definitions").
- 2. Proposed Limiting Conditions for Operation (LCO) 3.3.4.2 have been modified to
. reference thermal limits curves contained in the Core Operating Limits Report (COLR), and to'specify the conditions for which the curves are to be used. This use of the thermal limits curves is similar to the use of the curves contained in current
.TS Section 3.7.6 (" Main Turbine Bypass System") which was approved as a part of the conversion to improved Technical Specifications (Amendment Nos. 210 and 214, dated August 30,1995).-
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- 3. The setpoints contained in the proposed Surveillance Requirement 3.3.4.2.2 are based on values contained in Section 3.3.1.1 (" Reactor Protection System (RPS) instrumentation").
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Docket Nos.' 50-277 50-278 License Nos. DPR-44 DPR-56 4.'
The frequency for performance of the applicable surveillance requirements has
. been extended from the Standard Technical Specification frequency of 18 months to 24 months.- This 24 month frequency is based on the a 24 month refueling outage frequency for PBAPS, Units 2 and 3, and the current surveillance frequencies as provided in Section 3.3.1.1 (" Reactor Protection System (RPS) Instrumentation").
- 5. The Bases have been modified to account for: 1) the use of the thermal limits curves contained in the COLR for an inoperable EOC-RPT System,2) the PBAPS, Units 2 and 3 plant specific setpoint methodology, and, 3) the current licensing basis as provided in Section 3.3.1.1 (" Reactor Protection System Instrumentation (RPS) instrumentation"). Additional minor editorial clarifications have been included in the Bases section.
! PECO Energy is requesting approval of the proposed TS and Bases pages contained
. In Attachment 2 for both units.
Safety Assessment The purpose of the EOC-RPT System is to reduce the challenge to the integrity of the fuel barrier resulting from reactor pressurization events. For PBAPS, Units 2 and 3, these events include a turbine generator trip and a generator load rejection event. As part of this modification, two new 4.16 kV breakers will be installed between the Reactor Recirculation System (RRS) Motor Generator (M-G) Set and the RRS pump motor for each recirculation loop at PBAPS, Units 2 and 3.
' There will be two EOC-RPT trip systems. Signals from Reactor Protection System
. (RPS) channels A1 and B1 form one trip system and will trip one EOC-RPT breaker for
~each recirculation pump motor. Signals from RPS channels A2 and B2 form a second trip system and will trip the second EOC-RPT breaker for each recirculation pump motor Each channel has two functions. One function corresponding to the Turbine
- Stop Valve (TSV) function and the second function corresponding to the Turbine Control Valve (TCV) function. The trip will be initiated by either a TSV closure or a TCV fast closure. The channels utilize existing RPS sensors and relays.
The two trip systems of the EOC-RPT System will be separate and independent trip systems, either one of which will generate a trip signal. Each trip system will be eiectrically, mechanically, and physically independent to meet the single failure criterion.
The EOC-RPT System will improve the thermal response to plant pressurization transients, particularly during the latter portion of a typical fuel cycle when slower -
. negative scram reactivity insertion rates are encountered. The system improves themial response by tripping the recirculation pumps early in the pressurization phase of the event sequence. The pump trips introduce negative (void) reactivity to the core (via rapid core flow reduction), and reduces the neutron flux and fuel surface heat flux
' excursions. Upon detection of a fast closure of the turbine control valves or the closure of the turbine stop valves at a core power greater than or equal to 30% of rated thermal power, the RPS will initiate a reactor scram signal and, concurrently, an EOC-RPT
& > signal to prevent exceeding fuel thermal design limits.
The EOC-RPT System will enhance operating flexibility of the' reactor by providing an 2=
Dock:t Nos. 50-277 w..*
50-278 License Nos. DPR-44 DPR-56 improvement in the Critical Power Ratio (CPR) operating limit, which protects the
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integrity of the fuel barrier. Analysis indicates an approximate 0.05 reduction in the delta critical power ratio. The actual MCPR margin benefits derived as a result of this modification are core dependent and will be documented in the fuel cycle specific analysis and Core Operating Limits Report (COLR).
With the EOC-RPT System installed, assuming a core containing limiting 8x8 fuel design (BP/P8 X 8R), thg Licensing Basis Peak Cladding Temperature (PCT) is analyzed to increase 45 F from 1735 F to 1780"F during a Loss-of-Coolant Accident (LOCA). The faster coastdown of the recirculation pumps during a LOCA due to the removal of the Motor Generator (M-G) Set inertia results in an increase in the calculated peak cladding temperature. In no event, will this small increase cause the '
PCT to exceed the 2200 F PCT regulatory limit of 10 CFR 50.46. Presently at PBAPS, Units 2 and 3, there is no pre-GE 11 fuel in the core. However, situations may occur in j
which 8x8 fuel bundles may need to be inserted into the core. The fission product 1
~ barriers and the radiological analyses are not affected by the addition of the EOC-RPT
--System. Additionally, no design or safety limits will be exceeded.
For GE 11 fuel (9x9) and later designs (GE 12 and 13), no credit is taken for recirculation pump coastdown in the LOCA accident analysis, therefore, the installation of the RPT modification will not increase the current PCT for these designs.
In a letter dated March 15,1995 (letter from J. W. Shea (U. S. Nuclear Regulatory Commission (USNRC)) to PECO Energy Company), the USNRC provided a summary of a February 7,1995 meeting between the USNRC and PECO Energy regarding recirculation pump trip design requirements. In that letter, the USNRC provided regulatory acceptance criteria for the recirculation pump trip design. These criteria were delineated in Enclosure 3 of that letter, and are discussed below.
The RPT System has been classified as important-to-safety because it mitigates the effects of a plant transient. The system meets the single failure criterion, and will accomplish its design function by isolating the recirculation pump motor from the associated M-G set generator. Furthermore, the 125 VDC power feeds to the EOC-RPT logic control circuits will be from on-site, safety-related station battery backed power supplies. The routing of the control and power cables associated with the EOC-RPT System will be in metallic raceways and will meet separation guidelines equivalent to safety-related equipment.
There will be no software used in the EOC-RPT System. The system logic consists of two electrically and physically separated trip systems; one will be used to trip one EOC-RPT System breaker for each pump and the other will be used to trip the second EOC-RPT System breaker for each pump. Additionally, this modification will not affect the current power flow maps including the ARTS /MELLLA features.
The design of this modification assures that the new system is not susceptible to electromagnetic (EM) emissions, nor will it cause inadvertent operation of existing plant equipment due to EM emissions.
The EOC-RPT System design will utilize spare isolated contacts from the RPS relays to provide the trip initiation that will trip the recirculation pumps. The RPS relays contact-1 to-contact isolation will provide the electrical isolation between the safety-related RPS 3
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' Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 circuits and the EOC-RPT System circuit to prevent any' failure or malfunction in the EOC-RPT System from impacting the safety function of the RPS.
The EOC-RPT System for PBAPS, Units 2 and 3 meets the USNRC staff acceptance 1
criteria within the bounds of the current PBAPS commitments. There are some J
differences between the acceptance criteria described in the March.15,1995 letter, and the PBAPS commitments.. The March 15,1995 letter references the Standard Review Plan while PBAPS is a pre-Standard Review Plan facility. The following is a description of how the EOC-RPT System design meets the requirements of the March 15,1995 -
q letter:
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The EOC-RPT System will comply with IEEE 279-1971, " Criteria for Protection a
Systems for Nuclear Power Generating Stations,". with the exception of Section 4.3,
" Quality of Components and Modulas." As discussed in the March 15,1995 letter, j
an allowed exception to IEEE 279 Section 4.3 has been taken. Quality Assurance J
for the EOC-RPT System is described under GDC 1 discussed below. Since PBAPS, Units 2 and 3 were licensed prior to the publication of the Standard Review Plan, certain differences exist between the guidelines contained in Appendix B of
' the Standard Review Plan, Section 7.1, and the way PBAPS implements the requirements of IEEE 279. These alternative approaches are summarized in Table 1.
- 2. General Design Criteria (GDC) 1-The quality assurance requirements for the EOC-RPT system meet the guidance:
provided in Generic Letter 85-06, " Quality Assurance Guidance for ATWS Equipment That is Not Safety-Related." Additionally, the EOC-RPT System components were specified and purchased to the requirements of Generic Letter 85-06.
safety-related structures, which are designed to withstand natural phenomena such as hurricanes and tornadoes. The RPS sensors utilized by the EOC-RPT System will be qualified and mounted in accordance with safety-related requirements, and
- will be located in a Seismic Class ll structure. Fire and flooding are not considered to be hazards to the function of the system, since these phenomena are monitored in the applicable spaces, and will result in procedural actions which will satisfy the need for the EOC-RPT functions. The system will be designed to operate during and after an Operating Basis Earthquake, as discussed in the March 15,1995 letter.
- 4. GDC 3 The EOC-RPT System is not required to operate during or after a fire, since it has no formal safe shutdown requirements. The system is designed in accordance with
. PBAPS fire protection program requirements.-
- 5. LGDC 4 4
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Docket Nos. 50-277 q
GO-278 License Nos. DPR-44 DPR-56 The EOC-RPT System design and materials are qualified for the environment in
. which they operate. The system is not required to operate in a harsh environment, associated with a LOCA or High Energy Line Break (HELB).
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- 6. GDC 13 e
instrumentation will be provided to monitor the EOC-RPT System as well as main turbine stob valve position and main turbine control valve fast closure ow the.
anticipatec ranges for normal operation, and accident conditions, commensurate with the function of the system.
- 7. GDC 18 The EOC-RPT System will interface with the RPS and is designed to be tested in conjunction with the required RPS testing. The design allows for inspection of.
power and control components to assess continuity and to assess the condition of components during shutdown. Testing requirements are specified in the plant Technical Specifications to ensure high confidence in the operability of EOC-RPT System.
- 8. GDC 20 The EOC-RPT System is designed in accordance with the required provisions of IEEE 279-1971 except for Section 4.3, " Quality of Components and Modu!es."
Quality assurance for the EOC-RPT System is described under GDC 1.
- 9. GDC 21 The EOC-RPT System is designed to remain operable in the event of a single failure. Structures, systems and components in the EOC-RPT System are specified to have a high degree of functional reliability. The system is readily testable to verify operability, with redundant multiple inputs, and diverse input parameter design. Removal from service of any component or channel will not prevent the
. EOC-RPT function.
- 10. GDC 22 All EOC-RPT System components, except for the RPS sensors, will be located in safety-related structures, which are designed to withstand natural phenomena such
- as hurricanes and tornadoes. The RPS sensors utilized by the EOC-RPT System will be qualified and mounted in accordance with safety-related requirements, and are located in a Seismic Class ll structure. Fire and flooding are not considered to be hazards to the function of the system, since these phenomena are monitored in the applicable spaces, and will result in procedural actions to support the EOC-
, RPT functions. The EOC-RPT System will receive signals from RPS, but will be isolated from it by the use of safety-related relay contacts. All EOC-RPT System cables that run through RPS cabinets will be physically isolated and separated in accordance with approved station procedures. Power supplies will be protected.
. such that a failure in the EOC-RPT logic will not impact the safety-related 125 VDC system or any associated components. Redundant portions of the system will be 5
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,, 278 License Nos. DPR-44 DPR separated such that that no single failure can prevent the EOC-RPT System from functioning.
- 11. GDC 24 The EOC-RPT will be separated from control circuits by isolated relay contacts, physical separation and barriers, and indeMmdent conduit and divisional wiring / cable runs in accordance with criter a applicable to safety-related components. The system will have an interlock with the M-G Set 13 kV breaker which upon failure, or removal from service, has no impact on the tripping function of the EOC-RPT System.
- 12. GDC 29 The EOC-RPT System is designed to assure an extremely high probability of accomplishing its function during reactor pressurization transients such as a turbine trip or generator load rejection.
'The frequency for performance of the licable surveillance requirements has been extended from the Standard Technical pecification frequency of 18 months to 24 months. This 24 month frequency is based on the 24 month refueling outage frequency for PBAPS, Units 2 and 3, and the current surveillance frequencies as provided in Section 3.3.1.1 (" Reactor Protection System (RPS) instrumentation"). The RPT System components were specified and purchased to the requirements of Generic Letter 85-06, " Quality Assurance Guidance for ATWS Equipment That is Not Safety-Related."
The EOC-RPT System is designed to remain operable in the event of a single failure.
Additionally, this modification will not add any new component that requires calibration.
Therefore, the impact, if any, of extending the surveillance requirements from 18 to 24 months is small.
Information Sucoortina a Findina of No Sionificant Hazards Consideration We have concluded that the proposed change to the PBAPS, Units 2 and 3 TS does not involve a Significant Hazards Consideration. In support of this deterritination, an evaluation of each of the three (3) standards set forth in 10 CFR 50.92 is provided below.
-1.
- The'orooosed TS clanoes do not involve a sionificant increase in the probabilitV or conseauences of an accident previously evaluated.
. The addition of the EOC-RPT System will not involve a significant increase in the probability or consequences of an accident previously evaluated. The EOC-RPT System has been designed to appropriate standards and specifications to ensure that the ability of the plant to mitigate the effects of accidents is maintained. Each division is electrically, mechanically, and physically independent to meet the single failure criterion.
The EOC-RPT System will imarove the reactor core thermal response following
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' a turbine trip transient causec by either a turbine control valve fast closure or a
. turbine stop valve closure. The EOC-RPT will be relied upon to reduce the fuel 6
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Docket Nos. 50-277-4-
.50-278 License Nos. DPR-44 4
DPR-56 thermal mechanical transient excursion such that fuel thermal limits are not violated. Under conditions when the system is inoperable, more conservative thermallimits will be enforced.
The new system will utilize existing RPS logic to initiate the Reactor Recirculation System (RRS) pump trips on a turbine generator trip and a
. generator load rejection event. The inputs to RPS used by EOC-RPT will be from turbine stop valve (TSV) limit switches and turbine control valve (TCV) oil pressure switches. There will be no direct interface between the EOC-RPT System and the main turbine control system. Thus the new system can not initiate a turbine trip or generator load rejection event. This change does not result in significant increase in the probability of events described in the UFSAR. Additionally, the probability of inadvertent single or dual recirculation pump trips due to the addition cf the EOC-RPT components will not be significantly increased by this modification.
No new challenges to the reactor coolant pressure boundary will result from the incorporation of the EOC-RPT System which could result in a significant increase in the consequences of an accident.
2.
The orooosed TS chances do not create the oossibility of a new or different kind of accident from any accident oreviously evaluated.
The EOC-RPT System has been designed to appropriate standards and specifications to ensure that no new sequence of events or failure modes will occur such that a transient event will escalate into a new or different type of accident.
The PBAPS UFSAR evaluates several recirculation pump trip events, including the limiting case of a pump seizure. A spurious dual EOC-RPT pump trip is similar to other RRS pump trip events evaluated in the UFSAR and does not represent a different type of accident.
Additionally, this modification will not create any new failure mode or sequences of events that could lead to a different type of accident than previously evaluatedc The new EOC-RPT System will not involve any new challenges to a fission product barrier. The EOC-RPT System does not make any changes to the_ design function of the RRS. Therefore, the new equipment installed by this modification cannot create the possibility of a different type than previously evaluated in the SAR.
The EOC-RPT System is classified as important-to-safety. Failure or malfunction of the new equipment will not prevent or affect the ability of safety-related or important-to-safety systems to respond to the design basis accidents described in the FSAR.
There will be no software used in the EOC-RPT System. The system logic consists of two electrically and physically separated trip systems; one will be p
used to trip one EOC-RPT System breaker, and the other will bo used to trip the second EOC-RPT System breaker for each pump.
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1 Dock t Nos. 50-277 ~
- 50-278 License Nos. DPR-44 DPR-56 The design of this modification assures that the new system is not susceptible to~
electromagnetic (EM)' emissions'and will not cause inadvertent operation of existing plant equipment due to EM emissions.
Bas' ed on the previous discussion, the possibility of a new or different kind of accident from any accident previously evaluated will not be created.
3.
The orooosed TS chances do not involve a sianificant reduction in a marain of safety.
No margins of safety are reduced as's result of this change to the TS. The installation of this modification will not affect the margin of safety as defined in the Bases of the Technical Specifications. The EOC-RPT System will ensure
' that fuel thermal limits are not exceeded during the limiting transient. In the event that the EOC-RPT System is determined to be inoperable, specific operating limits are provided in the COLR. In all cases, thermal limits are not exceeded and the margin of safety is not reduced.
The plant LOCA response will not change for present core configurations.
. (i.e.,9 x 9 fuel) with the EOC-RPT System installed. For GE 8 x 8 fuel, which
. could be used at a future time, there could be a small increase in Peak Cladding Temperature (PCT). This increase would still be well below the 2200 F acceptance limit defined in 10 CFR 50.46. Since this limit will not be exceeded, there will be no reduction in the margin of safety. This modification does not
. impact the safety function of the RRS piping, thus reactor coolant pressure
' boundary safety limits are not affected. Therefore, this change does not result in the reducticn of any margin of safety.
Information Sucoortina an Environmental Assessment An environmental assessment is not required for the proposed changes since the proposed changes conform to the criteria for." actions eligible for categorical exclusion" as specified in 10 CFR 51.22(c)(9). The proposed changes will have no impact on the J environment. The proposed changes do not involve a significant hazards consideration as discussed in the preceding section. The proposed changes do not involve a significant change in the types or significant increase in the amounts of any effluents that may be released offsite. In addition, the proposed changes do not involve a significant increase in individual or cumulative occupational radiation exposure.
' Conclusion' We have concluded that the proposed change to the PBAPS, Units 2 and 3 TS does not involve a Significant Hazards Consideration.
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Dock:t Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 Table 1 i:
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Section 3, Paragraph 1 of The EOC-RPT System will use the same
" Design Basis" Appendix B to SRP setpoints as the RPS. These setpoints are Section 7.1 discusses based on the PECO Energy improved Section 3, Paragraph Instrument Setpoint Control Program (llSCP) 9 of IEEE 279, and methodology. This methodology was invokes Regulatory developed using the same ISA standard that Guide (RG) 1.105 with was endcrsed by the USNRC in RG 1.105, regard to instrument and was used as the basis for the PBAPS, spans and setpoints.
Units 2 and 3 improved Technical Specifications.
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Section 4.1, Paragraph 2 of Manual EOC-RPT System breaker operation
" General Appendix B to SRP will be provided from the main control room.
Functional Section 7.1 discusses Manua initiation of the logic is not included in Requirements" manual initiation the design since manual initiation of the EOC-requirements per RG RPT function is not possible within the 1.62.
required response time.
I Section 4.2, Paragraph 3 of A failure modes and effects analysis shows
" Single Failure Appendix B to SRP that the recirculation pumps will trip even if Criterion" Section 7.1 discusses there is a single failure. PBAPS, Units 2 and 3 single failure criteria are not committed to IEEE 379 or RG 1.53.
Section 4.6, Paragraph 7 of The redundant EOC-RPT trip systems will be
" Channel Appendix B to SRP independent and physically separated using independence" Section 7.1 discusses the same criteria as used for safety-related guidance for channel circuits. PBAPS independence criteria for independence per safety-related circuits is described in UFSAR IEEE 384 and RG Sections 7.1 and 8.4. EOC-RPT System 1.75.
cables are treated as safety-related cables.
The design contains no components common to both trip systems. PBAPS, Units 2 and 3 are not committed to IEEE 384 or RG 1.75.
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Dock t Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 Section 4.10, Paragraph 11 of The EOC-RPT System design meets the -
" Capability for Appendix B to SRP periodic testing requirements described in Test and Section 7.1 discusses UFSAR Section 7.1. PBAPS is not committed Calibration" guidance for periodic to IEEE 338, RG 1.22, or RG 1.118.
testing per RG 1.22 and IEEE 338, as supplemented by RG 1.118.-
Section 4.13, Paragraph 14 of Manual bypass of the EOC-RPT System logic
" Indication of Appendix B to SRP for testing will be under the control of the Bypass" Section _7.1 discusses reactor operator and will be continuously guidance provided in annunciated in the control room when used.
RG 1.47 and BTP The EOC-RPT System trip logic control power ICSB 21.
failure will be annunciated in the control room.
The EOC-RPT System breaker control power status will be indicated on the main control room console. Loss of breaker control power is considered to be an infrequent occurrence (i.e., less frequently that once per year).
PBAPS is not committed to RG 1.45 or BTP ICSB 21.
Section 4.17, Paragraph 18 of See section 4.1 above.
" Manual Initiation" Appendix B to SRP Section 7.1 discusses guidance per RG 1.62.
Section 4.22, Paragraph 23 of The EOC-RPT System is treated as safety-
" identification" Appendix B to SRP related for identification purposes. The Section 7.1 discusses identification distinguishes between redundant guidance per IEEE 384 circuits. The method of identification is as supplemented by described in UFSAR Sections 7.1 and 8.4.
PBAPS is not committed to IEEE 384 or RG 1.75.
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