ML20247E357
| ML20247E357 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 07/18/1989 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8907260144 | |
| Download: ML20247E357 (3) | |
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I 10 CFR 50.91 PHILADELPHIA ELECTRIC COMPANY j
J NUCLEAR GROUP HEADQUARTERS
]
I 955-65 CHESTERBROOK BLVD.
l WAYNE, PA 19087-5691 (215) 640-6000 July 18, 1989 Docket Nos. 50-277 50-278 U.S. Nuclear Regulatory Commission Attn: Document Control Desk.
Washington, DC 20555
SUBJECT:
Peach Bottom Atomic Power Station, Units 2 and 3 Request for Exigent Approval of a Technical Specification Change Request
Dear Sir:
This. letter is to request that the changes to the Peach BQttom Atomic Power Station, Units ja and 3 Technical Specifications proposed-in Technical Specification Change Request No. 85-04 be approved on an exigent basis in order to reduce unnecessary testing
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and potential degradation of safety-related equipment.
The technical specification change request, which was submitted to the NRC on August 26, 1988, proposes a change to Technical Specification
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4.5.F.1 (change request 19) to delete the accelerated testing requirements for Low Pressure Core and Containment Cooling systems
-when'one emergency diesel generator (EDG) is inoperable.
The change request, as stated on pages 27 and 20 of the application, is based upon i) the Standard Technical Specifications (NUREG-0123, Revision 3), ii) the reduction in system startup stresses and long term wear, iii) system reliability, and iv) the relationship between EDG operability and the operability of the Low Pressure Core and Containment Cooling systems.
The app]ication provides information supporting the reliability of components of the Residual Heat Removal (RHR), Core Spray (CS), and the High Pressure Service. Water (HPSW) systems.
The application addresses how the inoperability of one EDG does not impact the operability of the Low l,
. Pressure Core and Containment Cooling systems supplied by the operable EDGs and how operability of these systems is assured by other sections of the Technical Specifications.
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8907260144 090718 l' i e PDR ADOCK 05000277 i
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.,..Do'cument Control. Desk July 18,.1989 Page 2 The station is currently finishing the annual overhaul of the second of four EDGs and plans to complete the overhaul of the remaining two EDGs in August, 1989.
The overhauls of the remaining
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EDGs were postponed when the new plant manager recently recognized i
.the excessive amount of testing which the' Low Pressure Core and ContainmentLCooling systems are subjected to in order to comply with Technical Specification 4.5.F.1.
Tne remaining work is scheduled for August to allow processing of the technica] specification change request'and completion of the EDG overhauls within their annual
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surveillance intervals.
The schedule also considers the manpower resources immediately preceding the restart of Unit 3.
Annual EDG overhaul work has been completed at power over four week periods in the past with each EDG inoperable for a one week duration.
The safety impact of excessive testing of the Low Pressure Core and Containment Cooling systems during these overhauls was previously recognized and a technical specification change request was submitted to delete the testing requirements.
During the recent overhauls of the first and second EDGs, the plant manager became sensitive to the excessive amount of testing being performed on the RHR system.
Specifically, the negative impact of excessively i
testing the MO-10-25 (A, B), MO-10-34 (A, B) and the MO-10-154 (A, B) valves of the RER system was realized.
The valves are in 18 and 24 inch lines and the motor operators for the MO-10-154 valves are approximately 50 hp.
The testing also requires daily operation of four pumps which are powered by 2000 hp 4kv motors.
This testing also unnecessarily diverts a control room operator's attention from his.ormal duties, diverts floor operators from performance of equipment monitoring, and could cause an increase in operator overtime.
Although a recent revision to the surveillance test which satisfies Technical Specification 4.5.F.1 has reduced the number of valvo operations, plant management still feels the amount of testing activity is excessive relative to the deletion of the testing as requested by the technical specification change request.
In summary, this request for exigent approval of Technical Specification Change Request No. 85-04 meets the requirements for requesting an exigent technical specification change as provided in 10 CPR 50.91, paragraph (a)6.
The safety impact of the accelerated testing of the Low Pressure Core and Containment Cooling systems, required by Technical Specification 4.5.F.1, was previously identified and a technical specification change request was submitted on August 26, 1988.
During the current annual overhaul of the EDGs, the safety implications of potentially degrading specific RHR system valves due.to long term wear were recognized by the new plant manager.
The overhaul of the remaining EDGs has been postponed until August to allow time for processing the technical specification change request.
The EDG overhauls must be completed j
in August to meet their annual surveillance intervals in conjunction
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with expected plant manpower resources, i
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- i?' -, Documsnt7 Control Desk.
July'18, 1989
.i Page'3
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If you have any questions regarding this request,-please
. contact us.
i Very truly yours, f
i
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G. A. Bunger, Jr.
Director Licensing Section Nuclear Support Division cc:
W. T. Russell, Administrator, Region I, USNRC T. P. Johnson, USNRC Senior Resident Inspector R.E. Martin, USNRC Project Manager 1
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