ML20086Q453

Tech Spec Change Request 91-07 to Licenses DPR-44 & DPR-56, Changing Tech Specs to Implement Surveillance Testing Module of Util Plant Info Mgt Sys & Addressing Concerns Noted in Insp Repts 50-277/90-01 & 50-278/90-01

ML20086Q453
Person / Time
Site:	Peach Bottom
Issue date:	12/19/1991
From:	Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20086Q456	List: ML20086Q453 ML20086Q457
References
91-07, 91-7, NUDOCS 9112300204
Download: ML20086Q453 (13)

Text

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. PIIILADELI'IIIA ELECTRIC COhll'ANY NUCLEAR GROUP HEADQUARTERS 955-65 CHRSTERBROOK BLVD.

WAYNE. PA 19087 5691 (215) 64G 6000 NUCLEAR ENGINEERING & $0RVICES DEPAirTMfNT December 19, 1991 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 Dottom Atomic Power Station, Units 2 and 3 Technical Specifications Change Request 91-07

Dear Sir:

Philadelphia Electric Company (PECo) hereby submits Technical Specifications Change Request (TSCR) No. 91-07, in accordance with 10 CPR 50.90, requesting a change to Appendix A of the Peach Pottom Facility Operating Licenses. The proposed changes concern the definition of Surveillance Frequency.

! Attachment 1 to this letter describes the proposed I changes, and provides justification for the changes. Attachment 2 contains the revised Technical Specification pages.

If you have any questions regarding this m6tter, please contact us.

Verg truly y rs M +d G. J. ck, Manager Licensing Section

Enclosures:

Affidavit, Attachment 1, Attachment 2 cca T. T. Martin, Administrator, Region I, USNRC J. J. Lyash, USNRC Senior Resident Inspector, PBAPS T. M. Gerusky, Commonwealth of Pennsylvania t

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COMMONWEALTH OF PENNSYLVANIA:

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COUNTY OF CHESTER-D. R. Helwig, being first duly-sworn, deposes and-says: ,

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That-he is Vice President of Philadelphia. Electric Company; the Applicant herein; that.he has read the attached, Technical. -i Specifications Change Request (Number 91-07) for Peach. Bottom Facility Operating Licenses DPR-44 and DPR-56,Jand 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. .

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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 8

DPR-56 TECHNICAL S13CIFICATION CHANGE REQUEST 91-07

" Revisions to Surveillance Frequency Definition" Supporting Information for Changes 10 Pages u

. Dockot Noa. 50-277

. 50-278 License Nos. DPR-44 DPR-56 Philadelphia Electric Company (PECo), Licensee under Facility Operating Licenses DPR-44 nnd DPR-56 for the Peach Bottom Atomic Power Station (PBAPS)' Unit Nc. 2 and Unit No. 3, respectively, requests that the Technical Specifications contained in Appendix A to the Operating Licenses be amended. Proposed changes to the Technical Specifications are indicated by vertical bars in the margin of page 8. A proposed revised page 8-for each unit is included in Attachment 2.

The proposed changes concern the definition of Surveillance Frequency. Two of the-proposed changes described below are nee'ded to implement the Surveillance Testing module of our Plant Information Management System (PIMS). _This module will replace the current computer program used for scheduling and documenting surveillance test performance, referred to as the "

Surveillance Tests and-Records System (STARS). 'Another proposed change described below addresses a concern discussed by the NRC in Inspection Reports 50-277/90-01, 50-278/90-01 and 50-277/91-23 and 50-278/91-23, and is also addressed by our PIMS Surveillance Testing module. The concern was-that the STARS slgorithm did not al'.ow daily scheduling of tests or adequate control of tests required for mode or power-level changes (event based),

i We request that the proposed changes be-approved by the NRC by March 1, 1992, but not effective until after implementation and successful testing of the PIMS Surveillance Testing module. We r

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_ Docket Nos. 50-277

, , 50-278 License Nos. DPR-44 DPR-56 I

currently expect this offective date to be May, 1992. The reason  :

for requesting this interval between approval and effective dates i is to allow us to develop and implement an appropriate training ,

program for the PIMS module based on the final-NRC-approved definition of Surveillance Frequency.

Description of Changes (1) Add to-the definition of Surveillance Frequency on page 8-i the following, "Specified-periodic surveillance intervals--

are defined ass (N) Hours At : least _ once ; per - (N) hours-Shiftly , At least once'per112-hours Daily Atleast~once per_24 hours-(N) Days At'leastionce per (N). days.

Twice Per Week At leastionce per_4. days-Weekly At least once per 7-days At 1 east once_per_-(7xN)fdays-

~

(N) Weaks

-Semi monthly' AtEleastionce_perJ151 days Monthly 'At least once per 31 days- -

2~ Month At.least-oncelperL61-days _

=

-Quarterly or'3 month At least_.once per-92 daya Semi-annually.or,6 month- At least.once per 184 days l -

Annually or:12. month At least'once-per 366 days Once-Per Cycle' At_least'once per 550idays

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' -Docket Nos.-50-277 50-278 License Nos. DPR-44 DPR-56 18 Month At least once per 550 days Refuel At least once per 550 days (N) Years At least once per (366xN) days (N) Refuel Cycle At least once per (550xN) days" (2) Delete from the definition of Surveillance Frequency-the-sentence'which reads, "The operating cycle interval as pertaining to instrument and electrical surveillance shall not exceed 18 months."

(3) Delete from the definition of Surveillance Frequency the sentence which reads, "In cases where,the elapsed time interval has exceeded 100%-of-the specified-interval,-the-next surveillance interval shall commence at the end of the original specified' interval." j (4) Delete from the definition of-Surveillance Frequuacy the last sentence which reads, "When a testl is deferred under this provision, the next surveillance interval shall commence at the end of the original specified interval."

Safety Discussion Change Request (1) proposes to add a table to the-

Technical Specifications (TS) whichcexplicitly defines:the.various surveillance intervals in units-of'h'ours or days. The current-I;

s Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 PBAPS TS do not contain definitions for surveillance intervals. '

Because of limitations of the STARS program, intervals are interpreted with respect to calendar intervals. For example, when TS require a test to be performed weekly, STARS schedules the test to be performed anytime during a calendar week. As a result, weekly tests are scheduled 52 times during a year, but the interval between tests may be as long as 15 days (including the 25% grace period). The proposed table is more conservative than the current practice in that it will limit the time between weekly tests to 7

) days + 25% or 8.75 days. The proposed tatie includes applicable intervals defined in Table 1.1 of NUREG-0123, Revision 3, " Standard Technic- 9cifications for General Electric Bolling Water Reactors TS) and other curveillance intervals used throughout

)

the PBAPS TS. Those other surveillance intervals not listed in Table 1.1 of the STS were included in the proposed table for completeness and to avoid any misinterpretations._ This change request addresses a concern discussed by NRC in Inspection Reports 50-277/90-01, 50-278/90-01 and 50-277/91-23, 50-278/91-23.

Change Request (2) proposes'to delete a sentence defining length of operating cycle. This deletion is proposed because the surveillance interval "once per cycle" is-included in the proposed table. Eliminating redundancy between the proposed table and the ,

existing text is proposed to avoid confusion in interpreting the 1 definition.

. Dochet Now. 50-277

, 50-270 License Nos. DPM-44 DPR-56 Change Roquest (3) proposos to change the referenco dato for scheduling a subsequent test from the dato thr.t thu test was originally schaduled to the date that the test was last actually performed. A purposo of a Survoillanco Test (ST) program in to periodically verify t.ho operability of equipment. Once a test is performed, the operability of the equipment is verified for the period between that curront performanco dato and the dato of performance of the last test. Accordingly, the next test should be scheduled based-upen the most recont date that operability-was verified. The sentonce proposed to be doloted in Change Roquest ,

1 (3) is not found in STS. The Revision 3 vorsion of GTG still '

contains Specification 4.0.2.b which restricts extending survoillanco ntervals such that the combined time interval for any throo consecutive surveillanco intervals must bo less than 3.25 timos the specified surveillance interval. Removal of this 4 restriction was later concluded by the NRC to be a greator bonofit to plant satoty.

This conclusion is documented in Generic Letter 09-14 wheroin the NRC oncouraged licensoos to propose a change to their TS to remove this rostriction. The proposed deletion discussed in Chango Roquest (3) removes a similar rostriction.

Change Request (3) is also needed to implomont.the pIMS modulo, discussed earlier, in the a6me form that it will be used at Limerick Generating Station (uGS). Implomontation of this pIMS module is an overall enhancoment to the ST program. One of the many benefits, as discussed with respect to Chango Request (1),.is the ability to schedulo.STs on a daily basis.and to better control

Docket Hos. 50-277

. 00"270 l License Nos. DPR-44 DPR-56 STs performed on an event basia. Additionally, the current algorithm for this module usos tna same scheduling thilosophy used at plants with STS, including LGS. In the interont of of:ficiency and avoidance of confusion, it is desirable for PDAPS and LGS to have a common approach to ST programs.

l Chango Roquest (4) is also proposed to allow implomontation of the PIMS module. This roguest concerns a paragraph which was added to the definition of Surveillanco Frequency in Amondments 133 and 136 for Units 2 and 3, respectively. The purpono of this paragraph was to allow the emergency dio'so) generator (EDG) surveillanco testing required once por operating cycle by TS Section 4.9.A to be deforred until the next refueling outage, provided the equipment has boon similarly tested and moots the survoillanco requirements of the other unit.

This provision was requested because of the unique electrical ccnfiguration of PBAPS. The PBAPS sito has four EDGs which are equally thered between- Units 2 and 3. The EDG testing discussed involves the EDC and the associated unit sp9cific equipment and instrumentation which controls the opening of circuit breakers to shed loads and the closing of circuit breakers to sequence on loads. Performance of this testing requiro- ; plant shutdown.- The unit specific equipment included in this testing is tested by other TS required STs. The purpose of this previously granted provision was not to allow an extensivo grace period, but to take credit for

, tests performed on the some equipment,-either to satisfy the other I .

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Docket Nos. 50-277 50-270 Licenso Nos. DPR-44 DPR-5G -

unit's TS or to satisfy other TS requirements on the same unit, thoroby preventing a plant shutdown. As stated previously, Chango Roquest (4) is nooded to implomont the PIMS Survo111ance Testing module which schedules subsequent STs based on previouc performanco  ;

dato instead of previously scheduled dato. Implomontation of Chango Roquost (4) will not adversely affect the purpose of the -

previously granted provision or the basis upon which it was i

approved by the NRC.

No Significant Fazards Consideration The four change requests proposed in this Application do >

not constitute a significant hazards considoration in that:

1) The proposed changes do not involve a significant increaso in the probability or consequences of an accident previously_ovaluated.-

One of the purposes of the proposed changes is to allow implomontation of a'now survoillance testing software I system. Implomontation of this software will be an overall.onhancement to the surveillance testing program.

l Ono benefit is the ability to schedule survoillance tests on a daily basis and.to better control STs performed on an.ovent basis. Another-purpoao of the proposed changes is to' provide surveillanco interval definitions which are

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Docket Noo. 50-277 50-278 Licenso Nos. DPR-44 DPR-56 l

more conaarvative than thoso currently used. Attaining '

those two purposos could result in increased assuranco of plant equipment rollability. This will not increase the probability of accidents previously evaluated. The proposed changos oo not affect the consequences of accidents previously evaluated because they do not affect the initia) conditions or procursors assumed in any Updated Final Safety Analysis Report Section 14 accident analysos. Further, those proposed changes do not decrease the offectiveness of equipmo.:: rolled upon to mitigate the previously ovalunted accidents.

11) The proposed changos do not croato the possibility of a now or difforont kind of accident from any previously, ovaluated.

The proposed changes do not alter the design or-function of any equipment or introduce any now failure modos.

Implementation of proposed changes does not involve any now plant configurations, testing methods or operating scenarios. Therefore, the proposed changes do not create the possibility or a new or different kind of accident.

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, ,, Docket Nos. 50-277 50-278 Licenso Nos. DPR-44 DPR-56 111) Tho proposed changes do not involvo a significant reduction in a margin of safety.

One of the proposed changes involves survoillanco  ;

interval definitions which are more consorvativo than thos6 cdrrently in place. Another proposed chango deletes a requiremont to schedulo subsequent surveillance tests based on the originally scheduled dato. This

, requirement is similar to a requirement which the NRC, in Generic Lottor 89-14, recommanded that licensoos removo from Technical Specifications because of a greator benefit to plant safety. The remaining two changes aro  ;

proposed for clarity and consistency, and do not adversely affect the surveillanco testing program.

Consequently, the proposed changes do not reduce any margin of safety.

Environmental Assessment An environmental impact assessment is not required for the changes proposed by this Application because the changes conform to the criteria for " actions eligible for categorical exclusion" as speciflod in 10 CFR 51.22(c)(9). The proposed changes do not involve any systems that have a direct relationship with the' environment. The changes involve the definition of l-L i

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,' Docket Nos. 50-277

. 50-278 License Nos. DPR-44 DPR-56 Survo111anco Frequency. The Application involves no significant 1 chango in tho typos or significant increase in the amounts of any offluents that may bo roloased offsito and there will be no significant increaso in individual or cumulative occupational radiation exposure. ,

ponclusion The Plant Operations Review Committoo and the Nuclear Review Board have reviewed those proposed changes and have concluded that they do not involve an unroviewed safety question ,

and are not a throat to the health and safety of the public.

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