Text

Discusses Suppl 10 to Change Request 93-16 Re Conversion to Improved TS
	ML20085D780
Person / Time
Site:	Peach Bottom
Issue date:	06/07/1995
From:	Hunger G; PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20085D783	List: ML20085D780; ML20085D786;
References
	NUDOCS 9506160347
	Download: ML20085D780 (31)
	v • d • e

No *

.tasuon support occutm3nt

.t 10 CFR 50.90 4

'Y 5 J"o*a ita b,

PECO ENERGY 965 Chesterorook Boulevard ~

Wayne. PA 19087-5691 June 7,1995 9

Docket Nos. 50-277 50-278 L' cense Nos. DPR 44 DPR-56 a

s U.S. Nuclear Regulatory cow,;eeiO6 Attn: Document Control Desk Washington, DC 20555 i

i

Subject:

Peach Bottom Atomic Power Station, Units 2 and 3 l

Supplement 10 to TSCR 93-16 Conversion to improved Technical Specifications

Reference:

(1) Letter from G. A. Hunger, Jr. (PECO Energy) to USNRC Document Control Desk dated September 29,1994 t

Dear Sir:

t In Reference (1), PECO Energy submitted Technical Specification Change Request (TSCR) 93-16, requesting changes to Appendices A and B of the Faculty Operating Licenses for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. This TSCR proposed an overall conversion of the current PBAPS Technical Specifications to the improved Technical Specifications (ITS), as contained in NUREG 1433, " Standard Technical Specifications, General Electric Plants, BWR/4."

A public meeting was held on April 19,1995 to address questions concoming ITS Section 3.8, Electrical Distribution. During this meeting, PECO Energy presented preliminary responses to the NRC's questions. The attachment to this letter provides PECO Energy's response to these concerns. Where the information provided in this attachment is different from the information presented at the public meeting, a vertical bar has been included.

If you have any questions, please contact us.

Very truly yours, G. A. Hunger, Jr.

Director - Licensing Affidavit, Attachment f

cc:

T. T. Martin. Administrator, Region I, USNRC 0g W. L Schmidt, USNRC Senior Resident inspector, PBAPS

+

R. R. Janati, Commonwealth of Pennsylvania iu 9506160347 950607 PDR ADDCK 05000277 P

PDR l1

I ff f ' y _.

COMMONWEALTH OF PENNSYLVANIA ss.

COUNTY OF CHESTER W. H. Smith, III, being first duly sworn, deposes and says:

That he is Vice President, Station Support, of PECO Energy Company; the Applicant herein; that he has read the attached Supplement 10 to Technical Specifications change Request 93-16 for Peach Bottom Facility Operating Licenses DPR-44 and DPR-56, and knows the contents thereof; and that the statements and i

matters set forth therein are true and correct to the best of his knowledge, information and belief.

y Vice President Subscribed and swo n to before me this day of M

1995.

l M/,

t n

No,tary Public____

NotadSeaf Chester m~~n%

l

r e,

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING REQUEST FOR ADDITIONAL INFORMATION PEACH BOTTOM ATOMIC POWER STATION. UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS (ITS) REVIEW A1 The following clarification is requested in the support of documentation for RELCCATED requirements.

a.

In each of the following Discussion of Changes (DOC), add a discussion of the reasons why relocation of the subject item (s) is justified.

3.8.1.R, 3.8.1.R,, 3.8.1.R, 3.8.1.R., 3.8.1.R, 3.8.1.R., 3.8.1.R.

i 3

3.8.3.R,, 3.8.3.R, 3.8.3.R.

3 3.8.4.R,, 3.8.4.R 3 3.8.6.R, 3.8.7.R, Resoonse The following clarifications are provided in support of the relocated items.

For each of the following Discussion of Changes, a discussion of the reasons relocation of the subject item (s) is justified is provided.

3.8.1 R i The requirements that Diesel Generator (DG) testing be conducted in accordance with manufacturer's recommendation regarding warmup and, as applicable, loading and shutdown; that loads in excess of the specified band for special testing, under direct monitoring of the manufacturer or system engineer, shall not invalidate the test; that water be removed from the DG day tanks after each occasion when the DG has operated for greater than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ; and that performance of the hot restart test shall not be used to satisfy the requirements of the fast start test are details of the testing and operation of the DGs and are not necessary to assure the DG OPERABluTY.

The requirement to also perform the 10 year interdependence test after any modification which could affect DG interdependence is a post maintenance / modification testing requirement that is not necessary to ensure the OPERABluTY of the DGs. After the performance of any maintenance / modification that could cause a required SR to be failed, SR 3.0.1 requires the appropriate SRs (in this case SR 3.8.1.20) be performed to demonstrate the OPERABILITY of the affected components.

1-

.c.

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING 3.8.1 R, The detals of the trip level settings of the 480 V emergency load center timers and the 4 kV emergency bus sequential loading relays, the detaus of the number of channels provided by design, and the details of the function the timers and relays perform are not necessary to ensure the OPERABluTY of these components. The satisfactory performance of the requirements of SR 3.8.1.11, SR 5.8.1.12, SR 3.8.1.18, and SR 3.8.1.19 are adequate to ensure the OPERABILITY of these components.

3.8.1 Ra The requirement to inspect the DGs in accordance with procedures prepared in accordance with manufacturer's recommendations is a preventative maintenance type requirement. The failure to perform this requirement does not necessarily result in an inoperable DG. This requirement is oriented toward long term DG operability and does not have an immediate impact on EDG OPERABluTY. EDG OPERABluTY is verified by the SRs maintained in Specification 3.8.1. As a result, this requirement is not necessary to include in the Technical Specifications.

3.8.1 R.

The monthly verification of Conowingo Tie-Line Operability and NRC notification when the Conowingo Tie-Line is inoperable have not been included in the PBAPS ITS since these requirements are related to Station Blackout requirements. At this time, the NRC and the industry have not agreed that Station Blackout requirements should be included in the Technical Specifications. However, since PBAPS is crediting the Conowingo Tie-Line in our request to allow extension of a DG Allowed Outage Time (AOT), the same type verification of Conowingo Tie-Line Operability has been included in Required Action B.4.2.1. This Required Action must be performed prior to extending the DG AOT. Please note that revisions to this section may result from ongoing discussions with the NRC regarding TSCR 93-24. In addition, the Conowingo Tie-Line requirements are not necessary to ensure the OPERABluTY of the qualified offsite circuits or the DGs.

3.8.1 R, The requirement for the two qualified offsite circuits to be physically independent is an attribute of circuit OPERABILITY that is adequately controlled in the Bases. These details are not necessary in the Technical Specifications. The definition of OPERABluTY suffices.

i 3.8.1 R.

The requirement that provides a cross reference as to which TgMed Specification wSI apply if a 480 V emergency load center timer is inoperable is not mm+r,#y to ensure the proper application of the Technical Specifications. The determination of OPStABILITY and the resulting entry into the appropriate ACTIONS is inherent in use of Technical Specifications. The correct use and application of the PBAPS ITS, with rega-d to actions associated with an inoperable 480 V emergency load center, is adequately addressed by the definition of OPERABluTY and LCO in Section 3.0.2. As a result, the requirement is not necessary to include in the Technical Specifications.,

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OlL TESTING 3.8.1 R.

PECO Energy has in place a program that monitors reliability of the EDGs. This program satisfies the requirements of GL 94-01, and as discussed in Regulatory Guide 1.160, is consistent with the provisions of 10 CFR 50.65

Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." This program is based on commitments made in response to Station Blackout, (Letter from G. A. Hunger, Jr., to US NRC, April 24,1991) and addresses EDGs only. PECO Energy has also developed a separate plan to implement 10 CFR l

50.65 for plant equipment covered by the maintenance rule, in accordance with the schedule promulgated by 10 CFR 50.56. EDGs are included in this plan; however, the plan has not been fully developed. It is expected that EDG availability will be monitored by the Summer of 1995, and that a modified INPO EDG performance indicator will be used to monitor EDG availability j

performance.

1 The removal of the DG accelerated testing requirements and special reporting requirements is being done in accordance with the guidance in NRC Generic Letter 94-01, Generic Letter 94-01 allows the removal of the Technical Specification provisions for DG accelerated testing provided a maintenance program consistent with the requirements of 10 CFR 50.65 for monitoring and maintaining the DGs is implemented. In our April 24,1991 letter to the NRC on Station Blackout (page 6 of 27, item 3), PECO Energy specifically committed to a targot EDG reliability of 0.975.

1 This performance criterion has been acknowledged in Regulatory Guide 1.160, " Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," as an acceptable performance criterion for monitoring EDG performance. This commitment is implemented at PBAPS by procedure A-C-72, Rev. O, " Emergency Diesel Generator Reliability Program," effective November 23,1992.

PECO Energy reaffirms our ccmmitment to maintaining a EDG tarpet reliability of 0.975, and the target reliability value will continue to be monitored. This commitment, and our procedure, A-C-72 which implements this commitment satisfy the requirements for GL 94-01, necessary to remove the accelerated testing requirements and special reporting requirements for EDGs.

3.8.3 R, Post accident electrical loading and fuel consumption is not equally shared among the PBAPS DGs. Therefore, it may be necessary to transfer post accident loads between DGs or to transfer fuel oil between storage tanks to achieve 7 days of post accident operation for all four DGs.

Each storage tank contains sufficient fuel to support the operation of the DG with the heaviest load for greater than 6 days. The requirement to verify the fuel transfer pump transfers fuel from each fuel storage tank to the day tank of each DG via the installed cross connection lines is not necessary to ensure the OPERABILITY of the DGs since the preferred capability exists to transfer post accident loads between the DGs to equalize fuel oil consumption and ensure the DGs can operate for 7 days.

3.8.3 R3 The requirement to sample the fuel oil in the other three fuel oil storage tanks and confirm conformance with fuel oil particulate limits within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is not necessary to ensure the OPERABILITY of the DGs for the following two reasons. First, an unexpected high particulate level is most likely the result of poor sample procedures (bottom sampling), contaminated sampling equipment, or errors in laboratory analysis because particulate levels are trended which normally allows sufficient time to correct the problem before limits are exceeded.

Secondly, the presence of particulate does not mean failure of the fuel oil to burn property in the diesel engine, since particuhte concentration is unlikely to change significantly botween Surveillance Frequency inter tals, and since proper engine performance will have been demon-strated within 31 days. -

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3

)

IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING 3.8.3 R.

The requirements related to the fuel oil storage tank cathodic protection system are not necessary to ensure the OPERABluTY of the DG fuel oil storage tanks. As stated in the September 2,1987 letter from E. J. Bradley (PECo) to T. E. Muriey (NRC) and CTS Bases 4.9, these requirements were added to the Technical Specifications to centralize commitments related to Regulatory Guide 1.137, Position C.2, involving PBAPS. The NRC SER supporting PBAPS Amendment Numbers 131 and 134 (dated May 31,1988) states that the proposed requirements for the fuel oil storage tank are the same as those specified in Regulatory Guide 1.137. This NRC SER also stated the proposed change to the assoc;sted SER basis section (CTS Section 4.9 Bases) was reviewed and found to be acceptable. These requirements are oriented toward maintaining the long term operability of the DG fuel oil storage tanks and do not have an immediate Impact on the OPERABluTY of the DG fuel oli storage tanks.

3.8.4 R, The requirement for measurement and logging of overall battery voltage is not necessary to ensure the OPERABluTY of the batteries. SR 3.8A.1 which requires periodic verification that batiery voltage is within required limits is adequate to ensure the OPERABlUTY of the batteries.

The requirement to initiate repair work on an inoperable battery system in the most expeditious manner to return the failed component to an operable status is not necessary to ensure the battery system is restored in a timely manner. The ACTIONS of Spacification 3.8.4 are adequate to ensure the battery system is restored in a timely manner.

3.8.4 R3 The description of the number of 125 V batteries and chargers that constitute a DC electrical power subsystem has been relocated to the Bases. These details are not necessary in the Technical Specifications. The definition of OPERABluTY suffices.

The interpretation of once per 60 months in the Note to SR 3.8.4.7 as it relates to the performance of a discharge test has been relocated to the Bases. This Interpretation is provided for clarification and is not required for the application of the Note to SR 3.8.4.7.

3.8.6 R, The requirement for measurement and logging of battery cell parameters is not necessary to ensure the OPERABluTY of the batteries. SR 3.8.6.1 and SR 3.8.6.2 which require periodic verification that battery cell parameters are within required limits are adequate to ensure the OPERABluTY of the batteries.

The requirement specifying cell voltage measurements be performed "to nearest 0.1 volt" is not necessary to ensure the OPERABlWTY of the batteries. Table 3.8.6-1 specifies acceptance criteria for cell voltage of.>_2.13 volts for Category A and B limits and > 2.07 volts for Category C limits. As a result, if the acceptance criteria of Table 3.8.6-1 are satisfied, the relocated requirement (to nearest 0.1 volt) will be satisfied. This represents a more restricth,e change since, to satisfy the cell voltage requirements of Table 3.8.6-1, measurements must be performed to the nearest 0.01 volts. This item will be reclassified as a more restrictive change.

-4 s

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING 3.8.7 R, i

The requirement for the AC Distribution System to be energized is an attribute of AC Distribution System OPERABluTY that is adequately controlled in the Bases. These details are not necessary in the Technical Specifications. The definition of OPERABluTY suffices.

The description of the 4 kV emergency buses and 480 V emergency load centers that constitute the AC Distribution System have been relocated to the Bases. These details are not necessary in the Technical Specifications. The definition of OPERABluTY suffices.

b.

3.8.1.R.

The DOC Indicates, "In accordance with Generic Letter 94-01, " Removal of Accelerated Testing and Special Reporting Requirements for Emergency Diesel Generators,' the diesel generator accelerated testing requirements will be relocated to the PBAPS maintenance program for diesel generators." Generic Letter (GL) 94-01 states that licensees must commit to implement a maintenance program for monitoring and maintaining diesel generator (DG) performance consistent with the provisions of 10 CFR 50.65 and the gukiance of Regulatory Guide 1.160 within 90 days of the issuance of a license amendment to remove the provisions for accelerated testing and special reporting requirements. Please identify the location of your commitment to implement such a maintenance program.

EcsDonse PECO Energy has in place a program that monitors reliability of the EDGs. This plan satisfies the requirements of GL 94-01, and as discussed in Regulatory Guide 1.160 is consistent with the provisions of 10 CFR 50.65

Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants.* This program is based on commitments made in response to Station Blackout, (Letter from G. A. Hunger, Jr., to US NRC, April 24,1991) and addresses EDGs only.

PECO Energy has also developed a separate plan to implement 10 CFR 50.65 for plant equipment covered by the maintenance rule, in accordance with the schedule promulgated by 10 CFR 50.56. EDGs are included in this plan; however, the plan has not been fully developed.

It is expected that EDG availability will be monitored by the Summer of 1995, and that a modified INPO EDG performance indicator will be used to monitor EDG availability performance.

For more detalls on this program please refer to our response to A-1,3.8.1 R,.

A-2 The following clarification is requested in support of documentation for changes from the current technical specifications (CTS):

ITS 3 8.1 a.

CTS p. 34, 3.0.D.A,: ITS 3.8.1 allows 24/12 hours to declare required features inoperable when redundant required features are Inoperable and then take the appropriate actions for the resulting condition. The CTS requires immediate shutdown in the same condition (s) If a redundant feature is inoperable. This appears to be a less restrictive change, not an administrative change. Either change the designation for this change to less restrictive and modify the DOC accordingly or provide a justification for the administrative designation. l

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 i

EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING Resoonse i

CTS, page 34,3.0.D. Discussion of Change A, for ITS 3.8.1 is addressing the movement of the requirements to Specification 3.8.1, As annotated on CTS page 34, Discussion of Change L, for ITS 3.8.1 also applies to CTS 3.0.D. Discussion of Change L, for ITS 3.8.1 addresses the changes to the Completion Times for declaring required features j

l Inoperable when redundant required features are inoperable.

1 b.

CTS p. 81a, Table 4.2.B, item 15: 4 kV Emergency Power System Voltage Relays, l

second column: It is not clear what is being relocated here. Provide information regardh - what, if anything, is being relocated.

Resoonse Existing Specification 4.2.B (Table 4.2.B) requires an instrument Functional Test of the 4 kV Emergency Power System Voltage Relays (S), which provide a permissive for the individual load timers associated with each 4 kV emergency bus, once per operating cycle. The Functional Test of the 4 kV Emergency Power System Voltage Relays (S) is being relocated to the procedures which perform SR 3.8.1.11, SR 3.8.1.12, and SR l

3.8.1.19 because successful completion of any of these SRs constitutes a Functional Test of these relays.

j c.

CTS p. 218a, Footnote a: The change is acceptable, but it appears that the change is less restrictive and should be so justified. The A, justification could, with minor modifications, be an acceptable justification for a less restrict!ve change. Either change the designation for this change to less restrictive and modify the DOC accordingly or provide a justification for the administrative designation.

EffDD.DH The change to the existing Note stating the test 'shall" be conducted in accordance with manufacturer's recommendations regarding engine pre-lube and warmup is considered to be administrative since actual or simulated test signals may be used to satisfy these SRs. Therefore, the change acknowledges that the lack of a pre-lube or warmup does not prevent an actual start signal from being counted as a valid diesel test. In addition, if there were an actual event where the DG started and data was collected that demonstrated the SR acceptance criteria were satisfied, a Technical Specification Change Request would be pursued if that event was to be credited for satisfying the surveillance. However, the Technical Specification Change Request would describe the change as administrative in nature since all the acceptance criteria would have been satisfied and the test was more representative of realistic conditions.

d.

CTS p. 218e, Footnote c: DOC M. Includes a reference to surveillance requirement (SR) 3.8.1.14, but the justification is applicable to the CTS equivalent of ITS SR 3.8.1.15.

Explain this apparent discrepancy.

Resoonse Discussion of Change M, for ITS 3.8.1 incorrectly references SR 3.8.1.14. The correct reference is SR 3.8.1.15. The discussion of Change M for ITS 3.8.1 was revised in Revision A to TSCR 93-16, submitted May 16,1995. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OlL TESTING e.

CTS p. 218e, Footnote a: The change designated as A, appears to be a less restrictive change See item A-2.c above

]

Resoonas i

See response to kom A-2.c above.

f.

CTS p. 218f, 4.9.1.2.h.1.b, A,: This change involves deleting a CTS requirement, even though the requirement is incorrect. In light of this, the change should be justified on ks l

own merks as a less restrictive change. Either change the d::'y+" -i for this change j

to less restrictive and modify the DOC accordingly or provide a justification for the j

administrative designation..

l

-l Renoonae At PBAPS, the permanent loads with respect to the DGs are interpreted to be the associated 4 kV emergency buses As a result, the change to explicitly specify i

energizing the associated 4 kV emergency buses instead of permanent loads in the i

Technical Specifications is considered to be administrative in nature.

l l

g.

CTS p. 218f, Footnote a, A,: This change appears to be a less restrictive change. The l

change involves changing a mandatory requirement to a permissive which is less restrictive. Either change the designation for this change to less restrictive and modify the DOC accordingly or provide a justification for the administrative designation.

l Renoonae See response to item A-2.c above.

h.

CTS p. 218g,4.9.A.1.2.3.b: The change designated as A, appears to be a less restrictive change. See item A-2.f above.

j i

Response

See response to item A-2.f above.

j l.

CTS p. 218g, Footnote a: The change designated as A, appears to be a less restrictive i

change. See item A-2.c above.

Response

l i

See response to item A-2.c above.

j.

CTS p. 218h, Footnote a, A,: This change appears to be a less restrictive change.

l The change involves changing a mandatory requirement to a permissive which is less t

restrictive. Either change the designation for this change to less restrictive and modify the DOC sccv,e. gly or provide a justification for the administrative designation.

l I

Response

~

See response to item A-2.c above.

)

l l - --

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS,' SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING k.

CTS p. 2181, 4.9.A.1.2.m. L,: GL 9441 states that licensees must commit to implement a maintenance program for monitoring and maintaining DG performance consistent with the provisions of to CFR 50.66 and the guidance of Reguistory Guide 1.100 within 90 days of the issuance of a license amendment to remove the provisions for accelerated testing and special reporting requirements. Identify the location of your commitment to ;

implement such a maintenance program.

Resoonse PECO Energy has in place a program that monitors reliabHty of the EDGs. This program satisfies the requirements cf GL 9441, and as discussed in Regulatory Guide 1.160, is consistent with the provisions of 10 CFR 50.86 " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants

This program is based on commitments made in response to Station Blackout, (Letter from G. A. Hunger, Jr., to US NRC, Apri 24,1991) and addresses EDGs only. PECO Energy has also developed a separate plan to implement 10 CFR 50.66 for plant equipment covered by the maintenance rule, in accordance with the schedule promulgated by 10 CFR 50.56.

EDGs are included in this plan; however, the plan has not been fully developed. It is expected that EDG availability will be monitored by the Summer of 1996, and that a modified INPO EDG performance indicator will be used to monitor EDG availabulty performance. For more detaus on this program please refer to our response to A-1, 3.8.1 R.

l.

CTS p. 220s, 3.9.B.4, A,: This appears to be a less restrictive requirement. In this condition, CTS would rsquire immediate default to the Conditions and Required Actions of affected systems / components (1 DG and 1 offsite source inoperable, and DG inoperable in Unit 3). The ITS allow 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months before any action is required. Elther change the designation for this change to less restrictive and modify the DOC accordingly or provide a justification for the administrative designation.

Response

in ITS, with one offsite circuit inoperable and one DG inoperable and no AC power to any 4 kV emergency bus, the Note to Condition D of Specification 3.8.1 requires the applicable Required Action of LCO 3.8.7 to be taken for an inoperable subject unit AC power distribution subsystem. The applicable Required Action is Required Action C.1 of LCO 3.8.7 which allows 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to restore the subsystem. In the case of a 4 kV bus de-energized, CTS 3.9.B.7 would require the associated equipment to be declared inoperable immediately. The change to the requirements of CTS 3.9.8.7 (allowing 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to restore the AC power distribution subsystem) is addressed in Discussion of Change L, for ITS 3.8.7. -

ITS 3.83 m.

CTS p. 218h, 4.9.A.I.4.), R,: Relocation of tank cleaning requirements is being reviewed by the NRC staff. However, additional justification for relocation of the requirement is needed Please provide additional justification.

-S-

I PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OlL TESTING 7

Resoonse SR 3.8.3.6 in NUREG 1433 is a preventive type of SR. Sediment in the tank, or faRure to perform this SR, does not necessarly result in an inoperable storage tank as stated in the Bases for SR 3.8.3.6. Preventive maintenance type SRs generally have been relocated from the Technical Specifications and allowed to be under utiky control. This SR is simuar to the DG inspection SR, which was aRowed to be relocated to plant controlled documents; they are both preventive maintenance type requirements.

l Performance of SR 3.8.3.3 (fuel oR testing) and the limits of the Diesel Fuel OR Testing Program help ensure tank sediment is minimized. Performance of SR 3.8.3.1 (fuel ol volume verification) once per 31 days ensures that any degradation of the tank wall surface that results in a fuel oR volume reduction is detected and corrected in a timely manner. In addition, another govemment agency provides regulations for the maintenance of below ground fuel oR tanks. As a result, adequate controls exist to allow relocation of this requirement to plant controlled documents, in addition, this change wRI also be pursued as a generic change to the STS NUREGS.

ITS 3.8.4 n.

CTS p. 218),4.9.A.2.c R,: CTS requirements include determining and logging the specific gravity and voltage of each col following a discharge. An adequate Justification has not been provided for why these requirements can be relocated. Please provide additional justification.

Response

The requirements to determine and log the specific gravky and voltage of each call after the service test and after the discharge test are not necessary to ensure the OPERABlu1Y of the batteries. To ensure the acceptance criteria of SR 3.8.4.7 (Battery Service Test) and SR 3.8.4.8 (Battery Performance Test) are satisfied, col voltages must be determined in accordance with IEEE-450. In addition, to declare the batteries OPERABLE after the service test or the performance test, the acceptance criteria of Table 3.8.61 must be satisfied which requires specific gravity and cell voltages to be determined.

o.

CTS p. 218] 4.9.A.3.a: This CTS requirement appears to have been included as a Survellance Requirement (SR) in ITS LCO 3.5.1. LCO 3.5.1 does not address OPERABlUTY of power supplies nor does it contain a Condition and Required Actions for an inoperable power supply. Consequently, ITS LCO 3.5.1 contains an SR that has no direct tie to the LCO. Provide an explanation of what actions would be taken upon faRure of this SR in LCO 3.5.1.

Response

The requirements of the LPCI swing bus (CTS 4.9.A.3.a) have been moved to SR 3.5.1.6 of Specification 3.5.1 (ECCS-Operating). The function of this feature is simRar to that of the LPCI inverters in SR 3.5.1.5 of NUREG.1433 and has been treated in the same manner. The Bases for SR 3.5.1.6 state the following:

1 1

1 I

i PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 -

)

IMPROVED TECHNICAL SPECIRCATIONS, SECTION 3.8 J

C EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING i

i The ablity to provide power to the LPCI inboard injection valve and the recirculation l

pump discharDe valve from either 4 kV emergency bus associated with one LPCI subsystem ensures that a single fature of a DG wIl not result in the failure of both LPCI pumps in one subsystem. Therefore, falure of the automatic transfer capabity wNl result in the inoperabulty of the affected LPCI subsystem.

p.

CTS p. 220s,3.9.B.5: DOC L, is inconsistent with the ITS 3.8.4 Bases. The DOC addresses DC DMSiONAL inoperabulty wh5e the ITS Bases refer to DC SUSSYSTEMS (i.e. single battery, single charger, etc.) inoperabuity. Provide an explanation of or i

reconclie this inconsistency.

{

Response

At PBAPS, there are two independent divisions per unit, designated DMalon I and i

DMalon 11. Each division consists of two 125 VDC batteries. The two 125 VDC batteries in each division are connected in series Each 125 VDC battery has two chargers (one l

normally inservice charger and one spare charger) that are exclusively associated with that battery and cannot be interconnected with any other 125 VDC battery. As described in the LCO Section of the Bases for Specification 3.8.4, ench division has been defined as a subsystem with each DC subsystem consisting of two 125 V station batteries in series, two battery chargers (one por battery), cnd the corresponding control equipment and interconnecting cabling supplying power to the associated bus.

Therefore, no inconsistency is considered to exist between Discussion of Change L, for ITS 3.8.4 and the Bases for Specification 3.8.4.

j q.

CTS p. 220s, 3.5.B.5: Additional justification is needed in DOC R, for the relocation of l

this item. The Safety Function Determination Program (SFDP) is only involved when two or more LCOs are not satisfied. The CTS requires action if only 3.9.B.5 is not satisfied and would require additional action if 3.5.F and 3.9.B.3 were not satisfied. The SFDP.

requires an evaluation but would only require a shutdown if the LCO for the affected systems / components required the same for a loss of function condition. Provide additional discussion and justification for this relocation.

Response

The Safety Function Determination Program in Specification 5.5.11 (as modified by BWR-25, C3) states that upon entry into LCO 3.0.6, an evaluation shall be made to determine if a loss of safety function exists. LCO 3.0.6 is entered mch time a support i

system LCO is not met and only the Conditions and Required Actons of the support system are entered. As a result, any time a support system is inoperable, and supported system ACTIONS are not ettered, LCO 3.0.6 will be entered. When subsequent inoperab81 ties occur, safety function determinations wRl be performed i

CTS 3.5.F contains the requirements for low pressure ECCS during the Cold Condition (reactor coolant temperature 1212 F). For the DC Sources, the CTS Applicability for l

CTS 3.9.4 and actions of CTS 3.9.B.5 is whenever the reactor is critical. In accordance with CTS 3.0.A (which states Limiting Conditions for Operation and action requirements are applicable during the operational conditions or other states specified for each j

specification), the requirements of CTS 3.5.F are not applicable when the reactor is critical and the actions of CTS 3.9.b5 would not be applicable in the Cold Condition.

i 1 1

L 0

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING

)

CTS 3.9.B.3 allows one DG to be inoperable for a limited period of time. Therefore, the restriction of CTS 3.9.B.5 with regard to CTS 3.9.B.3 being satisfied is considered to allow one battery to be inoperable for three days provided only one DG is inoperable in accordance with CTS 3.9.B.3. CTS would require a shutdown if this was not satisfied (more than one DG inoperable). In the ITS, an Allowed Outage Time is justified in Discussion of Change L, for ITS 3.8.1 for the Condition of two or more DGs inoperable.

As a result, an immediate shutdown would not be required in ITS if two or more DGs are i

inoperable. If one DG is inoperable and a battery supporting the OPERABILITY of a second DG were to become Inoperable, then the provisions of Safety Function Determination Program would require the Condition of two or more DGs inoperable to be entered and the Required Actions taken.

ITS 3.8.7 r.

CTS p. 220b, 3.9.B.7: DOC M, includes a reference to a description in the ITS of the Unit 3 AC and DC power sources required to be OPERABLE to support continued Unit 2 OPERABILITY. Neither the ITS LCO 3.8.7 nor the Bases contain any description of the Unit 3 AC and DC power sources. Coordinate the justification with the ITS whRe taking into account the additional NRC staff comments on ITS LCO 3.8.7.

Respgnjig LCO 3.8.7.b. specifies that opposite unit requirements are those associated with the AC and DC electrical power distribution subsystems required to support the equipment required to be OPERABLE by the listed LCOs, rather than IIsting general opposite unit bus requirements (i.e., opposite unit DMsion I and il electrical power distribution subsystems.) This listing provides more detal regarding the opposite unit requirements than the current licensing bases. This approach allows PBAPS to maintain flexiblity for performing bus work during an opposite unit outage since bus requirements for the opposite unit can change with the MODE of the opposite unit and with which opposite unit component is being credited as satisfying the requirements for the subject unit.

Specifying the opposite unit requirements by LCO allows PBAPS the maximum flexibuity while still ensurin the opposite unit components required by the subject unit are maintained OPERABLE.

A-3 The following clarification is requested in suppoet of documentation for changes from NUREG-1433:

ITS 3.8.1 a.

Required Action A.2 Completion Time (CT): Current wording could be interpreted to mean the action is not required if more than one 4 kV emergency bus has no offsite power (see Condition D). Altemate wording could be "one or more 4 kV emergency i

buses' or 'no offsite power to any 4kV emergency bus." Revise wording or explain why current wording is appropriate and why it will not be misinterpreted.

.BesDonse The wording of the Completion Time of Required Action A.2 is consistent with NUREG-1433 except that the reference to *dMsion" has been replaced with '4 kV emergency bus". l

E

+

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING b.

Required Action A.3 CT: ' Fourteen days for second Completion Time does nu appear to be acceptable. NUREG-1433 is based on the Completion Time for an inoperable offsite circt4 (72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ) plus an addklonel 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , not an additional 7 days. The fact that the second Completion Time is twice the first Completion Time is a coincidence, not -

a criteria for establishing the second Completion Time (i.e., CT + 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , NOT 2 x CT).

Response

The maximum Completion Time for Required Action A.3 was derived from adding together the 7 day Completion Time for an inoperable offsite circut and the 7 day Completion Time for an inoperable DG, wkhout the Conowingo Line. This is consistent wkh the derivation of the maximum Completion Times in Example 1.3-3 of NUREG-1433 and the maximum Completion Times for Specification 3.1.7 of NUREG-1433.

c.

Required Action C.2: Is " Restore all but one" based on including al breakers as part of the offshe source?

Response

The wording in Required Action C.k, " Restore all but one" is based on the fact that feeder breakers are part of the offsite sources.

d.

SR 3.8.1.2 and SR 3.8.1.3, Frequencies, and Table 3.8.1-1: DOC P21 should be revised to identify the location of the commitment to the maintenance program described in GL 94-01. See A4.b above.

Response

PECO Energy has in place a program that monitors reliabuity of the EDGs. This program satisfies the requirements of GL 94 01, and as discussed in Regulatory Guide 1.160, is consistent with the provisions of 10 CFR 50.65 " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." This program is based on commitments made in response to Station Blackout, (Letter from G. A. Hunger, Jr., to US NRC, AprR 24,1991) and addresses EDGs only. PECO Energy has also developed a separate plan to implement 10 CFR 50.65 for plant equipment covered t;y the maintenance rule, in accordance with the schedule promulgated by 10 CFR 50.56.

EDGs are included in this plan; however, the plan has not been fully developed. It is expected that EDG avaRability will be monitored by the Summer of 1995, and that a modified INPO EDG performance indicator wul be used to monkor EDG avagabRity performance. For more detals on this program please refer to our response to A-1, 3.8.1 R.

i e.

SR 3.8.1.9, Note 2: This note is acceptable if the single largest load is the same for both units or the single largest load associated with either unit is used to satisfy the requirements for both units. Perhaps the SR needs some modification; e.g., "...its associated single largest post-accident load for either unit...* Please provide a discussion of your view of whetter the SR needs modification..

1 j

F PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3

)

i IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING

Response

The largest single load on the DGs at PBAPS is an RHR pump. Due to the possiblity of an RHR pump pumping into a break or two RHR pumps pumping into an intact line, load requirements can vary. The value of 1804 kW (nominal 2000 bhp) is the maximum value used in the DG load tabulations and is the same for both units as documented in PECO Energy calculations. Since the DGs are common to both units, the determination of what constitutes the single largest load on a DG must consider aN the loads on the p

DG not just those loads associated with a particular unit. As a result, it is not considered necessary to modify the SR.

f.

SR 3.4.1.14, Note 2: Provide documentation to support justification for this proposed deviation f:om NUREG-1433.

Response

Note 2 for SR 3.8.1.14 represents a deviation from NUREG-1433. This note allows relief from maintaining the power factor within limits during the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months run of DGs as required by SR 3.8.1.14 when grid conditions do not perinit. When this SR is performed the DG wNl be started in the %st mode", meaning in the event of a LOCA event or a Loss of Offsite Power, the CG would auto swap back to the ' emergency" mode. As part of the in!tial test setup, the applicable startup source (the one feeding the 4 kV emergency bus to be paralleled witn the DG) tap changer is placed in "OFF" (from

" AUTO") so it wul not " fight' the DG voltage regulator. Because the startup source tap j

changer is in "OFF,' voltage downstream of the startup source transformer varies as grid voltage varies, this includes the 4 kV emergency bus that is being paralleled by offsite power and the DG. This ultimately affects the power factor of the DG causing it to occasionally fan outside the limit specified in SR 3.8.1.14. While the power factor can be brought back within limits or maintained close to the limit under these conditions by manually adjusting the voltage regulator, an operator would have to be dedicated 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months watching VARS and load (KW).' This stNI would not guarantee the power factor i

would be maintained within limits.

Additional information requested by the NRC to support Note 2 for PBAPS included normal grid voltage (233 KV to 236 KV), the voltage drop between the 4 kV emergency buses and the input to the emergency transformers (approximately 8.4 kV; nominal voltage into the transformer is 13.8 kV and nominal 4 kV emergency bus voltage is 4.38 kV) and emergency transformer impedance (4.7% at 10713 KVA). An additional request by the NRC was for the additional amount of DG excitation needed to obtain the correct power factor. This would vary depending on the amount of change in grid voltage and the voPtage the DG had to initially achieve when parabeling to the bus and the remaining amount of room left to adjust the voltage regulator. In some cases at PBAPS, the amount of excitation needed could net be achieved, simply because the voltage regulator could not be adjusted any higher to maintain the power factor within limits.

g.

SR 3.8.1.17, Note: Provide additional information regarding the design of the control system to accomplish test mode override with one test for both units. _ _. _ _ _ _ _ _ _ _ _

y PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING Respones l

The modification to the control system'is designed so the test mode override can be accomplished with one test for both units. The EDG are common to both units, and the l

modified control system will be the same for each EDG; therefore, a test signal from i

either unk wIl verify the entire control logic for a EDG.

t h.

SR 3.8.1.21: Please verify that the following staff interpretation d this SR is correct.

When Unit 3 is in Mode 1,2, or 3, the following SRs must be performed on Unit 3 AC sources required to support Unit 2 OPERABluTY: 3.8.1.1 - 3.8.1.7. 3.8.1.9 - 3.8.1.11, 3.8.1.14 - 3.8.1.18, and 3.8.1.20. SRs not required to be performed are 3.8.1.1,3.8.1.12, 4

3.8.1.13,3.8.1.17,3.8.1.18, and 3.8.1.19. When Unk 3 is in MODES 4 or 5, or when moving irradiated fuel, only the following SRs need to be performed on Unit 3 AC sources required for Unit 2 OPERABluTY: 3.8.1.2,3.8.l.4 - 3.8.1.8, and 3.8.1.20.

Response

The correct interpretation of SR 3.8.1.21 is as follows:

When Unit 3 is in MODE 1,2, or 3, the following SRs must be.mg on Unit 3 AC Sources required to support Unit 2 OPERABluTY: 3.8.1.1 - 3.8.1.7, 3.8.1.9 - 3.8.1.11,3.8.1.14 -

(

3.8.1.18, and 3.8.1.20. SRs not required to be met are 3.8.1.8 (when only one Unit 3 offsite circuit is required), 3.8.1.12, 3.8.1.13, 3.8.1.17, 3.8.1.18, and 3.8.1.19. When Unit 3 is in MODE 4 or 5, or when moving irradiated fuel, only the following SRs nood to be i

performed on Unit 3 AC Sources required for Unit 2 OPERABluTY: 3.8.1.1,3.8.1.2, 3.8.1.4 - 3.8.1.8 (when more than one Unit 3 offsite circuit is required), and 3.8.1.20.

ITS 3 82 l.

LCO 3.8.2.d: It appears that at least two and possibly three Unit 3 distribution subsystems may be required to support Unit 2 in shutdown. LCO 3.8.2.d appears to be worded incorrectly since it uses the singular when the Unit 2 requirements may be multiple. This may not be a problem if Unit 3 is at power. Explain why this requirement is worded in the singular.

t Resoonse Currently, LCO 3.8.2 in NUREG 1433 does not require the required distribution l

subsystems to be capable of being powered from both a quellfied offsite circuit and a DG (i.e., one required distribution subsystem capable of being powered from an offsite circuit and another required distribution capable of being powered from a DG is j

allowed). As a result, PBAPS LCO 3.8.2.d is worded in the singular consistent with this allowance of NUREG-1433. However, when the opposite unit is at power this allowance could not be utlized due to the opposite unit's LCO 3.8.1 requirements.

r J.

LCO 3.8.2.c and 3.8.2.d: Has PBAPS prepared any type of matrix to show what Unit 3 equipment wRl be required by Unit 2 during Unit 3 shutdown?

i

}

m. _

J PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 lMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING Resoonse

]

PBAPS wil be developing a listing /rnatrix of the oppoelte equipment required by the i

subject unit when the subject unit is shutdown This is estimated to be completed prior 4

to implementation of the ITS at PBAPS.

k.

Condition C: This proposed Condklon does not appear to agree with LCO 3.8.2.d. The LCO requires one DG, while this Condition addresses inoperabulty of multiple DGs. This.

.[

is confusing See item A-3.1 above.

Reaoonse

_i Condition C is addressing both the requirements LCO 3.8.2.b and LCO 3.8.2.d. Since LCO 3.8.2 requires more than one DG to be OPERABLE, Condition C has been written i

to address multiple DG inoperabuities.

t ITS 3.8.3 1.

Condition E: Please add a discussion to DOC B,, to address how the value of 150 pelg I

was derived

Response

Existing Specification 4.9.A.1.2.a.6 requires that a DG be declared inoperable whenever its air receiver capacity falls below 225 poig, the pressure sufficient for five successive l

DG start attempts. Proposed Specification 3.8.3, in SR 3.8.3.4, also requires that each DG's air receiver pressure be maintained greater than 225 poig, however, Condition E allows 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to re-establish the pressure necessary for five successive DG start l

attempts if accumulator capacity remains sufficient for one start attempt (> 150 poig).

I The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months period allowed to complete restoration to the required pressure prior to declaring the DG inoperable is acceptable because: the remaining air start capacity is sufficient for one start attempt (consistent with safety analysis assumptions); the fact that most DG starts are accomplished on the first attempt; and, the low probablity of an i

event during this brief period The value of 150 psig for one fast start was derived from i

a test conducted at PBAPS on 12/29/92. This change is consistent with BWR Standard Technical Specifications, NUREG-1433.

ITS 3.8 4 m.

Condition A, Required Action Note: What is the intent of this Note? How can performance of SR 3.8.4.7 or SR 3.8.4.8 on Unit 3 batteries 3C or 3D cause a Unit 2 4 kV bus (E32 or E42) to become de-energized? Does this cause control voltage to go too low, thereby causing breakers to open? Are breakers E332, E232, E342, and E242 affected? Are the entire Unit 3, Division I and Division ll DC systems required for Unit 2 or only batteries 3C and 3D? If a Unit 3 DC bus becomes de-energized, what Unit TS are you in? This question is not clearly explained in LCO 3.8.7. It would appear that l

Unit 2 could be shut down as a consequence of a falure to complete an action in Unit 3 (LCO 3.8.7, Required Action B.1 and Required Actions E.1 and E.2).

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 -

)

EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING j

4 i

i

Response

The Note to Condition A was added to ensure that the appropriate actions are taken in the highly unlikely event that performance of a battery service or performance diecharge test on the opposite unit results in de-energization of a 4 kV emergency bus on the subject unt. This Note was added since the opposke unit batteries also cupply control power to the subject unit 4 kV emergency bus feeder breakers (for example, Unit 3 battery 3C provides control power to breakers E332 and E232 and Unit 3 battery 3D provides control power to breakers E342 and E242), if control power voltage were to g3 too low, the potential exists for the associated breakers to open.

t As stated in the Bases for Unit 2 LCO 3.8.4, a Unk 3 DC electrical power subsystem OPERABluTY requirements are the same as those required for a Unit 2 DC electrical power subrystem, except that the Unit 3: 1) DMsion i DC electrical power subsystem is allowed to consist of only the 125 V battery C, an associated battery charger, and the t

corresponding control equipment and interconnecting cabling supplying 125 V power to the associated bus; and 2) DMalon ll DC electrical power subsystem is allowed to l

consist of only the 125 V battery D, an associated battery charger, and the corresponding control equipment and interconnecting cabling supplying 125 V power to the associated bus. This exception is allowed only if all 250 VDC loads are removed from the associated bus. If the 250 VDC loads are not removed from the associated bus, then the entire opposite unit Division I and ll DC subsystems are required to be OPERABLE. Similar allowances exist in the Bases for Unit 3 LCO 3.8.4 except the t

applicable batteries are Unit 2 batteries 2A and 28.

As described in the Note to Required Action A.1, if a Unit 3 DC bus becomes de-energized during the performance d SR 3.8.4.7 or SR 3.8.4.8, then applicable Condition i

and Required Actions of LCO 3.8.7 must be entered. The applicable Condition of LCO 3.8.7 is Condition C which requires restoration of the DC bus within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The subject unit could be required to shutdown as a consequence of an inoperability of l

an opposite unit component / subsystem required to support the subject unit. However, the Required Actions and associated Completion Times (including any required shutdown actions) for the opposite unit components / subsystems required by the -

subject unit are all contained within the subject unit's Technical Specifications.

n.

Condition E: For this Condition, do you consider both Unit 3 and Unit 2 DC subsystem, or only Unit 2 DC subsystems? It appears, based on LCO wording and Condition wording, that this covers Unit 2 and Unit 3 and combinations of subsystems.

l Please clarify the intent.

Resoonan Condition E of LCO 3.8.4 applies to both the subject unit DC subsystems and the opposite unit DC subsystems required to support the subject unit since the subject unit LCO addresses both units DC subsystems.

o.

SR 3.8.4.8: Verify that only the spare battery chargers can be loaded to 200 amps and j

that OPERABLE battery chargers cannot.

i.

l PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPEOFICATIONS, SECTION 3.8

.j EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OlL TESTING.

Response

After the battery service or performance discharge test, the OPERABLE battery chargers can be loaded to 200 amps whle recharging the battery. However, in accordance wth the Notes to SR 3.8.4.7 and SR 3.8.4.8, these tests are not allowed to be performed when the subject unk is in MODE 1,2 or 3. The battery charger surveillance procedure -

to satisfy the requirements of SR 3.8.4.8 is currently being written to assure that the 3

spare charger is not connected to the battery during the test. The procedure change process and the requirements of to CFR 50.50 are adequate to ensure the test is only_

'l performed under appropriate condklons. This test represents a new requirement for PBAPS and the absence of the Note (which restricts the performance of the test to when i

the subject unt is not in MODE 1,2, or 3) is consistent with the current licensing basis.

i ITS 3.8.7 p.

Condition A: Note in Required Actions addresses de-energiration of a Unit 3 battery charger while Condition A addresses inoperable Unit 3 AC power distribution subsystems. What is the correlation between these terms?

Resoonse As described in the LCO section of the Bases for Specification 3.8.7, an AC distribution subsystem is required to be energized to ks proper voltage to be considered -

OPERABLE. For a battery charger to be OPERABLE It must be capable of recharging -

the battery in accordance with design / analysis acceptance criteria. This requires the i

battery charger to be energized. The wording "de4nergization of a required Unk(2)/(3) battery charger" rather than "inoperabHRy of a required Unit (2)/(3) battery charger" was selected for clarity.

i q.

Condition A: Unit 3 AC power also supports battery chargers required by LCO 3.8.4.

The Note in the Required Actions directs operators to enter the applicable Conditions and Required Actions of LCO 3.8.4 if a battery charger in Unit 3 becomes inoperable.

Do you intend for the operators to enter this Unit 3 TS in this situation? The staff does not believe this is appropriate. The TS for each unit should stand on their own. Please i

provide an explanation of the intent of this Note.

Response

The Note to Required Action A.1 of Unit 2 Specification 3.8.7 directs operators to enter applicable Conditions and Required Actions of LCO 3.8.4 If a reouired Unit 3 battery charger becomes de. energized. The word " required" is referring to an opposite unit -

battery charger that is required to support the subject unit. In this particular case, the opposite unit's battery charger supports the OPERABluTY of the subject unit's AC Sources. As a result, the subject unit's Conditions and Required Actions of LCO 3.8.4 must be entered.

r.

Required Action A.1 CT: What is the basis for the 7 day Compleion Time? Unit 3 AC provides power to cooling towers and motor operated valves (MOVs) required by Unit 2 to cope with the loss of river water event. The probabilty of this event should drive the Completion Time for this system inoperability.

] i j

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING

Response

The 7 day Completion Time for the opposite unit's AC distribution subsystem required by the subject unit is based on the shortest Completion Time allowed for systems affected by the inoperable AC distribution subsystem.

With regard to the Unit 3 AC distribution subsystem providing power to the emergency cooling towers and the MOVs required by Unit 2 to cope with the loss of river water -

event, the Completion Time for this system inoperablity was derived from the current licensing basis. The current Technical SpecNications allow tho Emergency Heat Sink FacIky (which includes the emergency cooling towers and HOVs) to be inoperable for a period of 7 days.

s.

Condition B: The staff does not agree with the Condition, Required Actions, or CT. If the appropriate Unit 3 DC subsystems are inoperable, the DG and the safety systems / components associated with that DC subsystem for BOTH UNITS are inoperable. As a minimum, this Condition should include a Required Action to verify OPERABILITY of redundant safety systems / components as is required when a DG is inoperable. The 12-hour Completion Time is also questionable. It is not clear why, if at all, the impact of a DC subsystem inoperabuky is any different on the opposite unit than it is on the subject unit. Please provide the additional justification for these items.

Response

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time for the opposite unit's DC distribution subsystem required by the subject unit is based on the Oompletion Time for an opposite unit's DC electrical power subsystem required by the subject unit. The basis for the CrWation Time for the opposke unit's DC electrical power subsystem required by the suect unit is as follows:

The loss of the opposite unit's DC electrical power subsystem results in inoperabilities simuar to that which would result from the loss of one DG and one offsite source in the STS. Therefore, a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time for an inoperable opposite unit's DC electrical power subsystem has been provided consistent with the Completion Time in NUREG 1433 Specification 3.8.1, 'AC Sources-Operating," for one DG and one offsite circuit inoperable. In addition, the current licensing basis as described in Technical SpecNications (3.9.B.5) provides a 3 day AOT for the loss of an opposite unit's DC electrical power subsystem.

The Safety Function Determination Program in Specification 5.5.11 (as modified by BWR-25, C3) states that upon entry into LCO 3.0.6, an evaluation shall be made io determine if a loss of safety function exists. LCO 3.0.6 is entered each time a support system LCO is not met and only the Conditions and Required Actions of the support system are entered. As a result, any time a support system is inoperable, and supported system ACTIONS are not entered, LCO 3.0.6 wul be entered. When subsequent inoperabuities occur, safety function determinations wRI be performed. As a result, any time an opposite unit's DC distribution subsystem required by the subject unk is inoperable, and only Required Action B.1 of SpecFication 3.8.7 is entered (i.e., LCO 3.0.6 is entered), a safety function determination must be performed This determination verifies the OPERABluTY of the redundant systems / components as is required when a DG is inoperable. As a result, an explicit Required Action to perform this evaluation in Condition B of Specification 3.8.7 is not required. The subject unit DC subsystems e

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING support the OPERABILITY of two DGs, two 4 kV emergency buses and associated -

safety system pump and load center breakers, ECCS and RCIC initiation instrumentation, accident monitoring instrumentation, remote shutdown system instrumentation, RPS electric power monitoring assemblies, ADS, HPCI, RCIC, and some i

PCIVs. The opposite unit DC subsystems required by the subject unit support the l

OPERABILITY of two DGs, two 4 kV emergency buses and associated safety system l

pump and load center breakers.

A-4 The following clarification is requested in support of documentation for the ITS Bases:

ITS B 3.8.1 a.

ITS p. B 3.8-4 & Insert B 3.8-4, #1: The above insert refers to "three" Unit 2 4 kV emergency busses, but there are four such busses is this an error in the insert?

In the last paragraph on this page there is a statement that e n offsite circuit must be connected to at least three busses to support OPERABlUTY of that circuit. Please provide an explanation for this requirement.

Response

i The OPERABluTY of the AC electrical power sources includes maintaining the onsite or offsite AC sources OPERABLE during accident conditions in the event of: 1) An assumed loss of all offsite power or all onsite AC power; and 2) a worst case single failure.

r As a result, if one offsite circuit is supplying or capable of supplying (due to auto transfer capability) at least three 4 kV emergency buses and the other offsite circuit is supplying or is capable of supplying at least three 4 kV emergency buses and the three buses being powered or are capable of being powered by the two offsite circuits are not i

all the same, then under accident conditions with an assumed loss of all onsite power and the worst case single failure, offsite power would still be maintained to three buses (only three of the four buses are required to mitigate the design basis accident).

The wording in the Bases is correct. However, it will be clarified to identify that if at least one of the two offsite circuits does not provide power to all four 4 kV emergency l

buses, then the three buses that each offsite circuit powers, or are capable of powering, I

can not all be the same.

b.

ITS p. B 3.8 5: The Bases section for Required Action A.2 aopears incorrect. Required Action A.2 applies when one or more 4 kV busses cannot be powered from offsite.

Provide a correction or an explanation why one is not needed.

The Bases section for Required Action A.2 is not entirely clear. It is difficult to establish the relationship of the 4 kV emergency busses to each other from the discussion The NRC staff suggests that you consider using a matrix to support the 3.8.1 Bases.

Discuss if PECO Energy will consider the use of a matrix in the Bases?

y PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING

Response

4 Required Action A.2 and the associated Bases were written to be consistent with the phBosophy and wording of NUREG-1433. No plant specific changes were deemed to be necessary. In addition, since multiple entries into Condition A would be required for subsequent offsite circuit inoperabilities, as well as entry into Condition C, Required Action A.2 would be required to be applied to the associated 4 IN bus affected by the subsequent offsite circuit inoperablity.

PBAPS currently uses a listing in a procedure to implement simuar requirements in accordance with CTS 3.0.D. No other matrices are deemed necessary to implement these requirements. After ITS implementation. the Bases wir be revised to refer to procedures used to implement these requirements.

c.

ITS p. B 3.8-6: The NRC staff requires additional information regarding the PBAPS design relative to the safety related systems / components required to mitigate the consequences of the design basis accidents and transients (e.g., ECCS, ESW, RHR).

.This information may be presented to the NRC staff at the next meeting on Section 3.8, i

rather than included in a response to this request.

Response

i PECO Energy presented additional information relative to the systems / components required to mitigate the consequences of design basis accidents and transients (e.g.,

ECCS, ESW, RHR) at the AprH 19.1996 meeting with the NRC on Section 3.8.

-i d.

ITS p. B 3.8-8: The comment under A-4.b above regarding the use of a matrix to clarify

.I the Bases discussion for Action A.2 is also applicable here but oriented to the DGs.

?

Response

F PBAPS currently uses a listing in a procedure to implement simRar requirements in accordance with CTS 3.0.D. No other matrices are deemed necessary to implement these requirements. After ITS implementation, the Bases wiu be revised to refer to procedures used to implement these requirements e.

ITS p. B 3.8-11: The Bases section for Required Actions C.1 and C.2 could also benefit from the use of a matrix to more clearly illustrate what redundant features are and what the relationships are. See item A-4.b above.

4

Response

i PBAPS currently uses a listing in a procedure to implement simaar requirements in accordance with CTS 3.0.D. No other matrices are deemed necessary to implement these requirements. After ITS implementation, the Bases wg1 be revised to refer to 1

procedures used to implement these requirements.

1 f.

ITS p. B 3.8-16, SR 3.8.1.7: The Bases for this SR are not consistent with the wording of the SR in the LCO. There is no discussion of reaching minimum voltage and 4

frequency within 10 seconds followed by steady state operation. Please correct the Bases. (Note: Any correction should reflect the generic resolution of this issue.)

i i ;

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING fiesoonse 1

The discussion regarding reaching minimum voltage and frequency within the required

{

time followed by steady state operation will be added to the Bases. This will be done in accordance with Generic Change WSTS-5 after the change is approved.

g.

ITS p. B 3.8-17, SR 3.8.1.3: This would be an appropriate place to add a discussion of DG test loading requirements versus post-accident loads, and why testing at the lower value is acceptable, as discussed at our a meeting on March 6,1995. Please provide such a discussion or an explanation of why such a discussion is not necessary.

Resoonse As discussed at the meeting on March 6,1995, the Bases will be revised to include a l

discussion of why testing at a lower value than the post-accident loads is acceptable.

This discussion will also be placed in the Bases for the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months DG run as well as any other SR discussion where the intent of the SR is to test at a load that envelopes the maximum post-accident load.

1 h.

ITS p. B 3.8-20, insert B 3.8-10, #2: The phrase 'or while solely supplying the bus' which follows *. paralleled to offsite power" does not appear to belong in the Insert.

Please delete the phrase or provide an explanation of why the phrase should remain.

Resoonse This change was made to achieve consistency with the changes approved in BWR-17, C2, Revision 1 and Revision 3.

l l

1.

ITS p. B 3.8-21, insert B 3.8-21: A single test for both units is acceptable provided the load used envelopes the single largest load for both units. The Bases are not clear on this point. Please clarify this point in the Bases or provide an explanation of why clarification is not needed.

Resoonse The largest single load on the DGs at PBAPS is an RHR pump. Due to the possibility of an RHR pump pumping into a break or two RHR pumps pumping into an intact line, load requirements can vary. The value of 1604 kW (nominal 2000 bhp) is the maximum value used in the DG load tabulations and is the same for both units as documented in i

PECO Energy calculations. Since the DGs are common to both units, the determination of what constkutes the single largest load on a DG must consider all the loads on the DG not just those loads associated with a particular unit. As a result, it is not considered necessary to modify the Bases for the SR.

l J.

ITS p. B 3.8-28, SR 3.8.1.15: This Bases section does not reflect the proposed changes to the SR volic,e and frequency acceptance criteria. The Bases should be revised accordingly. (Note: Any correction should reflect the generic resolution of this issue.) - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ __. _ _ _.

=

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 i

EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING

Response

The discussion regarding reaching minimum voltage and frequency wkhin the required time followed by steady state operation wlR be added to the Bases and submkted in Revision B to TSCR 93-16. This wNI be done in accordance wth Generic Change WSTS-5.

ITS B 342 k.

ITS p. B 3.5-37, last paragraph: Does the PBAPS design provide the capablity to cross-tie 4 kV emergency busses? The drawings provided to the staff do not Indicate such a capablity. Based on your response, the staff may request revisions to the Bases.

Response

PBAPS has the capabNity to cross-tie 4 kV emergency buses to support running required equipment during emergency situations. Specifically, during a Loss of Offsite Power event plant procedures direct an operator to backfeed the appropriate 4 kV buses as summarized below:

1.

Pull the appropriate undervoltage relay from the 4 kV breaker that wNl be i

supplying power to the Start-up Emergency bus that wNi be used for backfeeding.

2.

Open or verify open all 4kV bus feeder breakers which normally supply power to 4 kV buses from the offsite, including the breakers from the 4 kV bus that wNl be supplying power.

3.

Secure all large loads being supplied by the 4 kV bus that wHl be backfeeding the other 4 kV buses.

4.

Pull the appropriate control power fuses for pump breakers of the 4 kV bus that l

la supplying power and pull the appropriate control power fuses for loads that wk1 be supplied by the 4 kV buses that wNI be backfed.

5.

Energize the Start-up Emergency bus by closing the Breaker from the 4 kV emergency bus that WHi be supplying the power.

6.

Energize (backfed) the appropriate 4 kV bus by closing the breaker from the Start-up Emergency bus.

7.

Place in service the required loads that are needed to support current plant conditions.

j l.

ITS p. B 3.5-37, insert B 3.8-37, insert #3: What is meant by the phrase " Capable of connecting to its respective Unit 3 4 kV emergency bus?" Does this mean that the Unit 3 powered systems / components required by linit 2 technical specifications (TS) must have DG backup? __

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 I

EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING Resoonse The phrase " Capable of connecting to its respective Unit 3 4 kV emergency bus" means that the Unit 3 powered components required by Unit 2 LCO 3.8.2.d must have DG backup.

m.

ITS p. B 3.8-38, Actions A.1 and B.1: The staff does not understand what this section i

is supposed to address starting from " Required features remaining powered from a qualified offsite power circut, even if...* through the end of the section. Please provide l

additional explanation of this Bases section.

Resoonse The Bases for Required Actions A.1 and B.1 state " Required features remaining powered from a qualified offsite power circuit, even if that circuit is considered inoperable because it is not powering other required features, are not declared inoperable by this Required Action. If a single DG is credited with meeting both LCO 3.8.2.d and one of the DG requirements of LCO 3.8.2.b, then the required features remaining capable of being powered by the DG are not declared inoperable by this Required Action, even if l

the DG is considered inoperable because it is not capable of pc;.Ag other required features."

This section is explaining, for example, that if a feeder breaker from an offsite circuit or DG to a required 4 kV emergency bus is inoperable, then the applicable Conditions of Specification 3.8.2 are entered and Required Action A.1 or B.1 may be taken which require the affected features to be declared inoperable. However, in this example only the features powered from the 4 kV emergency bus with an inoperable breaker would be declared inoperable. Features powered from other required 4 kV emergency buses with OPERABLE feeder breakers from the same offsite circuit or DG would not be deciced i

inoperable per Required Action A.1 or B.1.

n.

ITS p. B 3.8-46, SR 3.4.3.3 P,: This proposed addition to the Bases is not acceptable because it takes exception to a TS requirement This is not the function of the Bases.

The generic resolution of this concem with dyed fuel is to invoke the ASTM standard for water and sediment by centrifuge in lieu of clear and bright. PBAPS can include this as a portion of the fuel oil program with an explanation in the Bases, but cannot make the option acceptable in the Bases alone.

Resoonse To address concems related to determining the presence of water and sediment in dyed DG fuel oil, the requirements of Specification 5.5.9, Diesel Fuel Oil Testing Program will be revised to allow the use of the ASTM water and sediment by centrifuge test in lieu of the clear and bright test. The Bases for SR 3.8.3.3 wBl also be revised to reflect the use of the ASTM water and sediment centrifuge test for dyed DG fuel oR.

o.

ITS p. B 3.8-47, SR 3.8.3.3, P,: The addition to the Bases is acceptable provided the same permissive is included in the appropriate part of TS 5.5.9. Without this (5.5.9), the proposed Bases addition would establish a permissive relative to a TS requirement.

Review TS 5.5.9 to ensure this portion of CTS is included, or make appropriate revisions. _.

y_

PEACH BOTTOM ATOMIC POWER STAllON, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING

Response

The PBAPS Diesel fuel oE testing program in spec 5.5.9.c does include the exception for the filter nominal pore size, consistent with the current licensing bases

)

ITS B 3.8.4 p.

ITS p. B 3.8-52, insert B 3.8-52: This insert is inconsistent other portions of the Bases.

For example, the Background section states that required battery chargers must be connected to their associated motor control centers (MCC) in order to be OPERABLE, but this insert appears to contradict that by stating a Unit 3 battery charger may be powered from Unit 2 and stil be considered OPERABLE. Please explain this apparent inconsistency. In addition, as a general comment, this insett comes very close to establishing requirements instead of explaining them and may have ' crossed the line."

Please review this Bases section to determine if some of these " requirements" would be l

more appropriately included in the LCO. Please provide an explanation of your conclusions in this re0ard.

Response

The Background section of the Bases in Insert B 3.8-50 is referring to the subject unit 4

battery chargers when the unit is in MODE 1,2, or 3. The Background section of the Bases also states to see the opposite unit's Bases for LCO 3.8.4 for a description of the

{

opposite unit's DC Sources. As a result, the opposite unit's battery charger may only be powered from the subject unit when the opposite unit is not in MODE 1,2, or 3.

Therefore, no inconsistency between the Bases insert B 3.8-50 and insert B 3.8-52 is q

considered to exist.

I J

With regard to Bases Insert B 3.8-52 establishing requirements that are more appropriate in the LCO, insert B 3.8-52 is describing what constitutes an OPERABLE opposite unit DC electrical power subsystem based on the opposite unit's MODE or condition. This is considered to be no different than the Bases descriptions of what constitutes OPERABLE low pressure subsystems in the Bases for Specification 3.5.1, ECCS-l Operating, and in the Bases for Specification 3.5.2, ECCS-Shutdown.

l q.

ITS p. B 3.8-51,2nd and 3rd paragraphs: There appears to be some inconsistency regarding the use of the terms " subsystems" and "dMsions

Please resolve this inconsistency.

Response

At PBAPS, there are two independent dMsions per unit, designated DMsion I and DMsion 11. Each dMalon consists of two 125 VDC betteries. The two 125 VDC batteries in each dMalon are connected in series. Each 125 VDC battery has two chargers (one normally inservice charger and one spare charger) that are exclusively associated with that battery and cannot be interconnected with any other 125 VDC battery. As described in the LCO Section of the Bases for Specification 3.8.4, each dMsion has been defined as a subsystem with each DC subsystem consisting of two 125 V station batteries in series, two battery chargers (one per battery), and the corresponding control equipment and interconnecting cabling supplying power to the associated bus.

Therefore, no inconsistency is considered to exist.

l 1 l l

~

s

"y

.l PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8

)

EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING r.

ITS p. B 3.8-53,3rd parayaph: The staff agrees with your deletion of the word-

' required." Regulatory Guides do not " require" anything However, neither do they

'specify" anything. Consider the use of another word, such as " stated."

Resoonae Regulatory Guides typically provide explicit detaus regarding the methods that are -

considered to be amtenhim by the NRC for achieving compliance wkh requirements.

As a result, the word "specified" was selected.

I s.

ITS p. B 3.8-53, insert B 3.843,1st paragraph: Is k the intent of this Note that the l

Required Actions and associated cts of the distribution system LCOs be followed ll power is lost to an AC or DC bus as a consequence of a Unit 3 DC subsystem

+

becoming inoperable? Consider the Required Actions and cts of LCO 3.8.7 wlN required shutdown long before 7 days. Please provide an explanation of the intent of i

this Note.

2nd paragraph: This Bases section is not clear that the subsequent postulated worst case single faRure would result in a Unit 2 loss of functiort Also, k should be clarified whether or not the postulated single faNure should occur in either Unit 2 or Unit 3, or i

only in Unit 2. Please clarify this section of the Bases or explain why clarification is not needed.

i

Response

The intent of the Note to Required Action A.1 is that the Required Actions and the associated Completion Times of the subject unit's LCO 3.8.7 be taken if a subject unit 4 kV emergency bus or required opposite unit DC bus is de-energized due to the l

performance of the battery service test or performance discharge on a required opposite unit's battery. It is understood that this could result in a required plant shutdown in less than the 7 day Completion Time of Specification 3.8.4, Required Action A.I. However, it is not expected that de-energization of a subject unit 4 kV emergency bus or required opposite unit DC bus wNI occur during the performance of these tests.

The Technical Specifications and the Bases for each unit have been written to stand on their own, to the extent practical. As a result, any reference to a loss of function is for l

the subject unit. The Bases section, with regard to a subsequent postulated worst case single faRure, is worded to be consistent with the wording of NUREG-1433. The LCO addresses both the subject unit DC electrical power subsystems and the opposite unit DC electrical power subsystems required by the subject unit. Therefore, the Bases is also addressing these subsystems and the postulated single faRure can not be limited to

'~

just the subject unit DC electrical power subsystems. As a result, no clarification is needed.

t.

ITS p. B 3.8-55, SR 3.8.4.3, insert 1: The staff agrees with the concept of this insert i

but questions whether this is appropriate material for the Bases. The SR is expressed in absolute terms; l.e., either there is damage or there is no damage. Per the SR, the absence of damage is the pass /faR criterion. This Bases section adds a new dimension that would appear to be better located in the body of the SR. Please relocate this 1

information to the SR or provide an explanation of why it is apgcg'.te to leave it in the Bases.,

y

e.

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING

Response

For consistency with the Bases for SR 3.8.4.3 in NUREG-1433, SR 3.8.4.3 will be revised to add "that could potentially degrade battery performance." This change wB also be pursued as a generic change to the STS NUREG.

u.

ITS p. B 3.8-56, SR 3.8.4.4: As a practical matter, some corrosion may be visible yet virtually impossible to remove without maidng the battery tests that the Bases include a discussion of acceptabilty; i.e., as long as connection resistance measurements are all right, some inaccessible yet visible corrosion is acceptable Please include such a discussion or explain why k is not needed.

Response

A discussion of inaccessible yet visible corrosion and the acceptabilky of its presence was not added since such a discussion was not in NUREG 1433, and PBAPS has, based on experience to date, no plant specific reason for adding such a discussion v.

ITS p. B 3.8-56, SR 3.8.4.6: This Bases discussion seems inappropriate, especially with respect to Frequency PBAPS has made a point of deleting MODE restrictions for this SR because there does not appear to be any unique plant conditions that must exist in order to perform this SR. The SR is performed on the charger that is credited as a spare. Consider developing another justification for the 24-month Frequency or provide an explanation of why the current justification is appropriate.

Response

t The Frequency discussion in the Bases for SR 3.8.4.6 wtl be revised to be more appropriate given the deletion of the MODE restrictions Noty w.

ITS p. B 3.8-87, insert 3.8.4.8.C: Please provide additional information, regarding " acid concentration in battery plates.' What is this? Are there any references on this subject that can be provided? Do the SR acceptance crkeria need to be changed to accommodate this concept? Copies of any technical documents addressing this subject i

would be helpful.

Response

An example of the effect of " acid concentration in plate material" on battery capacity can be seen during the first two years of battery service During this time period, battery capacity increases as the sponge lead of the battery absorbs the sulfuric acid allowing a greater volume of material for chemical reaction. PECO Energy presented additional information regarding the effect of " acid concentration in plate material" on battery capacity at the Aprt 19,1995, meeting with the NRC on Section 3.8.

ITS B. 3.8.5 x.

ITS p. B 3.8-60, insert B 3.5-40: See the comments regarding powering a Unit 3 battery charger from Unit 2 in A-4.r above..

- - +

~-

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 l

IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING 4-

Response

j i

See response to kom A-4.r above l

ITS B 3.8.7 y.

ITS p. B 3.8 78, (breakers and LCO 3.8.1): It is not clear what breakers are be%g discussed here (DG output breakers?). Also, the statement does not appear to be entirely correct. N a DG breaker is inoperable and there is a subsequent loss of offsite power to that associated bus, LCO 3.8.7 is invoked, not LCO 3.8.1. The staff agrees wkh the concept behind the changes to this Bases section but feels additional clarWication is needed Please provide clarification on this point.

j

Response

l The DG output breakers and the offsite circuit feeder breakers to the associated 4 kV i

emergency buses are being discussed at the end of the second paragraph in the l'

Background section of the Bases. As an example, N the output breaker is inoperable, the applicable Required Actions of LCO 3.8.1 must be taken. However, as described in the LCO section of the Bases for SpecNication 3.8.7, an AC distribution subsystem is

]

required to energized to its proper voltage to be considered OPERABLE. Therefore, N the associated bus becomes de-energized due to the inoperable DG output breaker, the applicable Required Actions of LCO 3.8.7 must also be taken. The entry into the applicable Required Actions of LCO 3.8.7 is due to the de-energization of the associated I

bus not the inoperability of the DG output breaker. This application is not considered to be ' cascading."

I z.

ITS p. B 3.6 79, insert LCO, PJ The staff has reviewed the proposed Unk 2 TS, but j

this insert directs the reader to the Unit 3 TS to determine what Unit 3 distribution i

subsystems must be OPERABLE to support continued operation of Unit 2. The staff j

does not believe this is appropriate. The TS for each unit should stand on their own.

l Please revise this Bases section or provide a justification for why the current Bases are i

appropriate, f

i

Response

For the opposke unit's AC and DC distribution subsystems required by the subject unit, l

the Bases clarWication was added to state that opposite unit distribution subsystems that may be required by the subject unit could be found in the opposite unit Bases. This approach was taken rather than listing each of the opposite unit's distribution subsystems since the required opposke unit's distribution subsystems can vary depending on which opposite unit component is being credited with meeting the requirements of the subject unit's Technical Specification. The option selected by the BWR/4 lead plant, which was to not state where the listing of the required opposite unit's distribution subsystem was located, was also considered. However, it was determined that this approach could lead to confusion regarding the voltage level of the required opposite unit's distribution subsystems which are addressed by LCO 3.8.7.b.

4...

! (m e ^

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING 1

I sa.

ITS p. B 3.8-79, LCO,2nd paragraph: This appears to be the first place in the TS or Bases where the PBAPS AC (4 W busses) are discussed in terms of divisional orientation. What busses make up Division I and Division ll? Is this consistent with the rest of the TS and Bases? This comment is generic to LCO 3.8.7 Bases.

Response

The footnote to Bases Table B 3.8.71 defines that each division of the AC and DC electrical power distribution systems is a subsystem. Bases Table B 3.8.7-1 also specifies the buses that make up DMelon I and DMelon ll. The use of the terms

" division" and " subsystem" when referring to electrical power distribution subsystems in the rest of the Technical Specifications and Bases is consistent with the information provided in Bases Table B 3.8.7-1. At PBAPS, subject unit AC electrical power distribution subsystem at the 4 W level is defined as 2 of the 4 emergency buses. The 8 l

hour completion time for restoring an inoperable AC electrical power distribution subsystem was selected by comparing the PBAPS design to the standard design for which the STS was developed. The standard design consists of 2 subsystems with only 1 emergency bus per subsystem at a voltage level equivalent to the PBAPS 4 W level.

For the standard design, the STS provides an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time for 1 inoperable AC electrical power distribution subsystem. At PBAPS, due to the additional diversity provided by the design, a similar level of degradation could only occur at the 4 W ievel if 2 of the 4 emergency buses were inoperable. As a result, the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months completion time for restoring a PBAPS subject unit AO electrical power distribution subsystem (2 of the 4 l

emergency buses at the 4 kV level) is equivalent to the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time for restoring an AC electrical power distribution subsystem (1 of 2 emergency buses at a level equivalent to 4 W) at unit with a standard design i

bb.

ITS p. B 3.8-79, insert LCO-2: This Bases change is not consistent with NUREG-1433 and is not acceptable. PBAPS appears to have combined part of the requirements in NUREG-1433 and part of the requirements from the CTS. Please provide additional i

justification for this deviation.

Response

The listing of the AC buses addressed by LCO 3.8.7 was developed to be consistent with the current licensing bases as defined in the CTS. Currently, when a bus that is not listed in existing Specification 3.9.A.3 becomes de-energized, the definition of OPERABILITY states components powered from the bus are inoperable and the applicable actions must be taken for the affected components.' As a result, this clarification was added to the ITS Bases to address the actions dat would be required if a bus not addressed by LCO 3.8.7 became de+nergized. The justification for not taking i

the applicable Required Actions for the components made Inoperable by a de-energized l

bus listed in ITS Bases Table B 3.8.7-1 is provided in Discussion of Change L, for ITS 3.8.7.

i cc.

See comments under item A-3.s.

Response

See response to item A-3.s. i

,u, y

I PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 IMPROVED TECHNICAL SPECIFICATIONS, SECTION 3.8 EXCEPTIONS TO ASTM STANDARDS REGARDING DIESEL FUEL OIL TESTING 4

ITS 5.5J i

dd.

Diesel Fuel Oil Testing Program: The staff has concluded that the proposed changes to NUREG 1433 are not acceptable. The staft's primary concems involve (1) the PBAPS wording to establish a program with " procedures based on applicable ASTM standards,"

(2) use of the same terminology in 5.1.2.15.c as t relates to deletion of ASTM 2276, and (3) the proposed ITS do not accurately rollect the CTS. In addklon, DOC P,, does not contain adequate justification for these changes.

Ploese revise Specification 5.5.9 rw orovide additional justification for the deviations from NUREG 1433.

Response

The proposed change: 'in accordance with procedures based on applicable ASTM

{

Standards," provides the capability for justified variances between the ASTM Standards and the implementing procedures. The problem wkh tte existing wording in NUREG-1433, "in accordance with applicable ASTM Standards," is that k invokes all the 1

requirements of the documents referenced by the ASTM Standards and requires verbatim compliance. The documents referenced by the ASTM Standards, as well as the ASTM Standards, do not address issues related to verbatim compliance very well.

As a result, while other approaches to meeting requiremen;s should be acceptable (such as using new glassware for determining kinematic viscoelty versus using glasswar6 that has been cleaned in chromic acid), they are not acceptable since the ASTM Standards and the associated referenced documents do not include these approaches. To address this concem, a letter to the NRC was submitted (TSCR 93-16, Supplement 7, l

May 24,1995) identifying the PBAPS exceptions to the applicable ASTM Standards regarding DG fuel oil testing to clarify what 'in accordance with applicable ASTM Standards' means. The wording in Specification 5.5.9 regarding " procedures based on applicable ASTM standards" will be revised as part of Revision B to reflect the wording of NUREG-1433.

j A revision to Specification 5.5.9, Diesel Fuel Oil Testing Program, was submitted as part of Revision A to update Specification 5.5.9 to accurately reflect the current Technical Specifications.

l A-5 Identify any differences between the Unit 2 ITS and the Unit 3 ITS for Section 3.8.

i Resoonse Differences between the PBAPS Unit 2 and Unit 3 ITS and Bases for Section 3.8 are identified in the marked up pages in Attachment A. -- --

.

ML20085D780

Text

Subject:

Reference:

Dear Sir:

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Response

Navigation menu

Search