ML20058D032
| ML20058D032 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/26/1990 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9011050277 | |
| Download: ML20058D032 (4) | |
Text
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PHILADELPHIA ELECTRIC COMPANY NUCLEAR GROUP HEADQUARTERS 955 65 CHESTERBROOK BLVD.
WAYNE, PA 19087 5691 (ats) s40 sooo October 26, 1990 Docket Nos. 50-277 50-278 U.S. Nuclear Regulatory Comtalssion Attn Document Control Desk L
Washington, DC 20555 I
SUBJECT:
Emergency Service Water Technical Specifications l
for Peach Bottom Atomic Power Station, Units 2 and 3 l
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REFERENCE:
Letter and request for additional information, i
G. Y. Suh (NRC) to G. A. Hunger, Jr. (PEco) l dated August 23, 1990 Dear Sir l-L The referenced letter requested additional information from Philadelphia Electric Company (PECo) regarding PECo's January 26, 1988 license amandment application.
The application proposed more restrictive.Tectnical Specifications (TS) limits on the Emergency l
Service Water (E0W) System.
These TS-limits also affect the Emergency Heat Sink (EHS) System (i.e., Emergency Cooling Water Pump, Emergency Cooling Tower Fans, and ESW Booster Pumps).
L
, PECo has recently altered its position on the capability of-
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the EHS system to serve as an equivalent to an ESW pump.
PECo's current position is not reflected by the information provided in the l
January.1988 license amendment application.- PECo also wants to propose'significantly different TOs for ESW and EHS.
Therefore, PECo hereby withdraws the January 26,'1988 application.
PECo will submit a new application by February 28, 1991.
1 Responses to each of the items in the NRC request for L'
-additional information are provided herein.
These items will be resolved by the new application, j
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'U.S. CuclOsr HIgulclory Commicolon October 26, 1990
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Emergency Service Water Page 2 Technical Specifications i
NRC ltem No. 3 The amendment application reflected the position that the emergency cooling water pump and associated equipment were equivalent-to an emergency service water pump.
Please provide a discussion of whether this is the current licensee position, given the concerns identified by an NRC SSPI for the closed cooling modes of the emergency service water system (as reported in Combined Inspection Report 50-277/90-200 and 50-278/90-200).
Hesponse to Item No. 1 On March 8, 1990 PEco established a formal position (Plant Operations Review Committee Position No. 33) that the Emergency Cooling Water (ECW) pump and associated equipment shall not be considered equivalent to an ESW pump for a Design Basis Accident.
Accordingly, PECo has imposed on itself allowable outage times that are more restrictive than those in the proposed TSs.
NHC Item No. 2
. Proposed TS 3.9.C.2 and TS 3.9.C.3 referred to the operability of the emergency cooling water pump.
If the reference was to a combinatlon of an operable emergency cooling water pump, one operable emergency service water booster pump, and two operable emergency cooling tower fans as implied in proposed TS 3.9.C.4, the proposed TSs need to be amended to provide clarification.
Response to item No. 2 Based on the position discussed in the. response to item No.
.CCo wil). propose that the requirements of the previously 1,
1 proposed TS 3.9 C.4 be relocated to TS 3.11.B, " Alternate Ileat Sink" j-(which is referred to as " Emergency Heat Sink" in the Section 10.24 of the Final Safety Analysis Report) with the necessary clarification.
PECo will also ensure that, if any references to Ells system components remain in the ESW section of the TSs, the l-
- references will be complete, clear and technically justified.
l NRC Item No. 3 Picaso provide justification for the proposed allowable cutage times for the emergency service water pumps which did not appear to be consistr,at with those specified in the standard technical specifications.
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iU.S. Cucloor R gulatory Commicalon Octobar 26, 1990 E'mergency Service Water Page 3 Technical Specifications Response to Item No. 3 Based on the position discussed in the response to item No.
1, PEco will propose different allowable outage times for ESW, with supporting justification.
NRC llem No. 4 Please provide the results of an evaluation of whether the enhanced surveillance testing outlined in an April 12, 1990 letter from D. M. Smith of Philadelphia Electric Company to the NRC, should be incorporated into the TS.
-Responne to Item No. 4 The enhanced surveillances to which PEco has committed are not included in NUREG 0123, Rev.
3, ' Standard Technical Cpecifications for General Electric dolling Water Reactors (HWR/S)"
or " Improved HWH Standard Technical Specifications" recently developed by the BWR Owners' Group.
The addition of such surveillances into TSs is also not recommended by NRC Generic Letter 89-13, " Service Water System Problems Affecting Safety-Related
. Equipment."
Therefore, PECo does not consider it appropriate to add these surveillances to the Peach Bottom TSs.
NRC Item No. S If it is determined that the emergency cooling water pump and associated equipment are not equivalent to an emergency service-water pump, please provide a discussion of whether the current and proposed TSo-for the emergency cooling water pump, emergency service water booster pumps, emergency cooling tower fans, and associated automatic valves should be moved to another TS section, such as 3/4.11.B for the alternate heat sink facility.
I Response to item No. 5 Based on the position discussed in the response to Item No.
1, PECo will propose that appropriate requirements be relocated to TS 3/4.11.B for the EHS system.
Since ESW and EHS are distinctly different systems, they should be addressed separately in the TSs.
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U.S..Cusicar R;gulctory Conniccion Octob3r 26, 1990 timergency Service Water Page 4 Technical Specifications t
If you have any questions or need additional information, please do not hesitate to contact us.
Very truly yours,
,h 7[61 G. A. Ilunger, Jr.
Manager-Licensing Nuclear Engineering & Services cc:
T. T. Martin, Administrator, Hegion I, USNRC J. J. Lyash, USNRC Senior Resident Inspector 4
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