ML19325D291
| ML19325D291 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/10/1989 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19325D292 | List: |
| References | |
| NUDOCS 8910230038 | |
| Download: ML19325D291 (7) | |
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10 CPR 50.90 g
f PHILADELPHIA ELECTRIC COMPANY NUCLEAR GROUP HEADQUARTERS l
f 955 65 CHESTERBROOK BLVD.
WAYNE. PA 19087 5691 l
tatslo40sooo l
October 10, 1989 Docket No. 50-353 l
License No. NPF-85 I
U.S. Nuclear Regulatory Commission
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Attn Document Control Desk I
Nashington, D.C.
20555
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Subject:
Limerick Generating Station, Unit 2 Technical Specifications Change Request Initial Visual Inspection.of Snubbers l
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Gentlemen:
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Philadelphia Electric Company (PBCo) hereby submits Technical l
Specifications Change Request No. 89-11, in accordance with 10 CPR
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50.90, requesting an amendment to the Technical Specifications (Appendix A) of the Limerick Generating Station (LGS), Unit 2 Operating License No. NPF-85.
Information supporting this change request is contained in Attachment 1 to this letter, and the proposed replacement page is contained in Attachment 2.
i This submittal requests a change to the Technical Specifications (TS) Surveillance Requirement, Section 4.7.4.b,." Plant Systems, Snubbers, Visual Inspections," which requires the first visual inspection of the snubbers to be conducted after four months of power operation.
The schedule for completing startup testing of LGS Unit 2 is such that the plant staff may be ready to begin snubber inspections i
within three months of commencing power operation.
However, the anubbers will have experienced sufficient variation in the modes of operation to fulfill the basis for the TS Surveillance Requirement i
c.nd, therefore, not constitute a significant hasards consideration.
Because this proposed change is schedular in nature, PECo requests that the amendment be issued on or before December 1, 1989.
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8910230038 891010 04 PDR ADOCK 05000353 i
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j U.S. Nu]1 car CegulctOry Cossaicolcn October 10, 1989 Document Cor, tral De:k P;ge 2 ef 2 l
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If you have any questions regarding this matter, please contact l
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l Very truly yours, I
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[s George A. Hunger: Jr.
Director Licensing Section i
Nuclear Support Division f
i Attachments
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t cc W. T. Russell, Administrator, Region I, USNRC f
T. J. Kenny, USNRC Senior Resident Inspector, 148 T. Gerusky, Director, PA Bureau of Radiological Protection I
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i TECHNICAL SPECIFICATIONS CHANGE REQUEST l
NO.
89-11 1
COMMONWEALTH OF PENNSYLVANIA :
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t COUNTY OF CHESTER D. R. Helwig, being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company; the Applicant herein; that he has read the foregoing Application for Amendment of Facility Operating Licenses to allow the first inservice inspection of each type of snubber to be performed after completing only three months of power operation, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
/
I Vice Presi n
Subscribed and sworn to beforemethis[fA--
day of M 1989.
LA E o'w<~ek 0
O' Notary Public NOTARIAL SEAL ANGELA O. oLENGNSKL Notary Publ4 MV 6'a
- n EA 31.1992
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i ATTACHMENT 1
i' LIMERICK GENERATING STATION UNIT 2
i DOCKET NO.
50-353 l
l LICENSE NO.
NPF-85 i
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i TECHNICAL SPECIFICATIONS CHANGE REQUEST NO.
89-11 e
Surveillance Requirement 4.7.4.b
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" Initial Visual Inspection of Snubbers" I
i Supporting information for Changes i
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1 Dockot No.
50-353 1
LicOn33 No. NPP-85 i
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REQUESTED CHANGE Philadelphia Electric Company (PECo), Licensee under Facility l
Operating License NPF-85 for Limerick Generating Station (LGS), Unit 3
2, hereby requests that the Technical Specifications (TS) contained in e
Appendix A to the Operating License be amended to revise the Plant l
Systems, Snubbers Surveillance Requirement to allow the first I
inservice visual inspection of each type of snubber to be performed j
after completing only three (3) months of POWER OPERATION.
The proposed change is indicated by vertical bars in the margin of page 3/4 7-11 as provided in Attachment 2.
The proposed revision is necessary due to the efficiency with which the initial startup testing program has been conducted, and as further discussed below, PEco requests that this amendment be issued t
i on or before December 1, 1989.
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DISCUSSION AND DESCRIPTION OF CHANGES
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The current TS Surveillance Requirement for visual inspections of snubbers requires "the first inservice visual inspection of each type l
of snubber shall be performed after 4 months but within 10 mouths of commencing POWER OPERATION and shall include all snubbers."
LGS Unit i
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2 received its full power operating license on August 25, 1989, and began POWER OPERATION, as defined by TS Definitions Table 1.2, on I
i September 1, 1989.
The first visual inspection of snubbers is therefore required to be performed between January 1, 1990 and July 1, 1990.
i The Startup Testing Program for LGS Unit 2 originally scheduled startup testing, other than the warranty run, to be completed after January 1, 1990, and the first snubber visual inspections to be completed subsequent to that testing and before the end of the ten month window.
The Startup Testing Program is currently proceeding at
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an pace which now projects a completion of the testing, other than the i
warranty run, during the first week in December, 1989.
This rapid completion of the testing program has also led PECo to re-evaluate the most efficient use of its resources to accomplish the necessary surveillances at LGS Unit 2.
This evaluation indicates that an outage immediately following completion of the testing, other than the warranty run, is the appropriate time to conduct the first visual inspection of the snubbers.
Since this outage could begin as earl the first week of December, 1989, a change to the TS is necessary.y ac The basis for requiring the initial visual inspection of snubbers after four months of commencing POWER OPERATION la to provide the I
anubbers a sufficient opportunity to experience various modes of operation (i.e., startups, shutdowns, transients, and steady-state).
Subjecting the snubbers to these various modes of operation establishes an operating history from which any major operational concerns can be identified.
Since LGS Unit 2 will have completed its 1
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Startup Testing Program, the snubbers will have experienced these I
varioun modes of operation, established an operating hiLtory, and I
fulfilled the basis for performing the initial visual inspection i
i within three months of commencing POWER OPERATION instead of four months as required by TS.
Changing the minimum interval for snubber i
visual inspection to three months eliminates one month of what would l
probably be steady state operation or shutdown from the operational I
experience of the snubber population.
Since steady state operation or shutdown does not significantly affect the visual inspection results for a snubber population early in life, one month of additional inspection time is unlikely to add to the effectiveness of this surveillance requiremont.
This proposed change does not alter any other TS requirement.
Therefore, any system that experiences an l
unexpected potentially damaging transient will be inspected in i
accordance with TS 4.7.4.d.
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INPORMATION SUPPORTING A PINDING OF NO i
SIGNIFICANT RAEARDS CONSIDERATION l
The proposed change was evaluated according to the standards of l
10 CPR 50.92 to determine if the proposed change constitutes a significant hazard.
The following evaluation of each standard is provided to support the conclusion.
(1)
The proposed change does not involve a significant increase in tie probability o'r consequences of an accident i
previously evaluated.
The proposed change does not affect the design or operation of equipment which is necessary to function to prevent an accident or mitigate the effects of an accident or to function following an accident.
The snubbers in question will not be altered in any manner, i
nor will their required surveillances be changed.
The initial visual inspection will be conducted in a calendar time frame consistent with the bases of the current surveillance requirement.
Further, this change does not affect any plant hardware, plant design, safety limit i
settings, plant system operation or procedures, and therefore does not l
modify or add any initiating parameters that would increase the l
probability of occurrence of the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the Final Safety Analysis Report.
(2)
The proposed change does not create the possibility of a new or difference kind of accident from any accident previously considered.
The proposed change does not add any new equipment, new procedures, or new tests or experiments.
It also does not affect the design or operation of equipment important to safety.
The snubbers will remain capable of performing their function and will be verified OPERABLE through performance of the visual inspection.
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0 (3)
The proposed change does not involve a significant 3
reduction in a margin of safety.
1 The initial visual inspections of the snubbers are intended to be j
i conducted as soon as practical following a sufficient period of t
I operation for the snubbers to experience various modes of operation.
The reduction of the calendar time frame for performing the initial visual inspection from four (4) months to three (3) months will not affect tha margin of safety as long as the snubbers have experienced sufficient various modes of operation.
Completion of the Startup 4
Testing Program, other than the warranty run, will ensure that the i
anubbers experience multiple startups and shutdowns, various l
transients, and periods of steady-state operation.
These various modes of operation are sufficient to establish an operating history j
for these snubbers and identify any major operational concerns through visual inspection.
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INFORMATION SUPPORTING AN ENVIRONMENTA1,ASSESSKENT I
The proposed TS change involves no increase in the amounts and no i
change in the types of effluents that may be released offsite, and involves no increase in the individual or cummulative occupational radiation exposure; therefore an environmental assessment is not l
required.
CONCLUSION The Plant Operations Review Committee and the Nuclear Review l
Board have reviewed this proposed change to the TS and have concluded i
that it does not involve a unreviewed safety question or a significant t
hazards consideration, and will not endanger the health and safety of the public.
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