ML20005E786
| ML20005E786 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/29/1989 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20005E787 | List: |
| References | |
| RTR-REGGD-01.099, RTR-REGGD-1.099 GL-88-11, NUDOCS 9001110064 | |
| Download: ML20005E786 (11) | |
Text
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.j 10 CPR 50.90 PHILADELPHIA ELECTRIC COMPANY
~ NUCLEAR GROUP HEADQUARTERS 955-65 CHESTERBROOK BLVD.
p, WAYNE, PA 19087 5691 (zis) s40 sooo 7
u December 29, 1989 A
Docket'No. 50-352
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License No. NPF-39 U.S. Nucleror. Regulatory Commission ATTN: Document Control Desk Washington, D. C.
20555
SUBJECT:
Limerick Generating Station, Unit 1 Technical Specifications Change Request
Dear Sir:
Philadelphis. Electric Company hereby submits Technical Specifications Change Request No. 89-08, in accordance with 10 CPR
-50.90, requesting'an amendment to the Technical Specifications (TS)
(Appendix A) of Operating License No. NPF-39.
Information supporting'this Change Request is contained in Attachment 1 to this letter, and the proposed replacement pages are contained.in.
This submittal requests changes to TS Section 3/4 4.6 and associated bases to specify the revised time period for which the Reactor Pressure Vessel Pressure-Temperature Operating Limit curves are valid as a result of calculations performed in accordance with Regulatory Guide 1.99, "2adiation Embrittlement of Reactor Vessel
' Materials," Revision 2.
We committed to submitting this TS change question by December 29, 1989 in our response to NRC Generic Letter 88-11, "NRC Position on Radiation Embrittlement of Reactor Vessel Materials and its, Impact on Plant Operations," dated November 23, 1988.
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9001110064 891229 PDR ADOCK 0500035' hool P
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If you have any questions regarding-this matter, please contact us..
3 Very truly yours, O n ',
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G. A. Hunger, r.
. Director Licensing Section Nuclear. Services Department'
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Attachments cc:
W.-T. Russell, Administrator, Region I, USNRC T. J. Kenny, USNRC Senior Resident Inspector,. LGS l
T. M. Gerusky, Director, PA Lareau of Radiological Protection
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TECHNICAL SPECIFICATIONS CHANGE REQUEST NO, 89-08 2
I COM ONWEALTH OF PENNSYLVANIA :
ss.
i COUNTY OF CHESTER.
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-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 Applicatiori for Amendment of Facility Operating License to revise the period of j
j applicability for the Pressure - Temperature Operating Limit (PTOL) i
. Curve for Limerick Generating Station, Unit 1, and knows the I,
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 (2re Vice Presiden
. Subscribed and sworn to beforemethis[ day of uted<d989.
Lua er~;.a 0
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i Notary Public r s:
NOTARIAL SEAL ANGELA o, OLENGINSKL Notary Public Wayne, Chester County My Commission Excites Sect _31.1992 1
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Attachment.1 Limerick Generating Station i
Unit 1 i
i Docket No. 50-352 License No. NPF-39
. TECHNICAL SPECIFICATIONS. CHANGE REQUEST.
TSL -- 89-08 i
" Proposed Change to the Technical i
Specifications to Specify the Revised-1 Time-Period For Which the Reactor Pressure Vessel Pressure-Temperature Operating Limit L
Curves Are Valid'As A Result of v
Calculations Performed in Accordance With Regulatory Guide 1.99, " Radiation I
L Embrittlement of Reactor Vessel Materials," Revision 2.
Supporting Information for Changes -
6 pages 1
9 Philtdalphic Electric-Company,-Lican203 under Pacility Operating License NPF-39 for Limerick Generating Station (LGS), Unit 1, hereby freguests that the Technical Specifications (TS) contained in Appendix A=to the Operating License be amended.
Proposed changes to 1
L the TSLare indicated by the vertical bars in the margins of'the.
.pages contained in Attachment 2.
The pages to be changed are 3/4 4-18,-3/4 4-19, 3/4 4-20, B 3/4 4-5, B 3/4 4-7.
L The proposed changes affect the Reactor Pressure Vessel (RPV)
Thermal and Pressurization Limitations Section of the LGS Unit 1 TS.
-The= proposed changes involve clarification of the Pressure-Temperature Operating Limit (PTOL) curve to reflect new Adjusted
. Reference Temperatures (ARTS) calculated in accordance with Regulatory Guide 1.99, " Radiation Embrittlement of Reactor Vessel Materials," Revision 2.
We committed to submit this TS change request in our response to Generic Letter 88-11, "NRC Position on i
Radiation Embrittlement of Reactor Vessel Materials and its Impact.
on Plant Operations," dated November 23, 1988.
The proposed changes to the TS.will not result in a change of limits of the PTOL curve, i
but will result in.a change to the time frame (i.e., Effective Full
)
i Power: Years, EFPY). over which the curve applies.
The supporting information for the proposed changes to the TS includes a Description of the Change, a Safety Discussion, information p.
p supporting a finding of no Significant Hazards Consideration, and information supporting an Environmental Impact Assessment.
L Description of the Proposed Change i
The PTOL curves in the TS are established to comply with the requirements of 10 CPR S0, Appendix G, " Fracture Toughness i
- Requirements," to assure that brittle fracture of the RPV is prevented.
Part of the analysis involved in deve'o9 ng the curvec i
se t
PrgD ' 2 is to account'for neutron irradiation embrittlement effects in the core = region, or beltline of the RPV.
In the past, Regulatory Guide i
1.99, Revision 1 has been used to predict the shift in the nil--
j ductility reference temperature (RTNDT). as a function of' neutron
]
J fluence in the RPV beltline region.- Regulatory Guide 1.99, Revision i
1 was developed assuming that copper (Cu) and phosphorus (P) were
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the key chemical elements influencing embrittlement.
I Regulatory Guide 1.99, Revision 2 was. issued in May 1988.
Revision 2' represents the results of statistical evaluation of L
1 commercial reactor surveillance test data accumulated through 1984.
I There are two basic factors used in the calculations to predict the shift'in RTNDT shown in this Regulatory Guide; a chemistry factor (CP) and a fluence factor.
Both of these factors remained-the same in.the RTNDT shift calculation from Revision 1 to Revision 2 of Regulatory Guide 1.99.
However, the method used to calculate each factor has been significantly changed in Revision 2.
The CF has been changed from an equation based on Cu and P in
' Revision 1 to tables of CF values based on Cu and nickel (Ni), with separate tables for RPV plates and for RPV welds.
The fluence factor has been modified in Revision 2 to a somewhat more complex form.
GE has calculated the ARTS for the limiting core beltline materials based on Regulatory Guide 1.99, Revision 2.
The results of these calculations were documented in GE Report SASR 88-82,
" Impact of Regulatory Guide 1.99, Revision 2 on LGS Unit 1," which 1
was previously transmitted to the NRC as an attachment to our l
l response to NRC Generic Letter 88-11, dated November 23, 1988.
The ART is the unirradiated RT l
P us the shift due to neutron i
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Page 3 s
p, fluence. T The GE report provides the' ARTS for predicted fluences'
'between 4 and 32 Effective Full Power Years (EFPY) based on both Revision 1,and Revision 2 of Regulatory Guide 1.99.
The ARTS i
! calculated using Revision 2 at 10 EPPY for the most limiting core beltline material are bounded by the ARTS calculated using Revision g
1 at 32 EFPY.
The beltline limits are predicted to continue to shift to the right with the corresponding increase in ART through the life of the plant.
The proposed pressure / temperature limit curve, Figure 3.4.6.1-1, curves A, B and C, are based on the non-m beltline, discontinuity areas of the RPV which do not receive significant neutron fluence and the RTNDTs will, therefore, not shift.
These limit curves are predicted to be bounding'for all areas of the RPV until 12 EFPY when the beltline material's RTNDT will shift due to neutron fluence and the beltline curves will intersect the non-beltline discontinuity curves.
The non-limiting beltline curves are not shown on proposed Figure 3.4.6.1-1, but' included on FSAR Figure 5.3-4.
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After 12 EFPY the non-beltline curves will no longer be the most limiting and new curves must be developed.
In accordance with TS a-4.4.6.1.3, " Pressure-Temperature Limits Reactor Coolant System, 1
Surveillance Requirements," the first RPV surveillance capsule will be-removed and analyzed prior to 10 EFPY.
In accordance with 10 CFR 50' Appendix H, " Reactor Vessel Material Surveillance Program Requirements," the PTOL curves will be adjusted as required at that 1
L time.
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.The ARTS at 32 EFPY predicted using the methodology in 0
Regulatory Guide 1.99, Revision 2, are below the 200 F allowable limit' contained in 10 CPR 50, Appendix G.
Therefore, no further J
E.A Paga 4 i
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fracture mechanics analysis, testing, or provisions for thermal annealing are required.
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We propose to revise Figure--3.4.6.1-1 to relabel the curves to.
L be applicable'for 12 EFPY and to remove the A',
B' and C' curves i
(non-limiting beltline PTOLs), which were included for information j
only, to improv'e. readability of the figure. -We further propose to-revise TS 3.4.6.1 and 4.4.6.1 to remove reference to the A',
B' and C'
curves.
thz also propose to revise Bases sections 3/4.4.6 and-Bases Table B 3/4.4.6-1 to reflect the above described changes.
Safety Discussion i
The proposed change in the applicability of the PTOL curve from 32 EPPY to 12 EPPY does not compromise the safe operation of LGS Unit l.
This proposed change only reflects the shortened time period (12 EPPY) for which the' existing PTOL curves will now apply.
Therefore, this proposed change does not affect the existing PTOL curves and Unit I will continue to operate exactly as before.
Future analysisaof the RPV surveillance capsule and revisions to the PTOL curves as required ensures that the reactor pressure boundary will behave in a non-brittle manner during plant testing, startup, and operation throughout the life of the plant.
Information Supporting a Finding of No Significant Hazards Consideration We have concluded that the proposed changes to the LGS TS, which specify a new period of applicability for the PTOL curves, do not constitute a Significant Hazards Consideration.
In support of this
- P ga S determination, an evaluation of each of the three standards set I
forth in 10 CFR 50.92 is provided below.
i 1)
The proposed changes do not involve a significant increase in
.i the probability or consequences of an accident previously evaluated.
The proposed changes to the TS affect only the period of i
i applicability of the PTOL curves and do not involve any changes i
I to the operating limits as dictated by the curves.
They do not-l involve any changes to-safety equipment or operation of the plant.
After implementing this change, Unit 1 will operate exactly as before, without any increase in the probability or j
consequence,of an accident previously evaluated.
t 2)
The proposed changes do not create the possibility of a new or different kind of accident from any accident previously i
evaluated.
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1 The proposed changes to the TS affect only the period of l
applicability of the PTOL curves and do not involve any changes S'
L to plant operation, plant operating limits, or safety related V
equipment.
The PTOL curves will not be affected by this change and the Unit 1 will be operated exactly as before this proposed change.
Therefore, we conclude that the proposed changes by the TS do not create the possibility of a new or different kind of accident from any accident previously evaluated.
3)
The proposed changes do not involve a significant reduction in a margin of safety.
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!The proposed changes to the TS affect only the period of applicability of the PTOL curve and do not involve any changes to plant operation, plant operating limits, or safety related l
equipment.
There is no change being made to the operating characteristics of the existing PTOL curves, therefore, we j
conclude that the proposed changes do not involve a reduction in j
a margin of safety.
1
-l Information Supporting an Environmental Impact Assessment l
An environmental assessment is not required _for the changes I
proposed by'this Change Request because the requested changes conform to the criteria for " actions eligible for categorical exclusion" as specified in 10 CPR 51.22(c)(9).
The requested-changes will have no impact on the environment.
This Change Request does not involve a significant hazards consideration as discussed in the. preceding section.
This Change Request does not involve a significant change in the-types or significant increase in the amounts of any effluents that may be released offsite.
In addition, this Change Request does not involve a significant increase in in'dividual or cumulative occupational radiation exposure.
Conclusion I
The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes to the TS and have concluded that they do not involve an unreviewed safety question and will not endanger the health and safety of the public.
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LIMERICK GENERATING STATION.
UNIT 1 Docket No. 50-352 i
License No. NPF-39
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TECHNICAL SPECIFICATION CHANGE REQUEST
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,i TSL-89-08 i
.i List of Attached Pages 3/4 4-18 l
3/4 4-19
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3/4 4-20 B 3/4 4-5 L
B 3/4 4-7
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