ML20012E492

Application for Amend to License NPF-39,consisting of Tech Spec Change Request 89-06,making Administrative Changes to Eliminate Differences Between Units 1 & 2 Tech Specs

ML20012E492
Person / Time
Site:	Limerick
Issue date:	03/20/1990
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20012E493	List: ML20012E492 ML20012E501
References
NUDOCS 9004050264
Download: ML20012E492 (10)

Text

._- -- - - . - .- . . - . __

7

Ye *e 10 CFR 50.90 0; i PHILADELPHIA ELECTRIC COMPANY j NUCLEAR GROUP HEADQUARTERS f 955 65 CHESTERBROOK BLVD.  !

WAYNE, PA 19087 5691 f' m .i........ .

i t

March 20, 1990  !

Docket No. 50-352 i License No. NPF-39 l 1

U.S. Nuclear Regulatory Commission l ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

Limerick Generating Station, Unit 1 i Technical Specifications Change Request  !

t Dear Sir-PhiladelphiaElectricCompany(PECo)herebysubmitsUnit1 Technical l Specifications Change Request No. 89-06, in 6ccordance with 10 CFR 50.90,  !

requesting an amendment to the Technical Specifications (Appendix A) of j' Operating License No. NPF-39. . Information supporting this Change Request, which i; L. makes administrative changes to eliminate differences between Unit 1 and Unit 2  ;

l Technical Specifications, is contained in Attachment 1 to this letter. The l > proposed replacement pages are contained in Attachment 2. All proposed changes  !

are indicated in the text by revision bars in the u rgin. .j If you have any questions regarding this matter, please contact us.  !

l t Very truly yours, i

4. a.

G. A. Hur.ger, Jr, Mep), .  !

Director i Licensing Section  :

Nuclear Services Department

• u Attachments l

-cc: 'W. T. Russell, Administrator, Region I. USNRC T. J. Kenny, USNRC Senior Resident Inspector, LGS T. M. Gerusky, Director, PA Bureau of Radiological Protection i l f@[0ggggk$$ {2 e

1

a i, ,- TECHNICAL SPECIFICATIONS CHANGE REQUEST

(. .

NO. 89-06 L

I f

COMMONWEALTH OF PENNSYLVANIA

[ ss.

. COUNTY OP CHESTER  :

F.

D. R. Helwig, being first duly sworn, deposes and sayst 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 make administrative changes to eliminate differences between Unit 1 and Unit 2 Technical Specifications, 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.

] V ,

Vice P estdent Subscribed and sworn to before me thisdOIay ofIX'Mefl990.

bCCArh< r/$ NI M Notary Public NOTAFUAL SEAL CATHERINE A. MENDEZ. Notary Public Trecyffrin Two.. Chester County My Commies!ci Encires Sect. 4.1903 I

J

5, a;c c

i ATTACHMENT 1 LIMERICK GENERATING STATION UNIT 1 Docket No. 50-352 License No. NPF-39 i

TECHNICAL SPECIFICATIONS CHANGE REQUEST Proposed Changes to the Technical Specifications to Eliminate Differences Between Unit 1 and Unit 2 l

Technical Specifications i

i Supporting Infomation for Changes - 8 pages i

1 L

L

~

y i /. ' . +

I  ;

5 7

,- Docket No. 50-352 .i I'

• Lic nse N). NPF-39 i I

j Philadelphia Electric Company (PECo). Licensee under Facility. i Operating License NPF-39 for Limerick Generating Station (LGS), Unit 1 hereby requests that the Technical Specifications (TS) contained in AppeMix A of the i Operating License be amended as proposed herein to make various administrative  !

changes to eliminate differences between the Unit 1 and Unit 2 TS. The proposed  ;

changes are listed and the proposed change pages are provided in Attachment 2.

The proposed changes are indicated by vertical bars in the margin of the pages. (

PECo requests the changes proposed herein to be effective upon issuance of the L Amendment. I l

This change request provides a discussion and description of the  :

proposed TS changes, a safety assessment of the proposed TS changes, infomation

supporting a finding of No Significant Hazards Consideration, and information i supporting an Environmental Assessment.

l . Discussion and Description of Changes ,

I s

The proposed changes to the LGS Unit 1 TS are identified on the the

" List of Changes" contained in the front of Attachment 2. These changes have l- been divided into seven (7) groups as shown by the numbers in the left hand j column of the List. A discussion of each group is provided 'velow by the c rresponding numbers. The proposed changes that are editorial changes are l l- identified as such on the " List of Changes" and no further discussion is l

l provided below.

i l 1. Revise Note

• in Table 3.3.2-1. Table 4.3.2.1-1 and Section 3.6.5.2.2 of the TS in accordance with the changes previously made to Note

• in

, *} - Docket No. 50-352  ;

m -

i Lic;nse No. NPf-39 I i

TS Sections 3.6.5.1.2 and 3.6.5.3 by Unit 1 TS Amendment 29. These changes clarified the definition of OPERATIONAL CONDITION

• but the changes were not implemented in every TS which references OPERATIONAL l

CONDITION *. This is an administrative change to achieve consistency-throughout the Unit 1 TS and to eliminate differences between Unit 1 i

and Unit 2 TS.

2. Revise TS Section 4.3.7.2.2 by incorporating the changes incorporated by NRC in the original Unit 2 TS. This change is an administrative change to clarify the fact that some seismic instruments are not accessible during power operation and to clarify when these '

instruments are required to be restored to OPERABLE status following an actuation. ,

l Revise TS Table 3.3.7.2-1 to replace the triaxal seismic trigger and switches range information with notes which provide setpoint information. This is an administrative change to correct an error, i Providing range information for the trigger and switches is not t

l meaningful because their function is to activate recording equipment at a given setpoint. Therefore, the appropriate information to be  ;

! included is the setpoint.

l l Add for clarification, the location of the seismic trigger and the response spectrum analyzer since these locations were originally I omitted from the Table. All of the above proposed changes will eliminate differences between Unit 1 and Unit 2 TS.

3. Delete the statements / note from TS Sections 4.6.5.3.g and 4.7.2e.3 ana TS Bases 3/4.6.5 which refer to " initial criticality of Unit 2" l

l

. ',; ,f Docket No. 50-352 l

License No. NPF-39 i e  :

and "the issuance of the Unit 2 full power operating license." These i events have already occurred and therefore the statements / note no longer apply and can be administratively removed.

i

4. Add "- COW ON SYSTEM" to the TS Section 3/4.6.5.3 title for Standby Gas Treatment System (SGTS) and to the TS Section 3/4.7.2 title for Control Room Emergency fresh Air Supply System (CREFAS). The NRC l proposed and implemented the same editorial change to the Residual  ;

Heat Removal Service Water System (RHRSW) and the Emergency Service Water System (ESW) in Unit 1 TS Amendment 27 to clearly alert the operators that there is an interdependency between units. This same interdependency exists for SGTS and CREFAS and the proposed change will achieve consistency throughout the Unit 1 TS. The appropriate changes to the corresponding TS Index pages and Bases pages will also be made. This change was incorporated by the NRC throughout the original Unit 2 TS for the SGTS, CREFAS, RHRSW and ESW.

5. Revise the ACTION statements for the diesel generators in TS Section '

3.9.1.1 to incorporate the more restrictive ACTION requirements which were administrative 1y required by PORC Position 45 as committed to in our June 14, 1989 letter to the NRC and incorporated in the original -

Unit 2 TS.

During the developmeni, of the Unit 2 TS, the NRC determined that the l

proposed TS ACTION requirements for an inoperable diesel generator were not restrictive enough. Specifically, the NRC concluded that a 92 day allowable out-of-service time (A0T) for one diesel generator was too long, therefore the probability of failure of a second diesel generator, if required, was too high. This became critical if l _ _ .

i

_, Docket No, 50-352 l

i Lic:nse No. NPF-39 l R certain combinations of diesel generators became unavailable, resulting in two-train safety systems without the capability of being p powered by an OPERABLE on-site power source. Thus, the 92 day A0T I was reduced to 30 days.

Also, due to the system loading of the diesel generators. ACTION 'e' '

wasrevisedtoreflectthatifone(nolongertwo)dieselgenerator l becomes inoperable, the redundant systems fed from the remaining OPERABLE diesel generator (s) must be OPERABLE.  ;

l The 30 day allowable out-of-service time (A0T) and the revised ACTION r

'e' are more restrictive than the requirements presently contained in the Unit 1 TS, which were originally determined to be acceptable by the NRC for operation of Unit 1 as a single unit station. A note j i

will also be added to TS ACTIONS 'a', 'b', 'c', 'd', and 'h' to serve as a reminder to the operators to consider the special requirements of ACTION 'e.' The Unit 1 TS Bases 3/4.8 will also be revised to incorporate, as appropriate, the changes made by the NRC to the Unit 2 TS Bases which were required by the revision of the ACTION statements. These are administrative changes which incorporate more  ;

restrictive requirements and which will eliminate differences between Unit I and Unit 2 TS.

6. Add a statement to TS Bases 3/4.4.3.2 concerning the ACTION requirements for pressure isolation valves. This is an administrative change to the TS Bases which was requested by the NRC during the development of the Unit 2 TS in order to clarify the existing bases. This change will eliminate differences between the Unit 1 and Unit 2 TS.

{ y i p '; , _ ',* Docket No. 50-352  !

L License No. NPF-39 .[ !

7. Add an asterisk to the title of TS Section 6.9.1.6. " Monthly f Operating Reports." to indicate that a single submittal of the report f is made for both units. This is an administrative change to achieve  !

I consistency between Unit 1 and Unit 2 TS.  :

l Safety Assessment The proposed changes to the TS will achieve consistency throughout I the TS. provide clarification, correct errors, eliminate statements thet no '

longer apply, and make editorial changes. These are purely administrative changes. The proposed diesel generator TS ACTION changes administratively i incorporate into the TS previously implemented requirements that are more ,

restrictive than the requirements presently included in the TS. The proposed '

changes to the TS do not affect plant design, hardware, system operation, or procedures. Therefore, the changes do not impact any accidents previously cvaluated in the SAR nor any equipment important to safety.

l Information Supporting a Finding of No Significant Hazards Consideration .

We have concluded that the proposed changes to the LGS Unit 1 TS, '

l-l .which make administrative changes to eliminate differences between Unit 1 and .

1 Unit 2 TS do not constitute a significant hazards consideration. In support of this determination, an evaluation of each of the three standards set forth in 10 CFR 50.92 is provided below.

1. The proposed changes do not involve a significant increase in the ,

r probability or consequences of an accident previously evaluated.

p. ,.

, 'c- Docket ~No. 50-352 g License No. NPF-39 The proposed changes to the TS will achieve consistency throughout the TS, provide clarification, correct errors, eliminate statements that no longer apply, and make editorial changes. These are purely administrative changes. The proposed diesel gerarator TS ACTION

' changes administrative 1y incorporate into the TS previously f

implemented requirements that are more restrictive than the I requirements presently included in the TS. The proposed changes to the TS do not affect plant design, hardware, system operation, or i procedures. Therefore, the proposed changes will not result in a  ;

significant increase in the probability or consequences of an accident previously evaluated.

2. The proposed changes do not create the possibility of a new or ,

difference kind of accident from any accident previously evaluated.

P As discussed in item 1. above, the proposed TS changes are purely administrative changes and do not affect plant design, hardware.  ;

system operation, or procedures. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

l 1

3. The proposed changes do not involve a significant reduction in a margin of safety.

I '

As discussed in Item 1. above, the proposed TS changes are purely administrative changes and do not affect plant design, hardware system operation, on procedures. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

L l

• *- i

, , Docket No. 50-352 Licens? No. NPf-39 l Jnformation Supporting an Environmental Assessment l

l An environmental assessment is not required for the changes proposed I by this Change Request because the requested changes conform to the criteria for i

• actionseligibleforcategoricalexclusion"asspecifiedin10CFR51.22(c)(9). ,

l The requested changes will have no impact on the environment. This Change ,

Request does not involve a significant hazards consideration as discussed in the l 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 individual or cumulative occupational radiation '

exposure..

4 Conclusion 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 or a significant hazards consideration, and will not endanger the health and safety of the public.

_._ . _ . _ _ _ . - - .-__ ,