ML20043D603

Safety Evaluation Supporting Amends 37 & 4 to Licenses NPF-39 & NPF-85,respectively

ML20043D603
Person / Time
Site:	Limerick
Issue date:	05/15/1990
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20043D602	List: ML20043D600 ML20043D603
References
NUDOCS 9006080304
Download: ML20043D603 (4)

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UNITED STATES W

NUCLEAR REGULATORY COMMISSION i,

WASHINGTON, D C. 20666 (o...*/

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NOS. 37 AND 4 TO FACILITY OPERATING LICENSE NOS. NPF-39 AND NPF '

PHILADELPHIA ELECTRIC COMPANY i

LIMERICK GENERATING STATION UNITS 1 AND 2 4

DOCKET NOS. 50-352 AND 50-353

1.0 INTRODUCTION

i By letter dated February 23, 1990, Philadelphia Electric Company (the licensee) requested an amendment to Facility Operating License Nos. NPF-39 and NPF-85 for the Limerick Generating Station, Units 1 and 2.

These proposed amendments would change the Technical Specifications (TSs) to remove cycle specific parameter limits in accordance with NRC Generic Letter (GL) 88-16, " Removal of Cycle Specific Parameter Limits from Technical Specifications" issued October 4, 1988. The proposed changes would replace the values of cycle-specific parameter limits with a reference to the Core Operating Limits Report,'which contains.the values of those limits. In addition, the Core Operating Limits Report (COLR) has been included in the Definitions Section of the TSs to note that-it is the unit-specific document that provides these limits for the current operating reload cycle. Furthermore, the definition notes that the values..

of these cycle-specific parameter limits are to be determined in accordance with the Specification 6.9.1.

This Specification-requires that the Core Operating Limits be determined for each reload cycle in accordance with the referenced NRC-approved methodology for these limits and consistent with the opplicable limits of the safety analysis Finally, this report and any mid-cycle revisions shall be provided to the NRC upon issuance.

Guidance on the proposed changes was developed by NRC on the basis of the review of a lead-)lant proposal submitted on the Oconee plant docket that was endorsed by tie Babcock and Wilcox Owners Group. This guidance was provided to all power reactor licensees and applicants by Generic Letter 88-16, dated October 4, 1988..

2.0 EVALUATION The licensee's proposed changes to the TS are_in accordance with the guidance provided by Generic Letter 88-16 and are addressed below.

(1) The Definitions section of the TS was modified to include a definition of the COLR that requires cycle / reload-specific parameter limits to be established on a unit-specific basis in accordance with 9006080304 900515 PDR ADOCK 05000352 P

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an NRC-approved methodology that maintains the limits of the safety analysis. The definition notes that plant operation within these limits is addressed by individual specifications.

1 (2) The following specifications were revised to replace the values of cycle-specific parameter limits with a reference to the COLR that provides these limits.

1 (a) Revise the Index.

1.

Remove figure references currently in Sections 3/4.2.1,

" Average Planar Linear Heat Generation Rate," and 3/4.2.3,

" Minimum Critical Power Ratio (MCPR)," for figures which are being relocated to the'COLR.

Insert a note on Index pages y and vi which describes the TS pages which have information intentionally omitted and references a note on a designated page. This note lets the reader know that information has been intentionally omitted and also gives a reference where the' reader can find further information.

11. Move information (which is not being deleted) on the affectedIndexpages-viandvia(forUnit1only)to reflect deletion of the figure references.

iii.Eliminatepagevia(forUnitl'only),sinceitisno longer required to acconnodate references to figures which are being deleted.

iv.

Insert " Core Operating Limits Report," into the

" Administrative Controls Section " 6.9, " Reporting Require-ments" under Section 6.9.1, " Routine Reports."

(b) Revise Section 3/4.2, " Power Distribution Limits."

i.

Revise Section 3/4.2.1, " Average Planar Linear Heat Generation Rate," by deleting the. phrase "which have been l

approved" and inserting in its place the phrase

" determined by approved methodology." Remove all figure references and add a reference to the COLR in Section 3/4.2.) for the limiting values. Remove Figures 3.2.1-1 thru 3.2.1-5, and for Unit 1 only, also remove Figures 3.2.1-6 thru 3.2.1-8.

Insert a note on page 3/4 2-2 i

describing which pages have been removed and that the information previousl 3/4 2-6c for Unit 1) y on pages 3/4 2-2 thru 2-6a (thru I

has been relocated to the COLR.

11. Revise Section 3/4.2.3, " Minimum Critical Power Ratio," to remove Figures 3.2.3-la, 3.2.3-lb and Figure 3.2.3-2.

Remove Figures 3.2.3-Ic and 3.2.3-1d from the Unit 1 TS 1

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only. Remove Table 3.2.3-1 from the Unit 2 TS only and note that the page has been intentionally left blank.

Remove all figure and table references and add a reference-to the COLR for the limiting values and the kj curve.

Insert a note on page 3/4 2-10 describing which pages have been removed and that the information previously oa pages 3/4 2-10 thru 3/4 2-11 has been relocated to the COLR.

iii. Revise Section 3/4.2.4, " Linear Heat Generation Rate (LHGR)," to reference the.COLR for limiting values.

iv. ReviseSection3/4.3.6,"RodBlockMonitor(RBM)," Table 3.3.6-2, Trip Function 1.a (RBM upscale) by replacing the RBM high flow clamped setpoint of 106 with the constant "N."

Revise all other cycle specific constants to functions of "N" (e.g., change 109' to (N+3)). The value of "N" is a cycle specific limit and is therefore referenced in the COLR.

(c) Modify Bases 3/4.2.1 and 3/4.2.3 to reference the COLR.

(d) Insert Sections 6.9.1.9 thru 6.9.1.12 into the " Administration Controls" Section 6.9.1, " Routine Reports." These Sections specify the information to be included in the COLR and the requirement to submit the COLR to the NRC. Specifically, this specification requires that the COLR be submitted, upon issuance, to the NRC Document Control Desk with copies to the Regional Administrator and Resident inspector. The report provides-the values of cycle-specific parameter limits that are applicable for the current fuel cycle. Furthermore, this specification requires that the values of these limits-be established using the NRC-approved methodology in NEDE-24011-P-A " General Electric Standard Application for Reactor Fuel" (Latest approved revision) and consistent with all applicable limits of 'the safety analysis. Finally, the specification requires that all changes in cycle-specific parameter limits be documented in the COLR before each reload cycle or remaining part of a reload cycle and submitted upon issuance to NRC, prior to operation with the new parameter limits.

(e) Move Section 6.9.2, "Special Reports," from page 6-18 to 6-18a to accommodate the addition of Sections 6.9.1.9 thru 6.9.1.12.

On the basis of the review of the above items, the NRC staff concludes that the licensee provided an acceptable response to those items as addressed in the NRC guidance in Generic Letter 88-16 on modifying E

cycle-specific parameter limits in TS. Because plant operation continues to be limited in accordance with the values of cycle-specific parameter limits that are established using an NRC-approved methodology, the NRC l

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staff concludes that this change is administrative in nature and there is no impact on plant safety as a consequence. Accordingly, the staff finds the proposed changes acceptable. The NRC staff, with the knowledge and consent of the licensee, made minor typographical and administrative corrections to the licensee's incoming Technical Specification pages.

As part of the implementation of Generic letter 88 16, the staff has also reviewed a sample COLR that was provided by the licensee. On the basis of this review, the staff concludes that the format and content of the sample COLR are acceptable.

3.0 ENVIRONMENTAL CONSIDERATION

These amendments involve changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendments meettheeligibility(10). criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and Pursuant to 10 CFR 51.22(b), no environmental t

l impact statement or environmental assessment need be prepared in connection j

with the issuance with the issuance of these amendments.

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4.0 CONCLUSION

The Comission made a proposed determination that these amendments involve no significant hazards consideration which was published in the Federal Register (55 FR *.0543) on March 21, 1990 and consulted with the comonwealth of Pennsylvania. No public coments were received and the Commonwealth of f

Pennsylvania did not lave any coments.

The staff has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the i

public will not be endangered by operation in the proposed - nner, and i

12) such activities will be conducted in capliance with try Comission's regulations and the issuance of.these amendments will not be inimical to the comon defense and the security nor to the health and safety of the public.

D4ted: May 15, 1990 Principal Contributors:

D."8. Fieno T. G. Dunning R. J. Clark l

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