ML20055F186

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Forwards Safety Evaluation Accepting Util Proposed Changes Re Scram Accumulator Check Valves
ML20055F186
Person / Time
Site: River Bend Entergy icon.png
Issue date: 06/27/1990
From: Abbate C
Office of Nuclear Reactor Regulation
To: Deddens J
GULF STATES UTILITIES CO.
Shared Package
ML20055F187 List:
References
NUDOCS 9007160052
Download: ML20055F186 (2)
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June 27, 1990 f

Docket No. 50 458 DISTRIBUTION 115HR"?TT57 E. Peyton Gulf States Utilities NRC PDR W. Paulsor ATTN: Mr. James C. Deddens local PDR C. Abbate SeniorVicePresident(RBNG) PDIV.2 R/F OGC Post Office Box 220 D. Crutchfield E. Jordan St. Francisv111e, Louisiana 70775 G. Holahan ACRS(10)

C. Grines J. Weibe

Dear Mr. Deddens:

PDIV.2 Plant File

SUBJECT:

LINE.lTEM IMPROVEMENT IN TECHNICAL SPECIFICATIONS . REQUIREMENTS RELATED TO BWR SCRAM ACCUMULATOR CHECK VALVES Recently the Philadelphia Electric Company requested a change to Technical 5)ecification (TS) requirenents related to scram accumulator check valves.

Tie requested change would allow the testing of these valves (and the success criterion) to be in accordance with the plant's inservice testing program rather than specified by TS requirements. The staff has completed its review of the proposed changes and has issued a Safety Evaluation (SE) accepting the three proposed changes.

Based on the similarity of River Bend's TS requirements to those of the Linerick Generating Station, you may wish to propose 15 changes based on the generic applicability to River Bend. Enclosed are the Philadelphia Electri Company amendment request (Enclosure 1) and the staff's SE (Enclosure 2). bese line-item TS improvements were not issued as a generic letter because of the small number of licensees involved, the requirements pertain to a select group of plants that received operating licenses in the 1982-1985 time frame, and the requirements involved do not exist in the Standard Technical Specifications for Boiling Water Reactors. The changes are completely voluntary. If you have any questions concerning this, please contact me.

Sincerely.

Original signed by:

Claudia M. Abbate Project Engineer Project Directorate IV.2 Division of Reactor Projects - 111, IV, Y and Special Projects Office of Nuclear Reactor Regulation

Enclosures:

As stated cc w/ enclosures:

See next page DFC  : PDIV-2/LA  : PDIV-2 PM ~:  :  :

......:....,,., ........:....... h.:.PDIV.2/D g .. .....y  :..............:..............:..............

NAME  : EPeyt n  : CAbbat :ye gC, Grimes'  :  :  :

DATE  : 6/5x/90  : 6hb/90 . 6/S7/90  :  :  :

l Document Name: LTR. TO MR. DEDDENS ,\

lOFFICIALItECORDCOPY 9007160052 900627 gDR ADOCK 0500 8 \

i: . ..

i Mr. James C. Deddens l cc w/ enclosures:

L Mark Wetterhahn, Esq. Ms. H. Anne Plettinger Bishop, Cook, Purcell & Reynolds 3456 Villa Rose Drive ,

1401 L Street,.N.W. Baton Rouge, Louisiana ,70806 Washington, D.C. 20005 Mr. Les England -

Director - Nuclear Licensing '

Gulf States Utilities Company i P. O. Box 220 St. Francisv111e, Louisiana 70775 Mr. Philip G. Harris l

'Cejun Electric Power Coop. Inc.

10719 Airline Highway '

P. O. Box 15540 Baton Rouge, Louisiana 70895 Senior Resident inspector P. O. Box 1051 ,

St. Francisville, Louisiana 70775 r President of West Feliciana Police Jury P. O. Box 1921 St..Francisville, Louisiana 70775 3

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission ,

~611-Ryan Plaza Drive. Suite 1000 '

Arlington, Texas 76011 Mr. J. E. Booker Mant.ger-Nuclear Industry Relations P. O. Box 2951 p Beaumont,-Texas 77704 Mr. William H. Spell Administratrre I l- NuclearEnergyDivisIon  :

Office of Environmental Affairs 1

I P. O. Box.14690 Baton Rouge, Louisiana 70898 Mr. J. David McNeill, III William G. Davis, Esq.

l- Department of Justice i l . Attorney General's Office P. O. Box 94095 Baton Rouge, Louisiana 70804-9095 1

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PHILADELPHIA ELECTRIC COMPANY NUCLEAR OROUP HEADQUARTERS 95545 CHESTERBROOK BLVD.

WAYNE. PA 19007 5691 i . . .. 4... q .

. November 17, 1989 Docket Mos. 50-352 50-353 ,,

License Nos. MPF-39 NPF-85 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555

SUBJECT:

Limerick Generating Station, Units 1 and 2 Technical Specifications change Request

Dear Sir:

Philadelphia Electric Corpany hereby submits Technical Specifications Change Request No. 89-12, in accordance with 10 CFR 50.90, requesting an-amendment to the Technical Specifications (TS)

(Appendix A) of Operating License Nos. NPF-39 and NPF-85.

Information supporting this Change Request is contained in .

Attachment 1 to this letter, and the proposed replacement pages are contained.in Attachment 2.

This submittal requests changes to TS Section 3/4.1.3, Limiting Condition for Operation (LCO) 3.1.3.5 and Surveillance Requirement (SR) 4.1.3.5, for the control rod stam accumulators. A

. misapplication of the requirements of TS Section 3/4.1.3 resulted in our request for a temporary waiver of compliance dated June 9, 1989 and an emergency TS Change Request dated June 10, 1989. The NRC letter approving the temporary waiver of compliance, dated June 9, 1989, allowed continued operation until the emergency TS Change request was approved. As committed to in our request for the emergency TS Change, dated June 10, 1989, we are proposing TS changes to provide a final resolution of this issue. ,

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The changes proposed herein were modeled after the corresponding TS approved for use at Rope Creek Generating Station,

. License No. NPF-57.

  • 4 If you have any questions regarding this matter, piease contact us. .

e very truly yours,  ;

Wh $L

. . Bung r, Jr.

Director Licensing Section ,

l- Nuclear Services Department l l

l Attachmentn cc: W. T. Russell, Administrator, Region I, OSNRC

! T. J. Kenny, USNRC Senior Resident Inspector, LGS l

T. M. Gerusky, Director, PA Bureau of Radiological Protection l..

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CO M ONWEALTH OF. PENNSYLVANIA *

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COUNTY OF CHESTER  :

D. R. Helwig, being first duly sworn, deposes and sayst i

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 modify the control rod scram accumulator Techneial 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.

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  • Vice Pres den Subscribed and sworn to C

beforemethis/7c.h ay of M 1989.

lA. ,SIA' N tary Public icuu. sm AN35'. A o o'. EN3Wsc N:.n'y pei WC- i Ei:'I*s Se 31 492

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.ATTACEMENT 1 l

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LIMERICK GENERATING STATION-  !

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Docket Nos. 50-352 50-353 l . License Nos. NPF-39 l

NPF-85 i L

TECHNICAL SPECIFICATIONS CHANGE REQUEST

" Control-Rod Scram Accumulator Technical Specifications Changes" '

l-AS. 74-/%

Supporting Information for Changes - 8 pages ,

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  • Dockot No. 50-352 50-353 e

Philadelphia Electric Company, Licensee unoer Pacility Operating Licenses NPF-39 and NPF-85 for Limerick Generating Station (LCS) Unit 1 and Unit 2 respectively, hereby requests that the Technical Specifications (TS) contanned in Appendia A of the operating Licenses be amended as proposed herein to modify TS Section 3/4.1.3, Limiting condition for operation (LCD) 3.1.3.5 and surveillance Requirement (SR) 4.1.3.5. The proposed changes are indicated with a vertical bar in the margin of pages 3/4 1-9 and 3/4 1-10 for both LGS Unit 1 and Unit 2 TS, and are contained in Attachment 2.

Philadelphia Electric Company (PEco

proposed herein to be effective upon issuance o)f the Amendments.' requests the changes This change Request provides a discussion of the proposed TS changes, a safety assessment of the proposed changes, information supporting a finding of No significant Bazards consideration, and information supporting an Environmental Assessment.

Discussion of Changes:

On June 9, 1989, prior to receipt of the Unit 2 Operating License, with Unit 1 at 50% power, we discovered that seventeen (17)

Unit 1 control rod drive (CRD) scram accumulators did not satisfy SR 4.1.3.5.b.2 during a leak test performed on May 9, 1989. Failure to satisfy the criteria of SR 4.1.3.5.b.2, which requires a leak test of each accumulator check valve, renders the associated control rods inoperable and thus requires a plant shutdown. Bowever, since Unit I was in a condition where the accumulators were determined to not be necessary to comply with design bases scram requirements, the NRC issued a temporary waiver of compliance allowing continued operation and subsequently, an emergency TS change was issued revising the applicability of the af fected SR. As committed in our request for the emergency TS change dated June 10, 1989, we are proposing the following TS changes as an appropriate final resolution of this issue.

AI) Remove SR 4.1.3.5.b.2 (and the associated footnote) which requires CRD scram accumulator check valve testing once per 18 months and specifies test acceptance criteria.

B) Modify LCO 3.1.3.5.a.2.a to allow the reactor operator twenty (20) minutes to restart a tripped CRD pump provided that reactor pressure is greater than or equal to 900 psig. If reactor pressure is less than 900 psig the operator will .h iedistely place the reactor mode switch in the Shutdovt. position.

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L Dockot No. 50-352 i

50-353

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' In addition, since we are proposing changes to the scraa accumulator TS, we are also using this Change Request to . propose a change to the scras accumulator low nitrogen pressure alara setpint. A number of TS violations have occurred at operating i

nuclear power plants due to setpoint drift of the nitrogen accumulator pressure sensors. As a result, General Electric Service L Information Letter (SIL) 429, Revision 1, '5CD Accumulator Pressure Switches," issued January. 18, 1988, recommends lowering the low nitrogen pressure alara setpoint of the scram accumulators to equal to or greater than 940 psig. This recommendation is intended to maintain the validity of the alara setpoint while reducing the risk l-of a TS violation which cauld occur due to setpint drift. We have ,

determined that GE SIL 429, Rev. 1 is applicable to LGS, although we have not experienced a '/S violation due to setpoint drif t of the pressure sensor for th9 low nitrogen pressure alars. To avoid such a TS violation, we arte proposing a TS change consistent with the intent of the GE SIL. Bowever, the change we are proposing is more conservative than the change recommended by GE in that the proposed alarm setpoint is equal to or greater than 955 psig.

(C) Change the 18 month scram accumulator pressure s2nsor channel calibration (setpoint), SR 4.1.3.5.b.1.b. from

  • 970 plus or minus 15 psig" to " equal to or greater than 955 psig".

t l Safety Assessment i

The changes proposed in (B) above ensure the scram l capability of all control rods.

Control rod scram accumulators and i

accumulator check valves are required to support the scram function l at reactor pressure less than 600 psig. At reactor pressures above 600 psig, reactor pressure alone is sufficient to scram the control rods. The proposed TS changes require an immediate shutdown if reactor pressure is less than 900 psig. Therefore, the scram capability of all control rods is ensured. When reactor pressure is greater than 900 psig, the allowance of 20 minutes to restart a CRD pump provides plant staff a reasonable time to restore pump operation. The additional LCO Action i.e.,

shutdown if reactor pressure is less than 900 psig) propose (d provides for prompt operator action to prevent reactor operation in a condition where the accumulators are required to support the scram function.

Removal of SR 4.1.3.5.b.2, proposed change (A) above, does not compromise proper testing and maintenance of the scram accumulator check valves since operability is ensured by TS SR 4.0.5 which requires inservice testing (IST) in accordance with Section XI of the ASKE Boiler and Pressure Vessel Code. The IST program requires a reverse flow surveillance test of the scram accumulator Docket No. 50-352 50-353 check valves once per calendar quarter if the plant is in Col'd Shutdown. This will ensure check valve testing at least during every Refueling Outage (i.e., le months). To verify that the check valves close, thi charging water header is depressurised and the i j

accumulator pressare and low pressure alaras are monitored. This i testing requirement ensures that the check valves are periodically 1 tested, maintained as needed, installed properly and function l

! correctly following maintenance. Therefore, proper testing and l operation of the scram accumulator check valves will continue to be I ensured by TS required IST program.

In addition, the current TS BR for the 18 month surveillance test of scraa accumulator check valves does not need to be required in the TS as the scram accumulators are not required to safely shut down the plant during normal reactor operation. A failed accumulator check valve would allow the accumulator pressure to bleed down on that one drive only if the CRD pump was tripped.

An operable CRD pump maintains charging water pressure at a higher pressure than the accumulator nitrogen pressure for all CRDs. Given a loss of the CRD pump and failure of a scram acenaulator check valve, the accumulator pressure would bleed down and not be able to assist that particular drive in a scram condition. Bowever, reactor pressure in excess of 600 psig is sufficient to fully insert a i

' control rod with a failed check valve. At 600 psig reactor pressure, the scram insertion time of an individual control rod with zero accumulator pressure would be within TS and design basis requirements. Also, the average scram time for all drives would continue meet design requirements. Therefore, failure of an accumulator or accumulator check valve is not significant with l

respect to the ability to shut down the plant during normal operating conditions.

The recommended TS change described in part (C) above would change the low nitrogen pressure alarm setpoint of the scram accumulator to " equal to or greater than 955 psig." This change is justifiable since the proposed setpoint maintains the same minimum alarm pressure currently allowed by TS. An upper limit is not necessary since, setting the low alarm setpoint grer'cer than 955 psig provides a more conservative setting (i.e., w311 result in earlier detection of decreasing pressure). This proposed TS change is in accordance with the GE recommendation (SIL 429 Rev. 1) to provide for adequate instrument drift allowance to avoid possible violations of the TS while maintaining sufficient nitrogen pressure for required scram performance.

The proposed TS changes for the control rod accumulators were reviewed against the design basis of the LGS Final Safety Analysis Report (FSAR). This review showed that the proposed changes would have no significant effects on system operation,

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Dockot No. 50-352

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average scram times, Minimum critical Power Ratio (MCPR), or the

. assumptions.

FSAR Section 15.1.3 " Pressure Regulator Failure - Open",

discusses a loss of reactor pressure event. The analysis does not I require the scram accumulators to shut down the plant.

FSAR Section 4.6.2 " Evaluations of the CRD Systaa,"

discusses control rod. operability assuming CRD equipment failure such as hydraulic line breaks. Bowever, the analysis does not .

require the scram accur.ulat9rs to shut down the plant.

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, FSAR Section 15.8 " Anticipated Transient Without Scram,"

i which discusses altigation of an ATWS event does not require the scram accumulators to mitigate the event.

In conclusion, the proposed changes to the TS do not i represent a change in the plant or the design bases as described in the LGS FSAR.

i In summary, the changes proposed are acceptable because operability of the scram accumulators will continue to be ensured by comp 11 ante to TS requirements. The reliability of the control rods

- to scrare is enhanced by the proposed Action statement, and the proposrd changes do not change the design bases as described in the FSAR.

Information Supporting a Finding of No Significant Bazards Consideration We have concluded that the proposed changes to the LGS scram accumulator TS, do not constitute a significant Bazards 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 probability or consequences of an accident previously evaluated.

Three changes have been proposed. .

A) Remove SR 4.1.3.5.b.2 which requires CRD scram accumulator check valve testing once per 18 months and specifies test acceptance criteria.

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Dockot No. 50-352 50-353

3) Modify LCO 3.1.3.5.a.2.a to allow the reactor operator twenty (20) ainutes to restart a tripped CRD pump provided that reactor pressure is greater than or equal to 900 psig. If' reactor pressure is less than 900_psig the operator will p namediately place the mode switch in the.8hutdown position.

+ C) Ch'ange the 18 month scram accumulator pressure sensor channel calibration (setpoint), SR 4.1.3.5.b.1.b from "970-plus or minus 15 psig' to .

  • equal to or greater than 955 psig." ,

The safety function of the scram accumulator is to assist in control rod insertion when reactor pressure alone is insufficient. The proposed changes do not change the capability of the control rod to perform its safety function and provide proper reactivity insertion within the required time.

Removal of the 18 month leak test specified by SR 4.1.3.5.b.2 does not affect the reliability of the check valves since operability of the scram accumulator check valves is assured by TS Section 4.0.5 which requires that inservice testing of the check valves comply with the ASKE Code,Section XI.

The proposed additions.to the TS LCO action statement 3.1.5.a.2.a described in (B) above impose additional requirements on operations personnel to prevent plant operation in a condition when the accumulators are required to support the scram function.

Finally, GE SIL 429 Rev. 1 provides a recommendation to change the applicable TS to allow for scram accumulator pressure instrument setpoint drift and thus avoid an unnecessary TS violation. The setpoint we have proposed in accordance with this GE SIL is within the currently allowed range but does not provide an upper limit. An upper limi+. is unnecessary since any pressure alarm activation above the minimum setpoint value is more conservative than alarm actuation at the minimum setpoint value.

In summary, the proposed will not affect nor change any-plant hardware, plant design or plant system operation from that already described in the PSAR. Therefore the proposed changes do not modify or add any initiating parameters that would significantly increase the 1

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DockGt No. 50-352 60-353 l J

^ i probability or consequences of any accident previously analysed.  !

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2. The proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated. ,

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As. discussed in (1) above, the design bases of the LCS i will remain the same. Therefore, the current PSAR will

' remain accurate with respect to its discussion of the i licensing basis events and its analysis of plant response and consequences. The propsed changes do not affect any ,

l equipment nor do they involve any potential initiating events that would create any-new or different kind of .

accident. As such, the plant initial conditions utilised for the design basis accident analyses are still valid.

3. The proposed changes do not involve a significant I reduction in a margin of safety. 1 I

As discussed in item (1) above, the safety function of the scram accumulator is to assist in control rod insertion when reactor pressure alone is insufficient. .

The proposed changes do not change capability of the l control rod to perform its safety function and provide H proper reactivity insertion within the required time. '

TS Section 3/4.1.3 requires that any control rod with an inoperable scram accumulator be restored to operable status or be declared as being inoperable and inserted.

This requirement'Is unchanged by'the proposed TS changes.

At normal reactor pressure (i.e., greater than 900 psig) reactor pressure alone is sufficient to scram the control rods. The proposed TS allow the plant operator 20 winutes to restore a tripped CRD pump if there is more )

than one inoperable scram accumulator and reactor pressure is equal to or greater than 900 psig. Control

' rod scram accumulators and accumulator check valves are required to support the scram function only at reactor '

pressure less than 600 psig. To prevent approaching the .

600 psig limit, the proposed TS require plant operators -

to immediately scram the reactor if there is more than one inoperable scram accumulator and there is not a CRD pump operating when reactor pressure is le6s than 900 psig.

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.. i LIMERICK GENERATING STATION . '

Docket Nos. 50-352 ,

50-353 4 i

License Nos. NPF-39 i NPF-85 L

PROPOSED TECENICAL SPECIFICATIONS CRANGES 4

List of Attached Change Pages l

Unit 1 3/4'l-9 i 3/4 1-10 .

Unit 2 3/4 1-9 3/4 1-10

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30t: TROL R0D $ CRAM ACCUMULATORS

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,, ),lMITING CONDITION FOR OPERATION 1

3.1.3.5 All control rod scram accumulators shall be OPERABLE. )

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 5*.

ACT, ON: ,,

a. In OPERATIONAL CONDITION 1 or 23 (
1. With one control rod scram accumulator inoperable, within 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />s:

l a) Restore the inoperable accumulator to OPERABLE status, or i b) Declare the control rod associated with the inoperable accumulator  !

inoperable.

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Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ,

2. With more than one control rod scram accumulator inoperable, declare the associated control rods inoperable and:

a) If the control rod associated with any inoperable scram '

accumulator is withdrawn, imediately verify that at least one .

control rod drive pump is operating by inserting at least one i withdrawn control rod at least one notch. If no control rod drive pump is operating and:

1) If reactor pressure is 3 control rod drive pump w,900 psig, ithir. 20 minutes then restart or placeat the least one reactor ,

mode switch in the shutdown position, or

2) sf reactor pressure is <900 psig, then place the reactor mode switch in the Shutdown position. ,

b) Insert the inoperable control rods and disarm the associated control valves either:

l l 1) Electrically, or l

' 2) Hydraulically by closing the drive water and exhaust water isolation valves.

l Otherwise, be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

b. In OPERATIONAL CONDITION $*:

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l *D 1. With one withdrawn control rod with its associated scram accumulator Rh. inoperable, insert the affected control rod and disarm the associated

(:. directional control valves within one hour, either:

a) Electrically, or f

- b) Hydraulically by closing the drive water and exhaust water isolation valves.

! 2. With more than one withdrawn control rod with the associated scram L

accumulator inoperable or no control rod drive pump operating, immediately place the reactor mode switch in the Shutdown position.

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'5WRVE!LLANCE R[QUIREM(NTS  !

1 4.1.3.5 Each control rod scram accumulator shall be determined OPERABLE: .

a. At least once per 7 days by verifying that the indicated pressure is 1 greater than or equal to 955 psig unless the control rod is inserted and l disarmed or scra med.
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b. At least once per 18 months by:
1. Performance of a:

a) CHANNEL FUNCTIONAL TEST of the leak detectors, and i b) CHANNEL CALIBRATION of the pressure detectors, and verifying an alarm setpoint of equal to or greater than 955 psig on l decreasing pressure.

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i LIMERICK - UNIT 1 3/4 1-10

, i L,1MITING CONDITION FOR OPERATION 3.1.3.5 All control rod scram accumulators shall be OPIRABLE.  !

APPLICABILITY: OPERATIONAL CONDITION $ 1, 2, and P.

ACT, ON: l

a. In OPERATIONAL CONDITION 1 or 2:
1. With one control rod scram accumulator inoperable, within 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />s:

a) Restore the inoperable accumulator to OPERABLE status, or ,

b) Declare the control rod associated with the inoperable accumulator '

inoperable. '

Otherwise, be in at least HOT $ HUT 00WN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

2. With more than one control rod scram accumulator inoperable, declare the associated control rods inoperable and:

a) If the control rod associated with any inoperable scram accumulator is withdrawn, immediately verify that at least one control rod drive pump is operating by inserting at least one withdrawn control rod at least one notch. If no control rod drive pump is operating and: i

1) If reactor pressure is 1900 psig, then restart at least one control rod drive pump within 20 minutes or place the reactor mode switch in the shutdown position, or
2) If reactor pressure is <900 psig, then place the reactor mode switch in the Shutdown position.

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' b) Insert the inoperable control rods and disarm the associated control valves either:

1) Electrically, or
2) Hydraulically by closing the drive water and exhaust water isolation valves.

Otherwise, be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

b. In OPERATIONAL CONDITION $*: .
1. With one withdrawn control rod with its associated scram accumu'lator inoperable, insert the affected control rod and disarm the assteciated directional control valves within one hour, either >

, a) Electrically, or

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b) Hydraulically by closing the drive water and exhaust water isolation valves.

2. With more than one withdrawn control rod with the associated scram accumulator inoperable or no control rod drive pump operating, immediately place the reactor mode switch in the Shutdown position.
  • At least the aCCumJlator associated with each withdrawn Control rod. Not applicable to control rods removed per Specification 3.9.10.1 or 3.9.10.2.

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SURVEILLANCE REQU]REMENTS

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. 4.1.3.5 - Each control rod scram accumulator shall be determined OPERABLE
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.a. At least'once'per 7 days by verifying that the indicated pressure is greater-than or equal to 955 psig unless the control rod is inserted and disarmed or scranmed. ,

b.- At least once pe'r 18 months by: '

1. Performance of a: ,

a) CHANNEL FUNCTIONAL TIST of the leak detectors, and b) CHANNEL CALIBRATION of the pressure detectors, and verifying an alarm setpoint of equal to or greater than 955 psig on l

decreasing pressure. l i

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LIMERICK - UN]T 2 3/4 1 10

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Dock 0t .thpo 50-352 3 50-353 i

The proposed change to the scram accumulator pressure instrument calibration setpoint is within the currently allowed range and is more conservative than the setpoint 4 recommended by GE.

3 For the reasons stated above the proposed changes do not involve a significant reduction in a margin of safety.

F Information supporting an Environmental Assessment An environmental assessment is not required for the '

changes proposed by this Change Request because the r g ested changes confore to the criteria for " actions eligible for >

' categorical exclusion" as specified in 10 CFR 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 L 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.

l Conclusion l The Plant Operations Review Comalttee 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 ,

do not involve a significant hazards consideration, and will not endanger the health and safety of the public.

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