ML20065E517

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Proposed Tech Specs,Increasing Surveillance Interval for Reactor Protection Sys Electrical Power Monitoring Channels
ML20065E517
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 03/28/1994
From:
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20065E514 List:
References
NUDOCS 9404080223
Download: ML20065E517 (3)
v • d • e


Text

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h ATTACHMENT 1 LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS.

50-352 50-353 LICENSE NOS.

NPF-39 ,

NPF-85 TECHNICAL SPECIFICATIONS CHANGE REQUEST NO. 92 054

" increased Surveillance Interval For The Reactor Protection System Electrical Power Monitoring Channels."

Supporting Information for Changes - 3 PAGES '

9404080223 940328 'S

' PDR -ADOCK 05000352 P PDR i

4 c ,

PAGE1 PECO Energy Company, licensee under Facility Operating Ucense Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, requests that the Technical Specifications (TS) -

contained in Appendix A to the Operating Licenses be amended as proposed herein, to increase the surveillance interval for the functional test of the Reactor Protection System (RPS) electrical' power monitoring channels, contained in TS section 4.8.4.3.a. from e /ery six (6) months to each time the plant is in cold shutdown for a period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unlest ine test was performed in the previous six months. This TS Change Request is based on the guidance set forth in NRC Generic Letter 91-09 " Modification Of Survolitance Interval For The Electrical Protective Assemblies in Power Supplies For The Reactor Protection System."

The proposed changes to the TS pages are indicated by a vertical bar in the margin of the affected TS pages. The TS pages showing the proposed changes are contained in Attachment 2.

We request that, if approved, the amendment to the LGS, Unit 1 and Unit 2 TS be effective upon issuance.

This submittal provides a discutslon and description of the proposed TS changes, a Safety Assessment of the proposed TS changes, information Supporting a Finding of No Significant Hazards Consideration, and Information Supporting an Environmental Assessment.

Discussion and Descriotion of the Pronosed Change 3 These proposed Limerick Generating Station, Unit 1 and Unit 2, Technical Specifications changes involve increasing the surveillance interval (i.e., reducing the test frequency) for the functional test of the Reactor Protection System electrical power monitoring channels, contained in TS section 4.8.4.3.a. from every six (6) months to each time the plant is in cold shutdown for a period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unless the test was performed in the previous six months. These changes eliminate the need to test the electrical power monitoring channels during power operation and thereby reduce the possibility of inadvertent challenges to the plant protection systems.

These proposed chan0es are in accordance with NRC Generic Letter 91-09 ' Modification Of Surveillance Interval For The Electrical Protective Assemblies in Power Supplies For The Reactor Protection System."

Safety Assegment These proposed Limerick Generating Station, Unit 1 and Unit 2 Technical Specifications changes involve increasing the surveillance interval for the functional test of the Reactor Protection System electrical power monitoring channels, contained in TS sectica 4.8.4.3.a from every six (6) months to each time the plant is in cold shutdown for a per!od of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unless the test was performed in the previous six months. If approved, this request would eliminate the nood to test the RPS electrical power channels during power operation and thereby reduce the possibility of inadvertent challenges to the protection system.

The design, function, and operation of the RPS system and its Electrical Protective Assemblies (EPAs) are not altered by this activity. The proposed changes are in accordance with the recommendations of Generic Letter 91-09 " Modification Of Surveillance Interval For The Electrical Protective Assemblies in Power Supplies For The Reactor Protection System." In addition, the proposed TS changes to increase the Interval between tests will not reduce the reliabi!Ity of the equipment to function as designed based on a review of Limerick Generating Station historical test results.

PAGE 8-Information Spooortino a Findino of No Slanificant Hazards Consideration We have concluded that the proposed changes to the Limerick Generating Station, Units 1 and 2, Technical Specifications, to increase the surveillanco interval (1.o., reduce the test frequency) for the functional test of the Reactor Protection System electrical power monitoring channels, do not involve a Signi'icant Hazards Consideration. In support of this determir#on, an evaluation of each of the three (3) standards, set forth in 10 CFR 50.92 is provided below.

1. The oronosed Technical Specifications crlances do not involve a slanificant increase in the orobability or conseauences of an accident oreviousiv evaluated The Reactor Protection System equipment subject to the proposed . Technical Specifications changes are not accident initiators. The Electrical Protective Assemblies (EPAs) speciflod by these proposed changes are not required to actuato in order to mitigate an accident. The functional test methodology of the RPS electrical power monitoring channels will not be effected by the proposed change in test frequency. The design and function of the EPAs will not be a!!ored and will perform as originally designed.

A review of the RPS electrical power monitoring relays surveillance test history results was performed and supports the proposed TS changes to extend the testing interval. Fifty-one (51) surveillanco tests were reviewed, and all the as-found channel calibration results were within the required TS limits. There were Identified deficienclos in four (4) of the fifty-one tests performed, however, these four deficiencies did not affect the operability of the RPS EPAs. Based on good ,

histc-ical surveillance test results, we have concluded that the rollability of the equipment is not expected to degrado during the proposed extended test interval. Furtherrnore, the proposed e.

reduced testing will result in a not decrease in the probability of occurrence of a malfunction of - e equipment important to safety. Those malfunctions would cause an invalid Inadvertent trip of the RPS which would impose unnecessary challenges on the affected unit at power. The guidanco set forth in Generic Letter 91-09 states 'The staff concludes that the benefit to safety of reducing the frequency of testing during power operations more than offsets the risk to safety from relaxing the survolllance requirement to test the EPAs during power operation."

Since the RPS EPAs are not accident initiators, and the design and function of the equipment will not be affected by the proposed TS changos, and the rollability of the equipment is not expected to degrade during the extended test interval, and the changes would reduce the probability of unnecessary challenges to the affected unit, we have concluded that the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. TjgprgngsidTJ_ changes.lio not create the,cossibility of a ,1ew or different kind of .i aJdent from any accident oroviousiv evaluated. '

The design and function of the RPS EPAs will not be affected oy the proposed TS changes.

The failure modos of the existing equipment will remain unchanged, and no new accident types will be created. Tho RPS electrical power monitoring channels' functional test methodology will not be affected by the proposed change in test frequency. Thereforo, the proposed TS changes do not create the possibility of a now or different kir,J of accident from any accident previously evaluated

PAGE 3

3. The orocosed TS chances do not involve a sionificant red iction in a marain of safety.

Based on a review of the RPS electrical power monitoring relays survol!!ance test history results we have concluded that the reliability of the equipment is not expected to degrado during the proposed extended test interval, in addition, the benefit to safety by reducing the frequency of testing during power operation and the attendant possible challenges to safety systems more than offsets any risk to safety from relaxing the surveillance requirements to test the EPAs during power operation. Therefore, the proposed TS changes do not involve a significant reduction in a '

margin of safety.

Information Suncortino an Environmental Assessment An Environmental Assessment is not required for the Technical Specifications changes proposed by this Chango Request because the requested changes to the Limerick Generating Station,-

Units 1 and 2 TS conform to the criteria for " actions eligible for categorical exclusion," as specified in 10CFR51.22(c)(9). The proposed TS changes do not involve a Significant Hazards j Consideration as discussed In the preceding safety assessment section.. The proposed changes do not involve a significant chango in the types or significant increase in the amounts of any effluent that may be released offsite. In addition, the proposed TS changes do not involvo a significant increase in individual or cumulative occupational radiation exposure.

Conclusion i The Plant Operations Review Committoo and the Nuclear Review Board have reviewed these proposed changes to the Limerick Generating Station, Units 1 and 2, Technical Specifications, and have concluded that they do not involve an unroviewed safety question, and will not endanger the health and safety of the public.

I 1

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i ATTACHMENT 2 ,

LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS.

50 352 50 353 LICENSE NOS..

NPF49 NPF-85 TECHNICAL SPECIFICATIONS CHANGE REQUEST NO. 9M5-0 .

AFFECTED PAGES I

UNIT 1 UNIT 2 3/4828 3/4 8-28 L

f i

v g ,-. - s -,

EllCiRICAL P0MER SYSTEMS

-REACTOR PROTECTION SYSTEM ELECTRICAL POWER MONITORING

~ LIMITING CONDITION FOR OPERATION 3.8.4.3 Two reactor protection system (RPS) electric power monitoring channels for each inservice RPS Inverter or alternate power supply shall be OPERABLE.

APPLICABILITY: At all times.

' ACTION:

a. With one RPS electric power monitoring channel for an inservice RPS Inverter or alternate power supply inoperable, restore the inoperable . -

~

power monitoring channel to OPERABLE status within 72. hours or remove the associated RPS Inverter or alternate power supply from service.

b. With both RPS electric power monitoring channels for an inservice RPS Inverter or alternate power supply inoperable, restore at least one electric power monitoring channel to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or remove the associated RPS Inverter or alternate power supply from service.

SURVEILLANCE REQUIREMENTS 4.8.4.3 The above specified RPS electric power monitoring channels shall be determined OPERABLE: >

a. By performance of a CHANNEL FUNCTIONAL TEST each time the plant is in COLD SHUTDOWN for a period of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unless performed in the previous 6 months.
b. At least once per 18 months by demonstrating the 0PERABILITY of overvoltage, undervoltage, and underfrequency protective instrumenta-tion by performance of a CHANNEL CALIBRATION including simulated automatic actuation of the protect've relays, tripping logic, and output circuit breakers and verifying the following setpoints.
1. Overvoltage s 132 VAC,
2. Undervoltage 2109 VAC,
3. Underfrequency 2 57 Hz.

. LIMERICK l-UNIT 1 3/4 8-28

7 ELEURidLPOWERSYSTEMS

~LIMITING-CONDITION FOR OPERATION

. 3.8.4.3 -Two reactor protection system (RPS). electric power monitoring channels

' for each inservice RPS Inverter or alternate power supply shall be OPERABLE.

APPLICABILITY: At all times.

SCTIO3:

a. With one. RPS electric power monitoring channel for an inservice RPS '

Inverter or alternate power supply. inoperable, restore the inoperable power monitoring channel to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or remove'the associated RPS Inverter or alternate power supply from service. .;

b. With both RPS electric power monitoring channels for an inservice RPS Inverter or alternate power. supply inoperable, restore at'least one electric power monitoring channel to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or remove the associated RPS Inverter or alternate power supply from service.

EURVEIlLANCE REQUIREMENTS 4.8.4.3 The above specified'RPS electric power monitoring channels shall be determined OPERABLE: .

a. By performance of a CHANNEL FUNCTIONAL TEST each time the plant is in COLD SHUTDOWN for a period of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unless ,

performed in the previous 6 months.

-b. At least once per 18 months by demonstrating the OPERABILITY of overvoltage, undervoltage, and underfrequency protective instrumenta-tion by performance of a' CHANNEL CALIBRATION including simulated automatic actuation of the protective relays, tripping logic, and output circuit breakers and verifying the following setpoints. ,

1. Overvoltage $ 132 VAC,
2. Undervoltage 2 109 VAC,
3. Undarfrequency 2 57 ilz.

LIMERICK - UNIT 2 3/4 8-28

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