ML20067C276

Application for Amends to Licenses NPF-39 & NPF-85, Consisting of Tech Spec Change Request 90-17-0,eliminating Tech Spec Surveillance Requirement 4.9.2.b.1 Re Source Range Monitor Channel Functional Tests

ML20067C276
Person / Time
Site:	Limerick
Issue date:	01/31/1991
From:	Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20067C279	List: ML20067C276 ML20067C281
References
NUDOCS 9102120010
Download: ML20067C276 (10)

Text

{ j 1 a ,

1 10'CFR 50.90 PHILADELPHI A ELECTRIC _ COM PANY -

NUCLEAR GROUP. HEADQUARTERS -

955 65 CHESTERBROOK-DLVD.

WAYNE, PA 19087 5691 (ats) s40 sooo : ,

January 131,.1991 Docket Nos. 50-352 'i 50-353  ?

License Nos.JNPF NPF >

U.S. Nuclear Regulatory' Commission y Attn: Document Control Desk Washington, DC' 20555 subject: Limerick Generating-Station, Units 1iando2 t Technical Speci'fications Change Request l

Gentlemen:

Philadelphia Electric Company:is submitting Technical- ,

Specifications (TS) Change-Request:No. 190-17-0, in'accordance with 10 CFR 50.90, requecting amendments ~.to the TS-(Appendix A) of 7 Operating License Nos. NPF-39;and NPF-85 for Limerick Generating

' Station (LGS), Units-1 and 2,7respectively., This.< submittal:

requests that the frequency for= performing Source Range. Monitor *

(SRM) channel functional tests; be ' reduced- by_ eliminating: TS--

Surveillance-Requirement =(SR)-4.9.2.b.1,_ requiring-channel functional tests within twenty four_(24)--hours prior.to the; start 4 of-core alterations, wh'ile retaining the existing-_SRoto perform the-same test at least'once per seven-(7) days.: Information supporting I

this Change Pnquest is contained in Attachment lito this~ letter,-

and the proposed replacement pages forJthe LGS, Units 11 and 2,.TS are contained in_ Attachment 2.

s

.We request that, if-approved,'t.i NRC' issue the Amendments _to-  :

l. the LGS, Units 1 and 2, TS in . time' te;r use during? thel upcoming; Unit '

2 refueling outage currently scheduled te begin'on March 2 3 ,_' 1 9 9 1 .

Therefore, we request'that the approved Amendments:be effective; 4 upon issuance.

r , 0- .

9102120010 910131 PDR ADOCK 05000352 ,-

N = }. x( , s . / ~.v P POR t

. . , , ,. + -. , , - , r .+ ~ . . o, -~a.--+ r ,+ - +

7 U.S. Nuclear Regulatory Commission January 31, 1991 Dagament_ Control Desk Patte 2 us.

If you have any questions, please'do not hesitate to contact Very truly yours,

,f L 9 s /

G. J. Beck Manager Licensing Section Nuclear Engineering and Services Attachments cc: T. T. Martin, Administrator, Region I, USNRC (w/ attachments)

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

~

(w/ attachments) _,

T. M. Gerusky, Diret i.or, PA Bureau of Radiological Protection (w/ attachments)

}

1 h

I f

} J

D

, , l COMMONWEALTH OF PENNSYLVANIA  :

es, j l

COUNTY OF CHESTER  : l j

i G. M. Leitch, being first duly sworn, deposes and says i

~ That he is Vice President of Philadelphia Electr .: Company; the Applicant herein; that he has read the foregoing. Application for. Amendment of Facility Operating License Nos. NPF-39 and NPF-85-(Technical-Speci.: ica tior

• Change. Request-No. 90-17-0) to reduce the frequency of performing Source Range Monitor (SRM) channel' functional testa during refueling operations, ano know that 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 .

, /

. .-- -p-Vice President subscribed and sworn to before me this 3 /"# day of a, % , 4 1991.

Ydl2n!u(b1%t.aud.1c..

Notary Public jp CA rsyp g' ,, g. $.gy ,k ,

i

_c4re two.Ch,%,c Q Q?.UjE,elht 4 1993 9"

I l

. l l

l l

l ATTACHMENT 1 LIMERICK GENERATING STATION

. Units 1 and 2 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85  ;

'l TECHNICAL SPECIFICATIONS CHANGE REQUEST No. 90-17-0 )

" Deletion of Source Range Monitor (SRM) Channel  !

Functional' Test Surveillance ~ Requirement" l Supporting Information for Changes 6 pages

) 1

-i

~

11 i

3 1

F

+

_. l

Attachment"1

, Page '

2-- l l l l

Philadelphia Electric Coppany -(PECo) ,- Licansee under -Facility j Operating License Nos. NPF-39 and NPF-SS for Lir.erick' Generating '

Station (LGS)~, Units 1 and 2'respectively,_ requests.that-the Technical Specifications (TS); c ontained in' Appendix A ;of the _;

oporating Licenses NPF-39 and NPF-85 be amended as proposed herein a to reduce the-frequency of performing Source Range' Monitor (SRM)  ;

i channel functional tests daring_ refueling _ operations. . _

Specifically, this Change Request proposes to-reduce the frequency: '

of performing SRM channel functional tests-during refuel ng operations by eliminating the TS Surveillance-Requi~rement-(bR) 4.9.2.b.1, requiring the. performance lof a channel ~ functional test. .,

within' twenty-four (24) hours prior tcothe e:. art of-core _ .

}

alterations,-while retaining the SR to-pe4tormLthe same test at-least once-per seven_ days. This proposed change,will allow forLa:  ;

reduction in refueling outagelcritical path-time andtbeller '

i utilization of skilled manpower _during refueling _ operations. LThe- . i

proposed change to the LGS, Units 1 Land 2, TS is< indicated by a; vertical bar in the margin of TS~page 3/4'9-4. The proposed TS change.pages.are contained-in Attachment'2.

This Change Request.for LGS,: Units'1LandL2, providesLa I discussion and description of the. proposed TS" change, a safety-assesament of the-proposed TS change,cinformation-supporting a1 finding of No Significant Hazards,:and information supportingfan Environmental- Assessment- ,

We are requesting that, if approved,Jthe-~NRC=

f issue.the Amendments to the LGS, Units 1 and-2, TS in timefforiuse_during the' upcoming Unit 2 refueling outage: currently scheduled to beginion March 23, 1991. -Therefore, ve request'that_the; approved Amendments-be effective upon-issuance.

Discussion and rescrintion of the ProDosed ChhD92-The SRM.is:a subsystem of the NeutronLMonitoring; System used-to 1) monitor neutron - flux. levels intthe ~ core: at Jvery low- power-levels during controlled plant" start-ups.and! shutdowns, and 2)L provide' signals to= block control rod withdrawal ificertain ~

proostablished. conditions are not mets During_ refueling _ operations-the SRMs mr.11 tor neutron flux-levels in thel core toiverify that the:

~

.react or is not' approaching-criticality. LThe SRM subsystem-provides-no safety-related function and is:not: assumed to_ operate during-any

~

designLbasis accident or transient.. However, if: core shutdown -

margin has not been demonstrated, the SRMs.doEprovide the. ,

compensatory _ protection of'a_ reactor' SCRAM.during the time;a control rod is being withdrawn since TSl Limiting / conditions 1.for -

Operation require that the SRM logicEshorting links be removedofrom the ReactoriProtection System circuitry which would, if'necessary, result in a non-coincident reactor. SCRAM-signal.

l 1

>- - - v.--e ..w.,., , ar,,,,,a w ,.-~ n wr.w, , .o m e ,,,-~a ,, -,r w ,+ a ne + e a v n.ww e . e

l Attachment l'  !

Page 3 i

1 The current TS SR for performing SRM channel functional i testing in Operational Condition 5 (Refueling) requires that SRMs undergo channel functional testing within twenty-four (24) hours prior to the start of core alterations, and at least once '

every seven (7) days. This proposed TS change requests that TS SR 4.9.2.b.1 (i.e., requiring SRM channel functional test:within twenty four (24) hours prior to the start of core alterations) be eliminated. TS SR 4.9.2.b.2 (i.e., requiring functional testing once overy seven (7) days) will, however, be retained. Eliminating 3 SR 4.9.2.b.1 Will allow for a reduction in. outage critical path

~

time and better utilization of manpower during refueling operations, j Safety Assessment The SRMs do not provide any safety-related function and are not assumed to operate during any design bacis accident or transient.

Additionally, there are no specific regulatory requirements concerning SRMs. The SRMs are designed to monitor neutron flux levels in the core at \ery low power levels during controlled plant start-ups and shutdowns, and to block control 1 rod withdrawal if certain preestablished conditions are not,mut. During refueling I activities, SRMs monitor neutron flux levels in ihe core to verify i that the reactor is not approaching criticality. _However, if core shutdown margin has not been dr.monstratcd, the SRMs do  ;

provide the compensatory protection of a reactor SCRAM during.the  ;

time a control rod is being withdrawn since the SRM logic shorting links are required to be removed which would, if necessary, result in a non-coincident reactor SCRAM signal.

This proposed TS change for LGS, Units 1 and 2, involves reducing the frequency of performing SRM channel functional tests during refueling activities by eliminating TS SR 4.9.2.b.1 (i.e., requiring SRM functional testing within twenty-four (24) hours prior to the start of core alterations) while retaining TS SR 4.9.2.b.2 (i.e., requiring functional testing once every seven (7)-

days).

In accoidance with the guidance provided by ANSI /IEEE Standard 352-1987, "IEEE Guide for General Principles of Reliability Analysis i of Nuclear Power Generating Station Safety Systems," an historical assessment was performed on past SRM channel functional test data.

This assessment provided an indicator concerning the unavailability of the SRM suhsystem for LGS, Units 1 and 2. The data obtained from this assessment were then compared .tas existing industry data collected for Boiling Water Reactors (BWRs).during the period 1975 through 1985. This industry data is documented in NEDO-31558, March 198e, Tesition on NRC Regulatory Guide 1,97, Revision 3, Requ;.rements for Post-Accident Neutron Monitoring System." The results of this data analysis for LGS, Units 1 and 2', are described below.

l'

[ Attachment l'

.Page 4 L

Unit 1.

The SRM channel . functional test data were collected for: the:

period of_ October 15, 1984 through July 12,o1990. During-this period, 438 SRM channellfunctional--tests wereJperformed on the SRMs. A review of the:dataEfor the"438 tests indicated (

that the' required limits for the; upscale-andJdownscale: trips c

were never exceeded as a result of mechanical failure and no- '

system functional failures occurred during1this time-period.. j However, _ .three - (3) surveillance test; failures owere identified during this period due_to incorrect setpoints. These~ .

failures are not associated.with,anyJinstrument malfunctions,;

and were. corrected; i

Unit 2 ,

-period The SRM channel of June 5,. functional . test data were': collected: for the:

1989 through July 22,J1990.- During:this i period, 102 SRM_ channel' functional' tests Were1 performed'on the SRMs. A review-ofLthe data'for the 102ctests indicated r

no system functional failures afor tho1 period.:- m 4

Based-on the historical'assessmentLofESRM:channeltfunctionall "

test data, the SRMs ' for- LGS, LUnits :1. and L2 h were never; declared- i!

inoperable . due to system '-functionalifailures.: 2The:BWR? industry-data dccumented in NEDO-31558Jfor the period: 1975Dthrough11985 also- g indicated to frequent that the SRMs:in BWRs:are highly reliable:and*notl subject.

failures. i 15.9.5.1, The LGS Updated Final Safety Anal'ysis Report /(UFSAR)',--Section1 states that-the appropriate surveillance" interval is ,

determined by consideration.of;theDeffect ofesystem(operability?on-

~

plant safety:and the:effect of testinguon plantTsafetya- SinceEthe=

historical assessment of SRM channel functionaljtest, data concluded:

that the systems -were 'never_ inoperable 1dueutoufunctionalE failures:

'and UFSAR Section 7.7.1.6' states that:thelSRMauare non-safety l

-related, reducing the surveillance:frequencyifor1SRMs?during.

refueling operations tofonce-every:seven (7) days.willunot effect 1 plant' safety.- Reducing the'surveillanceLfrequency ca_n"al'so reduce unnecessary testing ~of thejsPMs which mayxshorten the; lifetime;of components in the SRMs'and reduce (the possibility for' improper-

-restoration'after testing.: ThisLproposed!TS change will nots

' involve any. modifications'to the SRMsjorr other pinntLequipment; therefore,_thereLis no firexprotection or. radiological concerns-i

-f associated withLthis proposedichange..

I i

t i i) ;

k ".[-

7, Attachment 1 Page 5-i Additionally, TS SR 4.9.2.c.2_ requires that a_ count rate of at least 3.0 counts per-second (cps) be; verified on an1SRM channel once every twelve (12)-hours during core alterations; thereby, verifying SRM system operability. This proposed TS change to eliminate TS SR t.9.2.b.1 (i.e., perform channel functional test-within 24 hcurs prior-to the start of care alterations),-is consistent with the surveillance requirementsEspecified in_the proposed improvcd BWR TS currently under review by the NRC.

Information Suncortino a'Findina'of'No Sionificant Hazards Consideration We have: concluded that the proposed-change to.the LGS, Units 4 1 and 2 TS, which involves reducing the frequency of performing >SRM-channel functional testing, does not constitute etsignificant Hazards Consideration. In-supportiof this determination, an-evaluation of each of the-three (3) standards set forth in 10 CFR 50.92 is provided below.

1) The pronosed chance does not involve a sionificant increase inc ,

the plobability or consecuences of-an accident oreviousiv ,

evaluated.

The proposed TS change-involves reducing theifrequency.of-performing SRM-channel functional-tests;during refueling-operations by. eliminating TS SR 4.9.2.b.1 (i~e.,rrequiring a

. i channel _ functional test within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />sLprior to:the start of core alterations) while retaining TS SR 4.9.2.b.2 (i.e.,

requiring a channel-functional test at'least once every seven (7) days), i The SRMs provide no safety-related function and'are.not assumed to operate during any' design 1 basis accident-or. I transient.- The.SRMs were'not designed'as_ClassL1E and

-do not provide any automatic. plant trips during power operation. The SRMs provide.on-scale; monitoring of; neutron _ j flux levels-in the core during. start-up and' refueling .

i operations, and can initiate-control rod withdraw blocks if-neutron flux level limits are exceeded. Prevention and-mitigation'of promptJreactivity excursions during refueling and low power operation is _ controlled by : refueling . interlocks, the j Intermediate hange. Monitor (IRM), neutron flux ' reactor . SCRAM, '

the Average 1 Power Range = Monitor (APRM) neutron flux SCRAM,

~

Control Rod Block instrumentation,-and maintenance of the' core shutdown margin. However, if-shutdown margin has not been demonstrated, the SRMs do provide the compensatory-protection ,

of a reactor SCRAM during'the time a control rod is being withdrawn since the'SRM' logic-shorting l links-are; required to-be "

removed which would, if necessary, result in a non-coincident reactor SCRAM signal.

1

. . , - -- - - = - -

a e i= v1 Attachment 1 Page 6' i

Additionally, an historical assessment. ofiSRM channel functional test dataiconcluded that the operability ofithe SRM i system will not'be affected by reducing the channe1Lfunctional

. test-surveillance. frequency. . Monitoring the the countLrate of an SRM channel _once every twelve (12)' hours as- required Lby: TS' SR 4.9.2.c.2Lverifles system operability.- Reducing the1SRM surveillance -frequency during . refueling operations will' noti inhibit the response'of.any. systems _ described-in the UFSAR designed to mitigate the consequences of an accident.

l Therefore, basedion the evaluation-described above,-reducing- A theLSRM; surveillance frequency;during refueling 1 operations doesi

~

j not increase the probability'orEconsequencesiof an-accident: j previously_ evaluated.

2) The nroposed chance does not create'the nossibility of~a new or.

different kind of accident from'anv' accident nreviously i evaluated.

~

The proposed TS change _ involves reducing 1the frequencyc of:

~

performing SRM channel. functional 1 tests _during: refueling operations. The SRMs provide no-safety-related; function

-andrare not assumed toioperateiduringranysdesign' basis accident > -

or transient' analysis. :TheTSRMs= provide on-scale. monitoring of neutron flux levels: ini the core!during -start-up' and-

. refueling, and initiate: control: rod withdraw-blocks 1fineutron' l flux level liaits are exceeded.- TherSRMs.are/not: designed ast Class 1E and do not initiate'any; automatic plantitrips=during.

power. operation. Prevention and'mitigationLofLprompt- , .

reactivity excursions!during-refueling andilow(power 1 operation is controlled'by refueling. interlocks,~the'IRMEneutroniflux-reactor-SCRAM, the APRM neutron =l flux. reactor SCRAM,7controlfrod= j block instrumentation,=and" maintenance of-theicore) shutdown' .

y margin. However, if shutdownimargin'has-not been 3 demonstrated,b 1 the SRMs do providejcompensatory; protection _ofla reactoriSCRAM-during the'_ time a control 1 rod'is1being withdrawn since the1SRM logic-shorting links are' required to be removedtwhich would,mif necessary, result in-atnon-coincidentLreactor SCRAMasignal.

Reducing the surveillance frequency will'nottinhibit.the= l

. response ofcany system (c.g.,,IRMs, APRMs)Tdesignedi;to' mitigate.

the consequences of an accident. :Furthermorei this proposed;TS' change does not increase the potential for fuellfailures,Jor:

release of reactor coolantLor other radioactive = material.

Therefore, based cx1 the evaluation described above,J reducing, the SRM channel functionalz testtcurveillanceJfrequency:duringL ,

refueling,-by eliminating TS:SR 4'.9.2.b.1, does.notrinvolve.any 1 potentialEinitiating event that1wo'uld createfthe possibility;of 1 a.new or different kindfof accident fromEany.. accident fpreviously evaluated.

l l

l.

i

, - .- - , . . . , . J k-

-. - . -.-- . . - . . - - . . . . .~ - ..~. , - . . . - ~ ,

d .l.  !

Attachment 1 Page 7 f

4 4

3) The oroposed chance does not involve a sianificant reduction in .

~a marain of safety. J The proposed TS change involves reducing the,SRM channel functional test surveillance frequency. - The SRMs-provide'no r safety-related function and are not assumed to operate during '

any design bas 2s accident or transient.. Reducing'the surveillance' frequency will not prevent the SRM subsystem;from-functioning as designed to provide > neutron flux level:

indication,. control rod withdraw; blocks, or.a1 reactor' SCRAM. '

An historical assessment of SRM channel functionalitest data concluded.that the operability of the SRM: system will1not be

• affected by reducing:the: surveillance l frequency. - Monitoring ~- -

'the count rate recorded on:an SRM: channel once everyLtwelve (12) hours during refueling)as. required'by TS SP-4.9.2.c.2

~

verifies system operab 'ity.

Therefore, based on the evaluation described above,' reducing the SRM channel functional test' surveillance frequency does not '

~

involve a reduction in a margin of safety.

Information Suonortina an-Environmenta1' Assessment An environmental _ assessment ;is not reqdired' forLthe change '

proposed by this Change Request'because the requested 1changeito.the.

LGS, Units'1'and 2, TS' conforms to the criteria fort"act' ions eligible for categorical exclusion" as specified in 10(CFR

51. 22 (c) (9) . Therrequested. change will havefnoJimpactionLthe-environment. The proposed changeidoes notLinvolve alsignificantL hazards consideration as discussed-in1the1preccilingjsection. --The-  :

proposed change does not involve at significantLciangelin the types; 1

( or.significant-increase'in the: amounts of:any7eff.uents-that1may be.

4

released offsite. In addition,:-the proposed-changWidoes noti

)

involve an increase in individual.or cumulati*;&. occupational

~

'l radiation exposure.

Conclusion 1The Plant Operations' Review Committee and the. Nuclear: Review' Board have revlewed this. proposed-change;to the-LGS,; Units 1 and 2, TS and have concluded that,it:does not involveLan unreviewed--safety' question, or-a significant hazards consideration, Hand?will note

-endanger the health and safetyEof the:public.

I l

.q i

L mmI____ _ _ ______ w m-,s , t,$ , , . ,