ML20070D960

Responds to Request for Addl Info Re Power Rerate Program

ML20070D960
Person / Time
Site:	Limerick
Issue date:	07/05/1994
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9407130229
Download: ML20070D960 (5)

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9S5 Chesterbrook Boulevard i Wayne. PA 19087 5691 July 5,1994 i Docket Nos. 50-352 l I

50-353 Ucense Nos. NPF-39 I NPF-85 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Limerick Generating Station, Units 1 and 2 Response to Request for Additional Information Regarding Power Rerate Program dated June 4,1994 (RAl-1)

Gentlemen:

Attached is our response to your Request for Additional Information (RAI) dated June 4,1994 regarding our planned implementation of the Power Rerate Program at Limerick Generating Station (LGS), Units 1 and 2. The Power Rerate Program is the subject of Operating Ucense Change Request No. 93-24-0 which was forwarded to you by letter dated December 9,1993.

If you have any questions, please do not hesitate to contact us.

Very truly yours, 2d.

G. A. Hunger, Jr f

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Director - Ucensing Attachment cc: T. T. Martin, Administrator, Region I, USNRC - w/ attachment N. S. Perry, USNRC Senior Resident inspector, LGS - w/ attachment R. R. Janati, Director, PA Bureau of Radiological Protection - w/ attachment

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COMMONWEALTH OF PENNSYLVANIA  :

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COUNTY OF CHESTER  :

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W. H. Smith, Ill, being first duly sworn, deposes and says: l l

That he is Vice President of PECO Energy Company; the Applicant herein; that he has l

read the enclosed response to the NRC Request for Additional Information dated j June 4,1994, concerning Operating License Change Request (No. 93-24-0) for Limerick Generating Station Facility Operating License Nos. NPF-39 and NPF-85, 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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W Vice President Subscribed and sworn to before me thisd-4A. day of 1994.

Notary Public En A ( Putac

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Docket Nos. 50-352 50-353 Ucense Nos. NPF-39

- NPF-85 RESPONSE TO REQUEST FOR ADDITIONAL !NFORMATION (RAl-1)

LIMERICK GENERATING STATION, LINITS 1 AND 2 Duration A*

Sur submittal for power uprate does not discuss the instrument setpoint muhodology. The staff is unable to determine whether the GE setpoint methodology discussr,d in GE Topical Report NEDC-31336 was used, or a plant-specif!c setpoint methodology has been used for this application.

Resoonse A:

Section 5.1.3, " Instrument Setpoints", of NEDC-32225P, " Power Rerate Safety Analysis ,

Report for Limerick Generating Station Units 1 & 2," dated September,1993, discusses the instrument setpoints affected by the Power Rerate Program. Changes to inctrument setpoints discussed in Section 5.1.3 were determined using the General Electric Company (GE) instrument setpoint methodology discussed in NEDC-31336,

" General Electric Instrument Setpoint Methodology," dated October,1986. Limerick Generating Station is one of the original plants, for which the GE instrument setpoint methodology was developed and applied.

I The Reactor Pressure Vessel (RPV) High-Pressure Scram, RPV High-Pressure l Recirculation Pump Trip (RPT), Neutron Monitoring System (Flow-biased Average Power Range Monitor (APRM) Rod Block and APRM High Flux Scram), and Main Steam High Flow Isolation instrument setpoints were determined by plant specific calculations using the GE instrument setpoint methodology. The analytical limits for these setpoints are provided in Table 5-1 of NEDC-32225P.

The Safety / Relief Valves and Main Steamline High Radiation Scram are ' cased on qualitative discussions provided in Section 5.1.3 of NEDC-32225P and are consistent with GE instrument setpoint methodology.

The GE setpoint methodology was not used in establishing the Pressure Regulator setpoint which is a controller setting adjusted by the Reactor Operator to maintain turbine inlet pressure within its required operating range. This setpoint was developed as described in Section 5.1.3 of NEDC-32225P.

Question B:

If a plant-specific setpoint methodology is used, then provide the fo' lowing information:

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

- NPF-85

1. Setpoint methodology and how it differs from NEDC-31336.

2. Reference the setpoint methodology in the report.

3. Provide calculations and related documents that were utilized to derive the new trip setpoint and allowable values for the following parameters:

a. reactor vessel steam dome pressure, high.

b. flow biased simulated thermal power, high.

c. main steam line flow, high.

Resoonse B:

As discussed in the response to Question A, the GE instrument setpoint methodology discussed in NEDC-31336 was used to determine the changes to instrument setpoints affected by the Power Rerate Program, except for the Pressure Regulator controller setting.

Duestion C:

If the GE setpoint methodology is used, then provide the following information:

1. Reference the GE topical report in this report.

2. Y staff's Safety Evaluation Report on GE Topical Report NEDC-31336, k-N iled certain plant-specific information needed to justify the application of j the report. Provide a discussion regarding the applicability of the topical report. l l

l 3, Confirm that the calculation for the instrument setpoint is identical to the plant which was previously reviewed by the staff for power uprate. If not, then justify the differences. 1 Resoorse:

1. The RPV High-Pressure Scram, RPV High-Pressure RPT, Neutron Monitoring System (Flow-biased APRM Rod Block and APRM High Flux Scram), and Main Steam High Flow isolation instrument setpoints were determined by plant specific calculations using the GE instrument setpoint methodology discussed in NEDC-31336. The Safety / Relief Valves and Main Steamline High Radiation Scram instrument setpoints are based on qualitative discussions provided in Section 5.1.3 of NEDC-32225P and are consistent with GE instrument setpoint methodology.

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Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85

2. The Safety Evaluation Report for NEDC-31336 identifies certain plant-specific information needed to justify the applicability of NEDC-31336 to individual plants.

Limerick Generating Station is one of the original plants for which the GE instrument setpoint methodology was developed and applied. The instrument setpoints listed in Response C.1 above were determined using plant specific analysis consistent with NEDC-31336. This plant specific information includes analyses which address instrumentation, environments, seismic conditions, and other requirements, as appropriate.

The Safety Evaluation Report for NEDC-31336 identifies plant-specific information needed for plants that have safety relief valves that vent directly into containment or use instruments that are different from those presented in NEDC-31336. The plant specific calculations for Limerick Generating Station Units 1 and 2 address the environmental effects on instrument accuracy and process measurement for the environments expected for the time that the specific trip functions are required. For Limerick Generating Station Units 1 and 2, the instruments used to generate the trip functions listed in Response C.1 above, are similar to the instruments used for the same trip functions evaluated in NEDC-31336.

3. The instrument setpoints listed in Response C.1 above were determined using plant-specific calculations performed by GE in accordance with NEDC-31336.

Limerick Generating Station is one of the original plants for which the GE instrument setpoint methodology was developed and applied. The plant specific calculations for the Neutron Monitoring System (Flow-biased APRM Rod Block and APRM High Flux Scram) include implementation of the APRM/RBM Technical Specification Improvement (ARTS) Program and Maximum Extended Load Line Limit (MELLL) operation. ARTS /MELLL was developed after issuance of NEDC-31336. ARTS /MELLL has been incorporated in the plant specific instrument setpoint calculation in acccrdance with the methodology discussed in NEDC-31336. ARTS /MELLL has been approved for implementation at LGS, Units 1 and 2, via SER issued by NRC on February 10, 1994 and has been implemented at LGS Unit 1 during the fifth refueling outage in the first quarter of 1934.