ML20070N105
| ML20070N105 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/26/1994 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20070N103 | List: |
| References | |
| NUDOCS 9405050087 | |
| Download: ML20070N105 (3) | |
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UNITED STATES
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WASHINGTON, D.C. 20555-0001 SAFETY EVALVATION BY THE OFFICE OF NVCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 70 AND 33 TO FACILITY OPERATING LICENSE NOS. NPF-33 AND NPF-85 PHILADELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION. UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353
1.0 INTRODUCTION
By letter dated May 6, 1993, as supplemented by letter dated April 18, 1994, the Philadelphia Electric Company (PECo or the licensee) submitted a request for changes to the Limerick Generating Station (LGS), Units 1 and 2, Technical Specifications (TS).
The requested changes would extend surveillance test intervals (STIs) and allowed outage times (A0Ts) for selected actuation instrumentation based on " Bases for Changes to Surveillance Test Intervals and Allowed Out-of-Service Times for Selected Instrumentation Technical Specifications," GENE-770-06-1, February 1991, and as approved by NRC in
" Review of BWR Owners Group Report GENE-770-06-1 on Justification for Extending Surveillance Test Intervals and Allowed Out-of-Service Times for Selected BWR Actuation Instrumentation" dated July 21, 1992.
In addition, PECo proposes several editorial changes that correct previous omissions and reformat the TS. The supplemental letter does not change the proposed no significant hazards determination.
2.0 BACKGROUND
Licensing Topical Report (LTR), "BWR Owners Group Response to NRC Generic Letter 83-28, Item 4.5.3," General Electric Company, NEDC-30844, January 1985, provided justification for the acceptability of current Reactor Protection System (RPS) instrumentation.
In addition, the same report established a basis for extending STIs and A0Ts for RPS instrumentation ba~ sed on reliability analyses which estimate RPS instrumentation failure frequency. The analyses were further developed in GENE-770-06-1 for extending TS STIs and A0Ts for selected Boiling Water Reactor (BWR) Actuation Instrumentation, and the results were subsequently approved as detailed in an NRC safety evaluation dated July 21, 1992.
The staff's evaluation described the acceptability of both the analyses and the proposed TS changes provided to the NRC.
In addition, it provided criteria for plant-specific implementation of the generically-approved TS changes. The proposed editorial changes correct omissions to TS Sections 4.1.3.1.4 and 4.6.2.1, as a result of Change Request No. 89-16, dated April 26, 1990, and reformat TS 4.6.2.1(c) in two separate sections to identify currently proposed TS changes.
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, 3.0 EVALUATION The licensee has stated that the effect on safety of the proposed extensions to the STIs and A0Ts of the selected BWR actuation instrumentation has been addressed in GENE-770-06-1.
Furthermore, the NRC has detailed their acceptance of the analyses and the conclusions of GENE-770-06-1 in the July 21, 1992, safety evaluation.
The staff's evaluation concludes that implementation of the TS changes proposed in GENE-770-06-1 would provide an overall enhancement to plant safety and that the proposed changes are acceptable subject to the licensee documenting (1) plant-specific applicability, and (2) that instrument drift is bounded by the assumptions of the generic analyses. The licensee has addressed the acceptance conditions as follows:
1.
The licensee has conducted a plant-specific review of the applicability of the GENE-770-06-1.
For the selected BWR actuation instrumentation, the review compared the LGS configuration with those in the GENE-770-06-1 analyses.
This comparison concluded that the configurations are consistent with those in the GENE-770-06-1 analyses and thus the analyses are applicable to LGS, Units 1 and 2.
2.
In 1988, the NRC issued additional guidance regarding instrument drift.
The staff guidance letter stated that " licensees need only confirm that the setpoint drift, which could be expected under the extended STIs has been studied and either (1) has been shown to remain within the existing allowance in the RPS (for BWRs)... instrument setpoint calculation, or (2) that the allowance and setpoint have been adjusted to account for the additional expected drift." Present setpoint calculations for LGS are based on an 18-month calibration interval.
Therefore, drift occurring during a 3-month STI falls within the existing drift allowance.
To further verify this, the licensee has examined the instrument drift data of over three consecutive monthly test intervals.
" Limerick Generating Station, Unit 1, Instrument Drift Data for Selected Boiling Water Reactor Actuation Instrumentation," provides the as-found drift data on a 15%
sample of affected LGS, Unit 1 instrumentation.
This data provides actual verification that the drift occurring over three consecutive test intervals (i.e., one calendar quarter) is within the acceptable limits.
Further, the basis for this proposed change is not affected by the pending request to increase the STIs for certain instruments from a nominal 18-month frequency to a nominal 24-month frequency.
The staff finds that the licensee has demonstrated the applicability and acceptability of all proposed changes as stated above.
Therefore, the staff concludes that the changes proposed will minimize testing and relax restrictive A0Ts, while providing overall plant safety.
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, The proposed editorial changes that correct omissions for TS Change Request No. 89-16 and reformat TS 4.6.2.l(c) are found acceptable.
In TS Change Request No. 89-16, the licensee failed to include the necessary mark-up of TS Sections 4.1.3.1.4 and 4.6.2.1.
Therefore, the licensee is proposing to correct these omissions to eliminate the inconsistency between the 31-day STI currently required by TS Sections 4.1.3.1.4 and 4.6.2.1 and those which were approved in Amendments 53 and 17, currently shown in TS Tables 4.3.1.1-1 and 4.3.3.1-1, respectively.
The editorial change to TS 4.6.2.1(c) involves splitting this item into two separate items since the proposed changes apply only to the suppression chamber water level indicator and not the temperature indicators.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Pennsylvania State 1
official was notified of the proposed issuance of the amendments.
The State official had no comments.
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5.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.
The Commission has previously issued a proposed finding that the i
amendments involve no significant hazards consideration, and there has been no public comment on such finding (58 FR 34087). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
F. Rinaldi Date:
April 26, 1994