ML20071J535

TS Change Request 94-26-0 to Licenses NPF-39 & NPF-85, Removing Surveillance Frequency Details Governing 10CFR50, App J, 'B' & 'C' Type Testing from TS & Requests one-time Schedular Exemption from 10CFR50,App J

ML20071J535
Person / Time
Site:	Limerick
Issue date:	07/22/1994
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20071J538	List: ML20071J535 ML20071J540
References
NUDOCS 9407280246
Download: ML20071J535 (10)

Text

. ., Statlin Cupp;rt Depirimint _ ,

.10 CFR 50.90 1

d. __ _ 10 CFR 50.12 '

PECO ENERGY recoe eovcema v Nuclear Group Headquarters 965 chesterbrook Boulevard l Wayne, PA 19087-5691 1

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July 22,1994 Docket Nos. 50-352  ;

50-353 l License Nos. NPF-39 [

NPF-85 r

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 [

Subject:

Limerick Generating Station, Units 1 and 2  ;

Technical Specifications Change Request No. 94-26-0  !

and Request for Exemption .[

Gentlemen: l PECO Energy Company is submitting Technical Specifications (TS) Change Request No. 94 J 0, in accordance with 10 CFR 50.90, requesting a change to the TS (i.e., Appendix A) of l Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and t

2. In addition PECO is requesting a one-time schedular exemption, for LGS Unit 2, from 10 CFR j 50, Appendix J, " Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors,' in accordance with 10 CFR 50.12(a). >

TS Change Request No. 94 26-0 involves the removal of surveillance frequency details governing 10 CFR 50, Appendix J. 'B' and 'C' Type testing from TS. The Request for Exemption involves  ;

exemption from the two year test interval for Type 'B' and 'C' leak rate tests required by 10 CFR 50, Appendix J, Sections Ill.D.2(a) and Ill.D.3. l Information supporting this TS Change Request and Exemption Request is contained in Attachment 1 to this letter, the proposed replacement pages for the LGS TS are contained in Attachment 2, and the list of surveillance tests for which the exemption would apply is contained I in Attachment 3.  :

We request that, if approved, this TS Change Request for LGS, Units 1 and 2, and request for exemption for LGS Unit 2, be approved prior to January 24,1995 In support of the current surveillance interval end dates. ]

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truly yours, j JVe .

• G. A. Hunger, Jr.

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Director - Licensing i Attachments

.t Enclosure ,

i cc: T. T. Martin, Administrator, Region I, USNRC (w/ attachments and enclosure)  !

N. S. Perry, USNRC Senior Resident inspector, LGS (w/ attachments and enclosure)  :

R. R. Janati, PA Bureau of Radiological Protection (w/ attachments and enclosure)  ;

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CC,MMONWEAl.TH OF PENNSYLVANIA  :

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• COUNTY OF CHESTER  : ,

W. H. Smith, Ill, being first duly sworn, deposes and says: That he is Vice President of PECO Energy Company, the Applicant herein; that he has read the  !

enclosed Technical Specifications Change Request No. 94-26-0 " Removal of  !

l Surveillance Frequency Details Governing 10 CFR 50, Appendix J, 'B' and 'C' Type I Testing from Technical Specifications," for Limerick Generating Station, Unit 1 and l i

Unit 2, Facility Operating Ucense 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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Vice President  ;

Subscribed and sworn ,

before me this M day of 1994.

f aNotary Public . ,-

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" of Sion $xpe 495

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i ATTACHMENT 1  :

i LIMERICK GENERATING STATION UNIT 1 AND UNIT 2 j Docket Nos.  !

50-352 50-353 l i

Ucense Nos.  ;

NPF-39 i NPF-85 l TECHNICAL SPECIFICATIONS CHANGE REQUEST '

i NO. 94-26-0 AND EXEMPTION .l i

" Removal of Surveillance Frequency Details Governing 10 CFR 50,  ;

Appendix J, 'B' and 'C' Type testing from Technical Specifications and -I Request for Exemption From the Two Year Test Interval for ,

Type 'B' and 'C' Leak Rate Tests."  !

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Supporting information for Changes and Exemption - 6 PAGES i

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l PAGE1 PECO Energy Company, licensee under Facility Operating License 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 License be amended, as proposed herein, to remove surveillance frequency details governing 10 CFR 50, Appendix J, 'B' and 'C' Type testing from TS, prior to January 24,1995. In addition, coincident with the TS Change request, PECO requests a one-time Exemption from the two year test interval for Type 'B' and 'C' leak rate tests required by 10 CFR 50, Appendix J, Sections Ill.D.2(a) and Ill.D.3. This TS Change Request and Exemption Request are necessary to continue Unit 2 operation within its 24 month operating cycle, until its scheduled third refueling outage, scheduled to begin January 28,1994.

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

Discussion and Descriotion of the Prooosed TS Changes The proposed activity requests a permanent change to the TS for LGS, Units 1 and 2, to remove repetitious surveillance details from TS Sections 4.6.1.2.d,4.6.1.2.f, and 4.6.1.2.h, which are also found in 10 CFR 50, Appendix J, Sections Ill.D.2(a) and Ill.D.3. The rewording is considered a presentation preference which is administrative in nature. This proposed presentation is in accordance with NUREG-1433, " Standard Technical Specifications." This change is requested in coincidence with a Request for Exemption to support the third, Unit 2, operating cycle.

Safety Assessment The proposed TS change involves rewording of the LGS TS. These changes, since they do not involve technical changes to the TS, are administrative.

Information Suocortino a Finding of No Significant Hazards Consideration We have concluded that the proposed changes to the Limerick Generating Station, Unit 1 end Unit 2, Technical Specifications, which will remove repetitious surveillance details from TS, do not involve a Significant Hazards Consideration. In support of this determination, an evaluation of each of the three (3) stardards, set forth in 10 CFR 50.92 is provided below.

1. The orocosed Technical Soecifications changes do not involve a significant increase in the orobability or consecuences of an accident oreviously evaluated.

The proposed changes involve the removal of repetitious surveillance details from TS also found in 10 CFR 50, Appendix J, and rewording of TS. The removal and rewording involves no technical changes to the existing TS. The .

changes to the existing TS are proposed in order to be consistent with NUREG-1433. During the development of NUREG-1433, certain wording preferences or English language conventions were adopted. The proposed changes to this TS l

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PAGE 2 section are administrative in nature and do not impact initiators of analyzed events. They also do not impact the assumed mitigation of accidents or transient events. Therefore, the changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. The orocosed TS chanaes do not create the oossibility of a new or different kind of accident from any accident oreviously evaluated.

The proposed changes do not involve a physical alteration of the plant or changes in methods governing normal plant operation. The proposed changes will not impose any new or different requirements or eliminate any existing requirements. Therefore, the changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. The orocosed TS chances do not involve a significant reduction in a margin of safety.

The changes are administrative in nature and will not involve any technical changes. The proposed changes wili not reduce a margin of safety because they have no impact on any safety analysis assumptions. In addition, because the changes are administrative in nature, no question of safety is involved.

Therefore, the changes do not involve a significant reduction in a margin of safety.

Conelysion of TS Change Request The Plant Operations Review Committee 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 unreviewed safety question.

.plscussion and Justification For Exemotion Request An exemption from 10 CFR 50, Appendix J, is necessary due to a schedular difference between the Unit 2 end of third cycle shutdown date, and the expiration date of certain (specified in Attachment 3) Type 'B' and 'C' test intervals. Sections Ill.D.2(a) and Ill.D.3 of 10 CFR 50, Appendix J, require that Type 'B' and 'C' containment penetration leak rate tests shall be performed at intervals no greater than two years. The next LGS, Unit 2 refueling shutdown is scheduled to begin January 28,1995. Therefore, PECO Energy Company requests a one-time (i.e., temporary) schedular exemption from these requirements for the Limerick Generating Station (LGS), surveillance tests (STs) identified in Tables 1,2,3, and 4, of Attachment 3 for varying durations of 1 to 26 days, depending on the particular test contained in Attachment 3. The Tables in Attachment 3, are grouped by 7 day periods, where Table 1 contains the two year intervals that will expire prior to January 28,1995, and Table 2,3, and 4 contain the test intervals that will expire in the periods that follow, up to February 19,1995. Due to shutdown schedule changes and / or in anticipation of poor weather conditions, resulting in the need for continued Unit 2 operation, similar to the conditions PECO  !

PAGE 3 experienced at the beginning of 1994, we are including Tables 2,3, and 4 which list penetrations whose two year test intervals will expire, if not tested between January 28,1995 and February 18,1995. If granted, extension will be applied to the current expiration date of each ST listed on Tables 1, 2,3, and 4, not to exceed February 19, 1995. j l

Exemptions are being requested in order 1) to avoid an extended reactor shutdown in I order to comply with the two year testing interval, and 2) to allow for shutdown I scheduling flexibility following the third, Unit 2, operating cycle. LGS Unit 2 is now l utilizing a new core design which allows the intervals between reactor shutdowns for refueling to extend beyond the maximum-allowable, two-year testing period. Prior to the current operating cycle, local leak rate tests were performed in conjunction with an 18 month refueling cycle. Use of the extended-cycle, core designs has been recognized as a growing trend in the industry as discussed in Generic Letter 91-04,

" Changes in Technical Specification Surveillance intervals to Accummodate a 24-Month Fuel Cycle," dated April 2,1991.

Attachment 3 contains a list of the 22 leak rate tests where the two-year interval will expire prior to January 28,1995 and 46 additional tests which have the potential to expire, prior to shutdown, due to unforeseen shutdown schedule changes. PECO Energy requests exemption for all 68 tests for a period not to exceed February 19, 1995 (i.e.,1 to 26 days). Performance of these tests at the scheduled two-year ,

interval would result in undue financial hardship with little or no compensating increase in the level of safety or quality. Extending the testing interval no more than 26 days will not significantly impact the integrity of the containment boundary and, therefore, would not significantly impact the consequences of an accident or transient in the unlikely occurrence of an event during the 26 days of power operation. This minimal impact on primary containment integrity has been further reduced through the demonstration of a large margin in primary containment integrity, described below.

A large margin in primary containment integrity can be demonstrated by review of the total Type 'B' and 'C' minimum pathway leak rates. The Unit 2, as-left, minimum pathway leak rates, following the second, Unit 2 refueling outage, was .13 L, or 20,625 standard cubic centimeters per minute (sccm) (including contributions from the Main Steam Isolation Valves (MSIVs)), with a maximum pathway leak rate of .27 L, or 42,502 sccm (excluding MSIV leakage in accordance with LGS's current Appendix J, Exemption). These as-left, leak rates represent a significant margin to the maximum-allowable patilway leakage (i.e., L,.) of 158,273 sccm. Extending the two-year interval an additional 1 to 26 days for any one specified ST contained in Attachment 3, not to exceed February 19,1995, would not be expected to significantly reduce this margin, even considering the extended operating cycle, to the point that primary containment integrity would be violated.

The NRC may, upon application, grant exemptions from the requirements of 10CFR50, where special circurnstances are present.10 CFR 50.12(a)(2)(ii) defines such a circumstance where, " Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule..." The underlying purpose of 10 CFR 50, Appendix J,

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. l PAGE 4 Sections lil.D.2(a) and Ill.D.3, is to establish and maintain a level of confidence that any primary containment leakage, during a hypothetical design basis accident, will remain less than or equal to the maximum allowable value, L , established by  :

10CFR50, Appendix J, by performing periodic Type 'B' and 'C' testing.10CFR50, i Appendix J, requires that the Unit 2, Type 'B' and 'C' tests be performed at intervals no greater than two years. This is not necessary to achieve the underlying purpose of the rule, as explained in the above technical justification. The technical justification supports the conclusion that the requested schedular exemption to extend specified, Unit 2, Type 'B' and 'C' test intervals, no more than 26 days, will maintain the same level of confidence that any Unit 2 primary containment leakage will remain less than or equal to the maximum allowable leakage rate value, L , during the proposed one-time extension.

10 CFR 50.12(a)(2)(iii) states that the NRC may grant exemptions from requirements of 10 CFR 50 where, " Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted, or that are significantly in excess of those incurred by others similarly situated..." The current ,

LGS Unit 2, Type 'B' and 'C' test schedule established by 10 CFR 50, Appendix J, Sections Ill.D.2(a) and Ill.D.3, will require that Unit 2 be shutdown prematurely during its current fuel cycle schedule. This current testing schedule will result in unnecessary '

costs associated with an increase in the refueling outage length due to planned outage activity constraints. Use of the extended-cycle, core designs has been recently recognized as a growing trend in the industry as discussed in Generic Letter 91-04. ,

Finally,10 CFR 50.12(a)(2)(v) states that the NRC may grant exemptions from requirements of 10 CFR 50 where, "The exemption would provide only temporary relief from the applicable regulation and the licensee or applicant has made good faith efforts to comply with the regulation..." The requested exemption would provide only temporary relief pertaining to specified (contained in Attachment 3) third operating cycle, Unit 2, Type 'B' and 'C' test intervals, and as stated above, the underlying purpose of the rule is achieved.

Information Supportina an Environmental Assessment An Environmental Assessment is not required for the Technical Specifications changes proposed by this Change Request because the requested changes to the Umerick Generating Station, Units 1 and 2, TS conform to the criteria for " actions eligible for categorical exclusion," as specified in 10 CFR 51.22(c)(9). The requested change will have no impact on the environment. The proposed TS changes do not involve a Significant Hazards Consideration as discussed in the preceding safety assessment section. The proposed changes do not involve a significant change in the types or significant increase in the amounts of any effluent that may be released off-site, in addition, the proposed TS changes do not involve a significant increase in individual or i cumulative occupational radiation exposure.  !

With respect to the requested exemption for LGS, Unit 2, the following information is i l provided to support an Environmental Assessment.

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Identification of Proposed Action The proposed action is to grant an exemption from 10 CFR 50, Appendix J, Sections Ill.D.2(a) and Ill.D.3, which require that Type 'B' and 'C' containment penetration leak rate tests be performed during reactor shutdown for refueling, or other convenient intervals, but in no case greater than two years. This one-time exemption would allow the two year interval to be exceeded by no more than 26 days, for the Licensee specified penetrations contained in Attachment 3.

The Need for the Proposed Action b

The requested exemption is needed because the requirements of 10 CFR 50, Appendix J, would require that the 10 CFR 50, Appendix J, Type 'B' and 'C' tests be ,

performed at a time inconvenient with respect to the Unit 2 shutdown schedule, resulting in unneccssary costs associated with an increase in the refueling outage length due to planned outage activity constraints. In addition, the proposed action will provide shutdown scheduling flexibility and add contingencies for unforeseen outage work changes and weather restrictions.  ;

Environmentalimpacts of the Proposed Action The requested exemption would not significantly increase the probability of exceeding the maximum allowable value of expected primary-containment leakage (i.e., L ,  ;

established by 10 CFR 50, Appendix J), during a hypothetical design basis accident; i therefore, the primary containment integrity would be maintained. Although the requirements in 10 CFR 50, Appendix J, Sections Ill.D.2(a) and Ill.D.3 state that Type i

'B' and 'C' tests shall be performed at two-year intervals, we have concluded that i performing the Type 'B' and 'C' tests for the specified penetrations no more than 26 days beyond two years for any specified test contained in Attachment 3, not to exceed February 19,1995, would meet the underlying purpose of the rule, that any primary ,

containment leakage during a hypothetical design basis accident will remain less than -

the maximum allowable leakage rate value, L., established by 10 CFR 50, Appendix J. l This determination was made based on the preceding demonstration of a large margin in primary containment integrity.

Accordingly, the consequences of an accident would not be increased, that is, the post-accident radiological releases would not be greater than previously determined. .

The requested exemption would not affect plant radiological effluents. Therefore, there  ;

are no significant, radiological-environmental impacts associated with the requested ,

exemption. With regard to potential non-radiological impacts, the requested exemption l involves a one-time schedular change to surveillance and testing requirements. It i does not affect non-radiological plant effluents and has no other environmental impact.  ;

Alternative to the Proposed Action  !

Since we have concluded that there is no significant environmental impacts associated with the requested exemption, any alternatives would have either no or greater environmental impact.

PAGE 6 The' principal alternative viould be to deny the requested exemption which would require the performance of 10 CFR 50, Appendix J, Type 'B' and 'C' tests, which would require a premature shutdown at a time inconvenient with respect to the Unit 2 refueling outage schedule. Thic would not reduce the environmentalimpact attributed to the facility as compared to the impact of granting the requested exemption.

Alternative Use of Resources This proposed exemption does not involve the use of any resources not previously considered in connection with the Noclear Regulatory Commission's Final Environmental Statement dated, April 1984, related to the operation of the Limerick i Generating Station, Unit 1 and Unit 2.

Information Supporting a Finding of No Significant impact We have concluded, based on the preceding environmental assescment, that the proposed action will not have a significant effect on the quality of the human environment, therefore, an environmental impact statement for the requested  !'

exemption would not be required.

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