ML20073S776
| ML20073S776 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/30/1994 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20073S778 | List: |
| References | |
| NUDOCS 9407060183 | |
| Download: ML20073S776 (8) | |
Text
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Ctstlan !!u;pset Deosetmsnt 10CFR50.90 a
q5h YECO ENERGY t7f men,
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9cs cwww aw-o Wayne, f% 19387M91 June 30,1994 Docket No. 50-353 License No NPF-85 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Limerick Generating Station, Unit 2 Technical Specifications Change Request No. 93M 2 Gentlemen:
PEW Energy Company is submitting Technical Specifications (TS) Change Request No. 93M 2, in accordance with 10 CFR 50.90, requesting an amendment to the TS (AppendN A) of Operating License No.
NPF-85 for Limerick Generating Station (LGS), Unit 2. This proposed TS change will remove certain remote shutdown system controf valves and primary containment isolation valves from TS Tables 3.3.7.4 t and 3.6.3-1 respectively, as a result of eliminating the steam condensing mode of the Residual Heat Removal (RHR) system. Information supporting this Change Request Is contained in Attachment 1 to this letter, and the proposed replacement pages for the LGS Unit 2 TS are contained in Attachment 2.
We request that, if approved, the amendment to the LGS Unit 2 TS be effective by January 28,1995.
If you have any questions, please do not hesitate to contact us.
Very truly yr Q.
George Hunger, Jr.
Director Licensing Attachments cc: T. T. Martin, Administrator, Region I, USNRC w/ attachments N. S. Perry, USNRC Senior Resident inspector, LGS w/ attachments R. R. Janati, Director, PA Bureau of Radiological Protection w/ attachments
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9407060183 940630 DR ADOCK 05000353 u(,
8 COMMONWEALTH OF PENNSYLVAMA:
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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 Ennrgy Compsny; the Applicant herein; that he has read the foregoing Application for Amendment of Facility Operating License No. NPF 03 (Technical Specifettions Change Reques' No. 93M-2) to c'elete c6ttain primary contalement isolation valves and remote shutdown system control valves as a result of eliminating the steam condensing mode of the RHR syst9m at Limerick r
Generating Station Unit 2, ard knows the contents thereof; ar/1 that the statements and matters set forth therein are true and coirect to the best of his knowledge, information and befef.
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F Vice President I
Subscribed and sworn to before me this ay of A
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Notary Public N:xant Seal FA:s A Santon, Notay %
Tred WCom#nnTe Chester eo Erpes JJy 10. C95
w ATTACHMENT 1 LIMERICK GENERATING STATION UNIT 2 Docket No. 50-353 License No. NPF 85 TECHNICAL SPECIFICATIONS CHANGE REQUEST No. 93-06-2
- Delete Certain Primary Containment Isolation Valves and Remote Shutdown System Control Valves as a Result of Eliminating the Steam Condensing Mode of the Residual Heat Removal System - Unit 2*
Suppotiin0 Information for Changes - 5 pages
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Docket No. 50 353 License No. NPF-85 PECO Energy Company, Licensee under Facility Operating Ucense No. NPF-85 for Umorick Generating Station (LGS), Unit 2, requests that the Technical Specifications US) contained in Appendix A to the Operating Ucense be amended as proposed herein, to remove certain remote shutdown systein control valves and primary containment isolation valves from TS Tables 3.3.7.41 and 3.6.31 respectively, as a result of eliminating the steam condensing mode of the Residual Heat Removal (RHR) system. The proposed changes to the TS are indicated by the vertical bars in the margin of the TS pages 3/4 3 80,3/4 6 29 and 3/4 640. The TS pages showing the proposed changes are contained in Attachment 2.
We request that, if approved, the TS changes proposed herein be effective by January 28,1995, to facilitate implementation of these changes during the upcomag third Unit 2 refueling outage.
This TS Change Request provides a discussion 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 Environtnental Assessment.
Discussion and Descrintion of the Fr2 nosed Chances The function of the Residual Heat Removal (RHR) system steam condensing mode is to condense all of the steam genemted by the reactor core after a reactor SCRAM. The steam condensing mode has never been used at Limerick Generating Station (LGS), Unit 1 or Unit 2. Presently, a portion of the components that
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are exclusiveiy associated with this mode of the RHR system are abandoned in place, which renders the r cJe inoperable. However, routine preventive maintenance and surveNance testing continues to be
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required to be performed on various components that are exclusively sssociated with the steam condensing mode. These activities are time consuming and costly. Accordingly, a modification is planned to be performed during the upcoming third Unit 2 refueling outage expected to begin by January 28,1995, that will remove from service the remainder of the steam condensing mode components and will thereby eliminate any further iaquired testing of, or preventive maintenance on these components. These proposed changes involve the following.
Technical Specifications US) Table 3.3.7.41 will be revised to show the removal of controls for the following remote shutdown system control valves.
RHR heat exchanger discharge line to suppression pool valve:
HV 51-2F011 A RHR heat exchanger discharge line to Reactor Core Isolation Cooling (RCIC) system valve:
HV 512F02(.A Steam supply line to P.MTi iivat exchanger vatw:
HV-512F052A Steam suppy line to RHR heat exchanger warm-up bypate, valva:
HV-512HA
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l Docket No. 50-353 I
License No. N*F-85 These valves are not containment isolation valves and will be abandoned in place, locked closed, with the electrical power removed. The valves' handswitches, which are part of the remote shutdown panel (RSP) controls, will be physically removed from the RSP, since they will not perform any function and the TS surveillance reautrements do not apply.
The piping associated with valves HV-512F052A and HV 51-253A will be cut and steel plates will be welded at the ends, isolating the RHR system from the High Pressure Coolant injection (HPCI) system steam supply line. These valves are not belng used presently in Unit 2, and the interfacing systems are not impacted by these changes. The operation of RCIC, RHR or HPCI systems will not be affected by these changes.
i TS Table 3.6.31 will be revised to show the deletion of certain Primary Containment Isolation Valves (PCIVs) as described below.
The following RHR system, steam-condensing mode, pressure safety (i.e., rollef) valves will be physically removed from the plant and replaced by blank flanges.
PSV 51201 A (B)
PSV-512F055 A(B)
PSV-512F097 Primary containment penetration X 240 associated with valve PSV-51-2F097 will be capped and will become part of the primary containment structure. The portion of piping between the primary containment and the flanges replacing the PSVs, will not be affected and will continue to meet the original design requirements.
The RHR vacuum relief suction inboard PCIV HV 51230 and the associated piping leading up to the associated outboard PCIV HV-51-231 will be physically removed from the plant. Valve HV-51231 will be abandoned in place, in the closed position with the electrical power removed. The associated primary containment penetration (i.e., X 225) will be capped, as well as the piping upstream of HV 51 231. This valve will not be a containment isolation valve following these modifications (i.e., capping penetration X-225). The associated piping will continue to meet the original design requirements.
The components associated with the steam condensing mode of the RHR system are Selsmic Category 1, but have no safety-related function (i.e., no credit is taken in the Updated Final Safety Analysis Report (UFSAR) for this mode of the RHR to mitigate an accident). However, the RHR system piping and valves associated with this modo are safety-related for pressure and structural integrity. All valves to be removed from service or abandoned in place, are designed only for the RHR system steam condensing mode. The operation or safety-related function of the RHR or HPCI systems will not be affected by these changes. The flanges and penetration caps that will become part of the primary containment boundary will be periodically tested for leakage in accordance with the primary containment Integrated Leak Rate Testing (ILRT) Program at LGS. Therefore, we propose that TS Tables 3.3.7.41 and 3.6.3-1 be changed to reflect the removal of certain remote shutdown system control valves and PCIVs from Unit 2, as well as the corresponding l
changes to the primary containment pressure boundary, TS Table 3.6.31, page 3/4 6 29, will also be revised to correct a typographical error in the table heading for the PCIVs* maximum isolation time; specifically, reference should be made to Note 26 instead of Note 36 as currently shown.
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Docket No. 50-353 License No. NPF-85 Safety Assessmen_t The Residual Heat Removal (RHR) system steam condensing mode is a non-safety related function of RHR; however, the pressure ond structural integrity of the piping and valves are safety related. The proposed changes will not affect any components required to perform the safety-related function of the RHR or H'gh Pressure Coolant injection (HPCl) systems.
The ability of the RHR and HPCI systems to respond to an accident will not be degraded by these proposed changes. The proposed changes will have no impact on the existing High Energy Line Break (HELB) analysis for Limerick Generating Station (LGS), Only valves specifically dedicated for use for the RHR system steam condensing mode will be abandoned in-place, or removed from the plant. The valves' handswitches, which are part of the remote shutdown panel (RSP) controls, will be physically removed from the RSP, since they will not perform any function (i.e., the associated valves will have the electrical power removed). The other modes of RHR (e.g., Low Pressure Coolant injection (LPCI), Shutdown Cooling (SDC))
-111 not be affected by these preposed changes.
All safety-related flanges and pp caps added to the safety-related portions of piping for the RHR and HPCI systems, and the primary contalument penetration caps will be fabricated and installed in accordance with the original design requirements, i.e., the Amerix.n Society of Mechanical Engineers (ASME) Boller arn 1
Pressure Vessel (B&PV) Code, Section lit, Cir,s 2,1971 Edition wu Addenda through Wintu 1971, All
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piping and components that will remain oper;.
- ill continue to meet the original design requirements.
The flanges and penetration caps that will be..me part of the primary containment boundary will be periodically tested for leakage in accordance with the primary containment integratcd Leak Rate Testing (ILRT) Program at LGS.
The planned modification will also result Ire downgrading the portien of RHR system piping abandoned in place, frcm safety related to non-safety related, since this piping will no longer be a part of the primary containment p essure boundary and will be isolated from the RHR and HPCI systems. All pipe caps and 4
plates added to these downgraded portions of piping will be designed, fabricated, and installed in accordance with the requirements of American National Standards Institute (ANSI) standard B31.1 Power Piping Code - 1973 Edition and Addenda through Winter 1974. This piping will be quallfled to meet, as a minimum, Seismic Category llA requirements.
Information Succortino a Findina of No Slanificant Hazards Consideration We have concluthd that the proposed changes to the Umerick Generating Station (LGS), Unit 2, Tee /alcal Specifications (TS), vhich remove co ialn remote shutdown system control valves and primary containment isolation valves from *S Tables 3.0.7.41 and 3.6.3-1 respectively, as a result of eliminating the steam condensing mode of the Residual Heat Removal (RHR) system, do not involve a Significant Hazards Consideration in support of this determnistion, an evaluation of each of the three (3) standards set forth In 10CFR50.92 is provided below.
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Docket No. 50-353 License No. NPF 85
- 1. The crocosed Technical SoecificaFons (TS) chances do not involve a slanificant increase in the orobabilltv or conseauP3JLQ fn accident oreviously evaluated.
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'ihese proposed changes will result in abandoning in place certain remote shutdown system control valves and removing from service and abandoning in place certain Primary Containment isolation Valves (PCIVs) associated with the Residual Heat Removal (RHR) system steam condensing mode, and will remove the Interface between the High Pressure Coolant injection (HPCI) and RHR systems, therefore changing the primary containment pressure boundary.
The RHR cystem steam condensing mode is a non-safety related function of the RHR system; however, the pressure and structeral integrity of the associated piping and valves are safety-related.
These proposed changes will no: affect any components required to perform the safety-related function of the RHR or HPCI syst9ms.
The ability of the RHR c HPCI systems to respond to an accident will not be degraded. Only valves specifically dedicated for use for the RHR system steam condensing mode will be abandoned in-place, or removed frvm the plant. The valves' handswitches which are part of the remote shutdown panel (RSP) controis, will be physically removed from the RSP, since they will not perform any function (i.e., the associated valves will have the eiectrical power removed). The flanges and penetration caps that will become part of the primary containment boundary wl!! be periodically tested for leakage as required by TS and 10CFR50, Appendix J. All piping and components that will remain operable will meet the original design requirements. The other modes of operation of the RHR system (e.g., Low Pressure Coolant injection (LPCI), Shutdown cooling (SDC)) will not be affected by these changes. Therefore, the proposed TS changes do not involve an increase in the probability or consequences of an accident previously evaluated.
2.
The orocosed TS chanaes do not create the oossibility of a now or different kind of accident from any accident meviousiv evaluated.
No new failure modes of RHR or HPCI systems are crcated by the proposed TS changes. The proposed changes will have no impact on the existing High Ene gy Line Break (HELB) analysis for Umerick Generating Station (LGS). All valves or piping removed and/or abandoned in place, are dedicated specifically for the RHR system steam condensing mode, and will not affect the operation of any components or piping required for other modes of opera %n of the RHR or HPCI systems.
Therefore, the proposed TS changes do not create the possibi, of a new or different kind of accident from any previously evaluated.
3.
The crocosed TS chanaes do not involve a sianificant reduction in 1arain of safety.
The steam condensing mode is a non-safety related function of the RHR system and, therefore, is not addressed in the TS. This mode will be physically separated from the other modes of operation of RHR and HPCI systems, and consequently, will not preclude them from performing their safety-related functions. The remote shutdown system control valves to be abandoned in place are not being used presently, and the proposed changes will not impact the safe operation of LGS Unit 2.
The primary containment penetration caps, safety-related pipe caps and the flanges replacing the removed PCIVs will be designed, fabricated and installed in accordance with 'he original design requirements, i.e., American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code. Section ill,1971 Edition with Addenda through Winter iv71. The added penetration _
Docket No. 50453 License No. NPF-85 caps and flanges will be capable of maintaining the primary containment pressure boundary and isolation capabilities that were required of the PCIVs and will be tested for leakage periodically, as required by TS and 10CFR50, Appendix J. Additionally, all piping and components that will remain operable will meet original design requirements. Therefore, the proposed TS changes do not involve a reduction in a margin of safety.
Information Sucoortina an Environmental Assessment An environmental assessment is not required for the changes proposed by this Change Request because the sequested changes to the Limerick Generating Station (LGS), Unit 2 TS conform to the criteria for
'actioris eligible for categorical exclusion,' as specified in 10CFR51.22(c)(9). The requested changes will have no impact on the environment. The proposed changes do not in' olve a significant hazards ennsideration as discussed in the preceding section. The proposed changes do not involve a significant change in the types or signiGcant increase in the amounts of any effluents that may be released offsite. In addition, the proposed changes do not involve a significant increast in individual or cumulative occupational radiation exposure.
Conclusion The Plant Operations Review Committee and the 'Nclear Review Board have reviewed these proposed changes to the Limerick Generating Station (LGS), Unit 2 TS and have concluded that they do not involve an unreviewed safety question, and will not endanger the health and safety of the public. -
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