ML20080Q266
| ML20080Q266 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/01/1995 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20080Q268 | List: |
| References | |
| NUDOCS 9503080304 | |
| Download: ML20080Q266 (6) | |
Text
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Ctation Su; port Dep:rtmint A
10 CFR 50.90 PECO ENERGY
=rlf;it,;L 965 Chesterbrovk Boultuard Wayne, PA 19087-5091 March 1,1995 Docket Nos. 50452 50 353 Ucense Nos. NPF-39 NPF-85 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
SUBJECT:
Umerick Generating Station Units 1 and 2 Technical Specifications Change No. 94-02-0 Hydrogen and Oxygen Calibration Gas Concentrations Gentlemen:
PECO Energy Company is submitting Technical Specifications (TS) Change Request No. 94-02-0 in accordance with 10 CFR 50.90, requesting changes to the TS (i.e., Appendix A) of Operating Ocense Nos. NPF-39 and NPF-85 for Umerick Generating Station (LGS), Units 1 and 2.
These proposed changes will clarify the concentrations of calibration gas required to calibrate the Hydrogen and Oxygen Analyzers, and support the requirements of LGS Transient Response implementation Plan (TRIP) T-102, " Primary Containment Control Bases."
Information supporting this TS Change Request is contained in Attachment 1 to this letter, and the proposed replacement pages for the LGS TS are contained in Attachment 2. This TS Change Request is being submitted under affirmation, and the assoc!ated affidavit is enclosed.
We request that, if approved, the amendment for LGS, Units 1 and 2, be issued prior to September 1,1995 and become effective within 30 days of issuance.
If you have any questions, please do not hesitate to contact us.
Very truly yours, h
G. A. Hunger, Jr. (/
Director - Ucensing Attachments Enclosure 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) 9503080304 950301 PDR ADOCK 05000352
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j COMMONWEALTH OF PENNSYLVANIA ss.
COUNTY OF CHESTER W. H. Smith, I!l, being first duly sworn, deposes and says: That he is Vice Presidsnt of PECO Energy l
Company, the Applicant herein; that he has read the foregoing Technical Specifications Change Request i
No. 94-02-0, ' Hydrogen and Oxygen Calibration Gas Concentrations,' for Umenck Generating Station, Unit I
i 1 and Unit 2, 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, j
information and belief.
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lb vv Vice President Subscribed and sworn to before me this day of 1995.
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Notary Public NotanalSeal Edm A Santon,NotayPubic gym IIxp b#
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ATTACHMENT 1 i
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UMERICK GENERATING STATION i
UNITS 1 AND 2 1
Docket Nos.
50-352
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50-353 License Nos. NPF-39 NPF-85 i
TECHNICAL SPECIFICATIONS CHANGE REQUEST i
No. 94-02-0 i
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" Hydrogen and Oxygen Calibration Gas Concentrations' j
Supporting Information for Changes - 3 Pages 4
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PECO Energy Company, Licensee under Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, respectively, requests that the Technical Specifications (fS) contained in Appendix A to the Operating Licenses be amended as proposed herein, to delete part a. and revise part b. of Notos
Concentration Analyzers. The proposed changes to the TS are indicated by a vertical bar in the margin of TS page 3/4 3-87 for Units 1 and 2. The TS pages showing the proposed changes are contained in.
We request that, if approved, the TS changes proposed herein be issued by September 1,1995 and become effective within 30 days of issuance of the amendments.
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 Environmental Assessment.
Discussion and Descriotion of the Prooosed Chanaes These proposed TS changes will clarify the concentrations of calibration gas required to calibrate the H,/0, Analyzers, and support the requirements of LGS Transient Response Implementation Plan (IRIP) T-102, l
' Primary Containment Control Bases.' The current documented method of zero calibration is being deleted.
j The span gas concentration is being revised from 5% to 7% to support the requirements of TRIP T-102 l
which requires the operator to determine if the Drywell or Suppression Pool H, concentration is AT DB -
ABOVE 6%. The concem with H, concentration is related to the Post-Loss-Of-Coolant. Accident (LOCA) H, l
Recombiners, because at above 6% concentration the Recombiner may be an ignition source as stated in j
the TRIP procedure Bases.
1 This TS Change Request involves the removal of Notes *.a and #.a and revises Notes *.b and #.b on TS l
Table 4.3.7.5-1.
Safety Assessment The H,/0, Analyzers provide Indication of the concentrations of combustible gases in the primary i
containment and provide annunciation when combustible gas concentrations reach unacceptable levels.
These Technical Specifications (TS) changes will clarify several discrepancies and ambiguities regarding the H, and O, Analyzers as described in the LGS Updated Final Safety Analysis Report (UFSAR) and TS.
Adding clarification to the UFSAR and TS to specify that the H,/0, Analyzers are calibrated to provide accurate indication of H, and O, concentrations in the range of 0% to 7% does not negatively impact the accuracles of the analyzers or the atmosphere in the primary containment. Calibration of the 0% to 7% range will be reflected in both TS Table 4.3.7.5-1 and UFSAR Sections 6.2.5.2.2, 6.2.5.4, and 7.5.1.4.2.1.4. The analyzers will display accurate readings only within the range of the span gas used. Furthermore, calibration of only the 0% to 7% ranges is acceptable since the postulated maximum Post-LOCA containment H, and O, concentrations, per UFSAR Figures 6.2-43 and 6.2-45, are less than 5%.
A calibration gas containing 0% H, (or O,) and 100% bottled Nitrogen (N,) is not required for calibration of the analyzers to the required accuracy. Zero calibration is achieved by valving out the reagent gas. This results in the comparing of the same sample gas, resulting in a 0% difference in concentration. The zero concentration values are calibrated to the required accuracy using a comparison of thermal conductivities of two samples of the same span gas without a reagent gas for recombination. Calibration of the H,/O, l
Analyzers are done in accordance with the manufacturer's instructions.
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2 Information Suonottina a Findina of No Slanificant Hazards Consideration We have concluded that the proposed changes to the Limerick Generating Station (LGS), Unit 1 and Unit 2 Technical Specifications (TS), which remove and revise Notes on TS Table 4.3.7.5-1 to clarify several discrepancies and ambiguities, do not involve a Significant Hazards Consideration. In support of this j
determination, an evaluation of each of the three (3) standards, set forth in 10 CFR 50.g2 is provided below.
1.-
The oroonaad TS chanoes do not involve a sianificant incr=== in the ornhahaltv or conaar ices of an accident oreviousiv evaluated.
The proposed TS changes remove calibration of the H,/0, Analyzers using zero volume percent hydrogen (H ) and 100% bottled Nitrogen (N,). A calibration gas containing zero volume percent 2
H, and 100% bottled N, is not required for calibration of the analyzers to the required accuracy.
Calibration of the H,/O, Analyzers is done in accordance with the manufacturer's h atructions. The proposed TS changes also revise the span gas concentration from 5% to 7% to support the requirements of TRIP T-102. The H,/O, Analyzers provide indication of the concentrations of combustible gases in the primary containment and provide annunciation when combustible gas concentrations reach unacceptable levels. FaRure of the analyzers is not an accident initiator. The analyzers do not connect to the reactor coolant pressure boundary; therefore,they do not increase the probabRity of a LOCA. The proposed TS changes do not involve any design changes to
- analyzers. Therefore, these TS changes whl not involve a significant increase in the probabuity or consequences of an accident previously evaluated.
2.
The oroonnad TS chanaes do not craa'a the nneaNity of a new or different kind of accidant from any accident oreviousiv evaluated.
The H,/O, Analyzers provide indication and alarms for H, and O, concentrations in containment.
No physical or design changes to the analyzers are being made by these TS changes. During normal operations, the potential for an explosive atmosphere is negligible due to the absence of H, sources. For Post-LOCA, conditions the levels of H, and O, in containment have already been evaluated in LGS UFSAR Section 6.2.5. No physical or design changes which could introduce a new analyzer faRure mode are being made. The faRure modes of the analyzers are evaluated in UFSAR Table 6.2-21. Therefore, these TS changes wHl not create the possibulty of a new or different kind of accident from any accident previously evaluated.
3.
The orocosed TS chanaes do not involve a sianificant reduction in a marain of safety.
These TS changes wul clarify statements in the LGS UFSAR and TS concerning calibrated ranges of the analyzers. The change of the span gas from 5% to 7% falls within conditions previously analyzed. The Bases for TS 3/4.3.7.5 and 3/4.6.6 require operable H /0, Analyzers to ensure the 2
analyzers will be avaHable for monitoring, assessing and controlling H, and O, levels in containment 3
following a LOCA. These TS changes do not adversely affect operabHity of the analyzers or their i
availabuity for use during Post-LOCA conditions; therefore, the margin of safety is not reduced.
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1 Information Suonortina an Environmental Assessment i
j 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 i
l conform to the criteria for " actions eligible for categorical exclusion," as specified in 10CFR51.22(c)(9). The requested changes will have no impact on the environment. The proposed TS changes do not involve a i
Significant Hazards Consideration as discussed in the preceding section.- The proposed changes do not i
involve a significant change in the types or significant increase in the amounts of any emuent that may be released offsite. In addition, the proposed TS changes do not involve a significant increase in Individual or j
cumulative occupational radiation exposure.
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l Conclusion f
The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed
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changes to the Limerick Generating Station, Units 1 and 2, Technical Specifications, and have corx:luded j
that they do not involve an unreviewed safety question.
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