ML20086B838

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Safety Evaluation Supporting Amends 95 & 59 to Licenses NPF-39 & NPF-85,respectively
ML20086B838
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 06/22/1995
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20086B833 List:
References
NUDOCS 9507060124
Download: ML20086B838 (3)


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UNITED STATES NUCLEAR REGULATORY COMMISSION I

f WASHINGTON, D.C. 20566 4 001

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 1

RELATED TO AMENDMENT NOS. 95 AND 59 TO FACILITY OPERATING LICENSE NOS. NPF-39 AND NPF-85 PHILADELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION. UNITS I AND 2 DOCKET NOS. 50-352 AND 50-353

1.0 INTRODUCTION

By letter dated August 31, 1994, the Philadelphia Electric Company (the licensee) submitted a request for changes to the Limerick Generating Station, Units 1 and 2, Technical Specifications (TS).

The requested changes would permit the operability of one Low Pressure Coolant Injection (LPCI) subsystem of Residual Heat Removal (RHR) while the subsystem is aligned and operating in the Shutdown Cooling Mode during Operational Conditions (OPCONs) 4 and 5.

These amendments address Section 4 of the licensee's August 31, 1994-submittal, " Permit Operability of Low Pressure Coolant Injection While Aligned to Shutdown Cooling." There are two remaining items to this application.

2.0 EVALUATION The licensee proposed to add a footnote to Limiting Condition for Operation 3.5.2.b.2 and Surveillance Requirements (SR) 4.5.2.1 with the statement, "One LPCI subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of _being manually realigned and not otherwise inoperable," applicable for OPCONs 4 and 5.

Currently, the LPCI mode of RHR at LGS, Units 1 and 2, is an automatic Emergency Core Cooling system (ECCS) function during OPCONs 4 and 5.

The proposed change involves permitting the operability of one LPCI subsystem while the components of that subsystem are aligned and operating in the Shutdown cooling mode of RHR, provided all other components of that subsystem are operable and can be manually realigned from the Main control Room if necessary. The licensee stated that the reactor operator has sufficient time during OPCONs 4 and 5 to perform the manual LPCI alignment from the Main Control Room, since the reactor decay heat loads and temperatures are significantly reduced from those parameters analyzed for OPCON 1.

The LGS Updated Final Safety Analysis Report (UFSAR) Section 6.3 states based on the conditions of OPCON 1, two loops of core Spray and one loop of LPCI are the minimum required low pressure ECCS.

In addition, when the unit is in OPCON 4 or 5, cold shutdown would have already been obtained, eliminating the high temperatures of OPCON 1.

Hence, the cooler reactor inventory eliminates the loss of coolant potential from depressurization and the inventory flashing to steam.

There will be no physical changes made to plant equipment, nor will there be any change in the method of their operation.

9507060124 950622 PDR ADOCK 05000352 P

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The licensee performed an evaluation for the need that calls for manual i

realignment of the pump minimum flow path since operating in Shutdown Cooling normally results in the isolation of the pump minimum flow path to prevent i

inadvertent draining of the reactor vessel. When reactor pressure is low enough to allow immediate injection to the reactor vessel without a minimum flow path, the associated pump.is still operable during OPCONs 4 and 5.

When the reactor pressure may not be low enough to allow injection, the RHR system will not be aligned for Shutdown Cooling in some OPCON 4 situations, since the reactor vessel pressure will be greater than the RHR " cut-in" permissive.

j pressure. Currently, LGS Administrative Controls are in place to realign RHR to the LPCI mode for planned pressure increases.

The proposed TS change is in accordance with SR 3.5.2.4 of NUREG-1433,

" Standard Technical Specifications, General Electric Plants, BWR/4," dated September 1992. The staff agrees that the proposed change does not involve any physical changes of plant equipment nor the method of operation.

Based on j

the above evaluation, the staff considers the proposed change to be acceptable.

3.0 STATE CONSULTATION

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In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments. The State official had no comments.

4.0 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 and changes the Surveillance Requirements. 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 amendments involve no significant hazards consideration, and there has been no public comment on such finding (59 FR 55884). 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.

5.0 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

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- activities will be conducted in compliance with the Comission's regulations, and (3) the issuance of the amendments will not be inimical to the comon defense and security or to the health and safety of the public.

Principal Contributor:

T. Liu Date: June 22, 1995 I

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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:

T. Liu 6

Date: June 22, 1995 J

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