ML20086S598

Application for Amends to Licenses NPF-39 & NPF-85,revising TS Table 4.3.1.1-1,to Reflect Changes to Surveillance Test Frequency Requirements for Various RPS Instrumentation

ML20086S598
Person / Time
Site:	Limerick
Issue date:	07/28/1995
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20086S600	List: ML20086S598 ML20086S613
References
NUDOCS 9508020058
Download: ML20086S598 (8)

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. PEco Energy company .

Nuclear Group Headquarters .

965 Chesterbrook Boulevard Wayne, PA 19087-5691 July 28,1995 :

Docket Nos. 50-352 o 50 353

1. 4 License Nos. NPF-30 NPF-851

' 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. 95-11-0 Gentlemen:

PECO Energy Company is submitting Technical Specircations (TS) Change Request No. ..

L 95-11-0, in accordance with 10CFR 50.90, requesting an amendment to the TS (Appendk A) of .

Operating License Nos. NPF-30 and NPF 85 for Umorick Generating Station (LGS), Units 1 and 2, respectively. This prnivmad change will revise TS Table 4.3.1.1-1,

• Reactor Protection System Instrumentation Surveillance Requirements" to reflect changes to the survetlance test frequency requirements for various Reactor Protection System instrumentation. Information supporting this Change Request is contained in Attachment I to this letter, and the marked up pages showing the proposed changes to the LGS Units 1 and 2 TS are contained in Attachment 2. This e information is being submitted under affirmation, and the required affidavit is enclosed We request that, if approved, the amendment to the LGS Units 1 and 2 TS be issued by January 26,1996, and become effective within 30 days of issuance.

If you have any questions, please do not hesitate to contact us.

Very truly yours, G. A. Hunger, Jr.,

Director Licensing Enclosure, Attachments cc: T T. Martin, Admmistrator, Region 1. USNRC (w/ enclosure, attachments)

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

R. R. Janati, PA Bureau of Radiological Protection (w/ enclosure, attachments) 9soso2oose 9so72s 8 p

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W. H. Smith, Ill, being first duly sworn. deposes and says:

l That he is Vice President of PECO Energy Company, the Applicant herein; that he has read the

- foregoing Applicr*lon for Amendment of Facility Operating License Nos. NPF-39 and NPF 85 (Technical Specifications Change Request No. 95-11-0), to change the surveillance test frequency requirements for various Reactor Protection System instrumentation, at Limerick Generating Station, Units 1 and 2, 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.

hv Vice President Subscribed and swom to before me thish day Y

of 1995.

x Notary ublic j Noteriet Seal ,

Edos S. Maisomvaz, Putsc -  !

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l ATTACHMENT 1' i

UMERICK GENERATING STATION *

UNITS 1 AND 2  !

~*: DOCKET NOS. 50452 50-353 .!

UCENSE NOS. NPF 39 l NPF-85 .j TECHNICAL SPECIFICATIONS CHANGE REQUEST j NO.95-110 ,

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' CHANGES TO THE SURVEILLANCE TEST FREQUENCY REQUIREMENTS FOR VARIOUS REACTOR PROTECTION SYSTEM INSTRUMENTATION" I

L Supporting information for Changes - 4 Pages .!

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Docket Nos. 50-352 50-353 Ucense Nos. NPF-39 NPF-85 PECO Energy Company, licensee under Facility Operating License Nos. NPF-39 and NPF 85 for Umerick Generating Station (LGS), Units 1 and 2, respectively, requests that the Technical Specifications (TS) contained in Appendix A to the Operating License be amended as proposed herein, to reflect changes to the surveillance test frequency requirements for various Reactor Protection System (RPS) instrumentation, thereby revising TS Table 4.3.1.1-1. The proposed changes to the TS are indicated by mark-ups on TS pages 3/4 3-7 and 3/4 3-8. The TS pages showing the proposed changes are contained in Attachment 2.

, We request that, if approved, the TS changes proposed herein be issued by January 26,1996, and p 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.

l Discussion and Descriotion of the Prooosed Chances  !

l The proposed changes to the LGS Units 1 and 2 Technical Specifications (TS) Table 4.3.1.1-1, " Reactor l Protection System Instrurnentation SurveDiance Requirements," will reflect changes to the surveillance j test frequency requirements for various Reactor Protection System (RPS) instrumentation, as follows.

- Delete the need to perform the channel check and functional test for intermediate Range Monitor  !

(IRM) and Average Power Range Monitor (APRM), for (prior to) startup. This Is in accordance i with improved Standard Technical Specifications, NUREG-1433, issued September 28,1992.  ;

- Change the required frequency of the APRM functional test from Weekly (W) to Quarteriy (O) for the Neutron Flux Upscale, Setdown function. This is based on documented plant instrumentation performance and reliability.

This TS change will provide the station with the floribility to maintain the IRM and APRM instrumentation .

surveillance tests at frequencies already shown tri be acceptable, while minimizing delays in plant startup  !

due to requirements that are bounded by those !mposed during normal operation.

Therefore, we propose that TS Table 4.3.1.1 1 be revised to reflect the changes to the survelliance test frequency requirements for various RPS instrumentation (i.e., IRM and APRM). Note (c) of Table 4.3.1.1-1 is also being deleted as a result of the proposed changes. t 1

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Docket Nos. 50-352 50-353 l License Nos. NPF-39 l NPF-85 Safety Assessment The proposed TS changes to the surveillance test frequency requirements for various Reactor Protection System (RPS) instrumentation, such as intermediate Range Monitor (IRM) and Average Power Range Monitor (APRM), do not involve a physical change in the configuraticn, setpoints, or operation of any safety-related instrumentation. The proposed TS changes do not modify the manner in which the associated IRM and APRM instrumentation carry out the scram functions.

The deletion of requirements to perform the channel check and functional test for IRM and APRM for (prior to) startup is in accordance with the improved Standard Technical Specifications, NUREG-1433, issued September 28,1992. The reliability of each tested function is confirmed by the fact that the normal surveillance frequency specified in TS for that function, remains unchanged and it is greater than, or equal to the startup surveillance interval associated with that function.

The change to the required frequency of the APRM functional test from Weekly (W) to Quartorfy (O) for the Neutron Flux-Upscale, Setdown function is based on APRM instrumentation reliability confirmed by plant operating experience at LGS Units 1 and 2. The setpoint data was collected for each APRM channt.1, for HPS and Control Rod Block Upscale Setdown surveillance testing performed since August 1992, until present. The results of the (0) tests confirmed that the APRM Upscale Setdown function has over 2.5 years of performance in Operational Condition 1 (Power Operation) without any failures, thus being extremely reliable.

The proposed TS changes do not affect existing accident analyses or design assumptions, nor do they impact any safety limits of the plant.

Information Sucoortina a Findina of No Slanificant Hazards Consideration We have concluded that the proposed changes to the Limerick Generation Station (LGS), Units 1 and 2 Technical Specifications (TS), which will revise TS Table 4.3.1.1 1, " Reactor Protection System Instrumentation Surveillance Requirements" to reflect changes to the surveillance test frequency requirements for various Reactor Protection System (RPS) instrumentation do not involve a Significant Hazards Consideration. In support of this determination, an evaluation of each of the three (3) standards set forth in 10 CFR 50.92 is provided below.

1. The oronosed Technical Soecifications fTS) chanaes do not involve a slanificant increase in the orobability or consecuences of an accident oreviousiv evaluated.

In all of the applicable SAR evaluated events, the IRM and APRM instrumentation is credited for performing a mitigating function (i.e., initiating a scram), to terminate the transient prier to a safety limit being exceeded. The proposed TS changes do not alter the RPS configuration, or i RPS instrumentation setpoints, nor do they change the manner in which the IRM and APRM instrumentation carry out the scram functions. Therefore the consequences of any potential malfunction of equipment important to safety will remain unchanged.

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, Docket Nos. 50-352 l 50-353 IJcense Nos. NPF-39 NPF-85 in each case where a startup surveillance test requirement is proposed to be deleted, (i.e., IRM and APRM), the normal surveHlance test frequency specified for the required Operational Condition remains unchanged (except for the APRM Upscale Setdown functional test). The startup surveillance requirement is conservatively bounded by the normal surveillance test interval which is greater than or equal to any interval associated with the startup surveHlance requirement and ensures that the IRM and APRM instrumentation reliability is unchanged. This is in accordance with the Improved Standard Technical Specifications, NUREG 1433, issued September 28,1992.

The re!!abalty of the APRM Upscale Setdown scram function will not be decreased due to changing the functional test frequency from Weekly (W), to Quarterly (Q), in Operational Conditions 2,3, and 5 (Startup, Hot Shutdown and Refueling, respectively). Plant operational data taken from each of the APRM calbration/ functional tests performed since August 1992 untH present at LGS Units 1 and 2, shows that setpoint reliability wlH be maintained if the functional test frequency is increased to quarterly, as proposed. Presently, each time an APRM calibration / functional test is performed, both the Upscale Setdown and the Flow Reference scram circuits are tested. The results of the quarterly tests confirm that the APRM Upscale Setdown function already has over 2.5 years of performance without faHure in Operational Condition 1, thus being extremely reliable.

Therefore, the proposed TS changes do not involve an increase in the probabHity or consequences of an accident previously evaluated.

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

The proposed TS changes affect only the required surveHlance test intervals, not the RPS configuration or RPS instrumentation setpoints. The proposed TS changes do not introduce a new faHure mode for the IRM or APRM instrumentation. Plant operating experience data confirms that at LGS Units 1 and 2, the IRM and APRM instrumentation will continue to perform their safety function as currently designed, with the same degree of reliabulty.

The proposed TS changes do not alter the configuration of the plant, nor the way the plant is operated.

Therefore, the proposed TS changes do not create the possibility of a new or different kind of accident, from any accident previously evaluated.

3. The oronosed TS chances do not involve a slanificant reduction in a maroin of safety.

The following TS Bases were reviewed for potential reduction in the margin of safety:

B 2.2.1 Reactor Protection System Instrumentation Setpoints B 3/4.1.4 Control Rod Proaram Controls B 3/4.2 Power Distributlori Limits B 3/4.3.1 Reactor ProicMen System Instrumentation B 3/4.3.6 Control Rod Block Instrumentation 3-

Docket Nos. 50-352 i'

50453

) License Nos. NPF-39 NPF-85 The surveNiance test frequency changes proposed for the RPS instrumentation section of TS do l not adversely affect the IRM or APRM instrumentation, which wHI continue to perform the RPS I functions required to maintain the present margin of safety. Changes to the IRM instrumentation startup surveillance intervals are already bounded by the existing surveHlance requirements, and are in accordance with the improved Standard Technical Specifications, NUREG-1433, issued September 28,1992. The same statement applies to the APRM instrumentation, with respect to deletion of the startup surveHlance requirement. The change of the APRM Upscale Setdown

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! Channel functional test surveNiance interval from Weekly to Quarterly was evaluated to ensure that the APRM instrumentation would perform that function, with the same degree of reliabHity as presently experienced. A review of the plant operating experience data at LGS Units 1 and 2 shows that APRM instrumentation is extremely reliable for a quarterly surveHlance test interval.

The proposed TS changes do not modify plant configuration, RPS Instrumentation setpoints, or RPS operation. The margin of safety remains unchanged.

t Therefore, the proposed TS changes do not involve a reduction in a margin of safety.

Information Sucoortino an Environmental Assesstaggi An environmental assessment is not required for the changes proposed by this TS Change Request because the requested changes to the Limerick Genera:Ing Station (LGS), Units 1 and 2, TS conform to the criteria for " actions eligible for categorical exclusion" ss specified in 10 CFR51.22(c)(9). The requested changes will have no impact on the environment. The proposed changes do not involve a significant hazards consideration as discussed in the preceding section. The proposed changes do not ,

involve a significant change in the types or significant increase in the amounts of any effluents that may be released offsite. In addition, the proposed changes do not involve a significant increase in individual or cumulative occupational radiation exposure.

I Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes to the Limerick Generating Station (LGS), Units 1 and 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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ATTACHMENT 2 i

i UMERICK GENERATING STATION  ;

i UNITS 1 AND 2 i

DOCKET NOS. 50452 l 50-353 i UCENSE NOS. NPF-39 '{

NPF-85 l

-i TECHNICAL SPECIFICATIONS CHANGE REQUEST ,

i NO. 95-11-0  !

.i UST OF AFFECTED PAGES i UNIT 1 UNIT 2 i

-i 3/43-7 3/43-7 i 3/43-8 3/43-8 i

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