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TS Change Request 94-28-0 to Licenses NPF-39 & NPF-85, Revising TS SR & Deleting Specific Requirements to Perform Surveillances Prior to Beginning or Resuming Core Alterations or CR Withdrawal Assoc W/Refueling Activities
	ML20086U482
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
ML20086U484	List: ML20086U482; ML20086U505;
References
	NUDOCS 9508040115
	Download: ML20086U482 (9)
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Station support Department

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PECO ENERGY Nuclear Group Headquarters 965 Chesterbrook Boulevard Wayne, PA 19087-5691 July 28,1995 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 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. 94-28-0 Gentlemen:

PECO Energy Company is submitting Technical Specifications (TS) Change Request No.94-284, in accordance with 10 CFR 50.90, requesting an amendment to the TS (Appendix A) of Operating Ucense Nos. NPF-39 and NnF-85 for Umerick Generating Station (LGS), Units 1 and 2, respectively. This proposed TS change involves revising TS Surveillance Requirements (SRs) 4.9.1.1,4.9.1.2,4.9.3,4.9.5, and 4.9.8 to delete specific requirements to perform surveillances h.gt Arkg to beginning or resuming core alterations or control rod withdrawal associated with refueling activities. This proposed TS change also requests that the phrase "iricore instrumentation" be deleted from the footnote in TS Section 3/4.9.5, " Communications."

These proposed TS changes are consistent with criteria delineated in the improved Standard TS (i.e., NUREG-1433,

Standard Technical Specifications, General Electric Plants, BWR/4," dated September 28,1992). Information supporting this TS Change Request is contained in ,

Attachment 1 to this letter, and copies of the marked-up TS pages for the LGS, Units 1 and 2, TS are contained in Attachment 2. This TS Change Request is being submitted under i affirmation, and the required affidavit is enclosed.

We request that, if aps .ved, the amendments to the LGS, Units 1 and 2 TS be issued prior to :

January 26,1996, ard ecorv effective within 30 days following issuance. ;

.t If you have any questions or require additional information, please do not hesitate to contact us.

Very truly yours, j

. h. r -

G. A. Hungar, Jr. ,

Director -IJcensing ;

Attachments i Enclosure cc: T. T. Martin, Administrator, Region 1. USNRC (w/ attachments, enclosure)

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

R. R. Janati, Director, PA Bureau of Radiological P;otection (w/ attachments, enclosure) 040035 930804013s ,5072s

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PDR ADOCK 05000352 %lg F PDR !

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COUNTY OF CHESTER .

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

That he is Vice President of PECO Energy Company, the Applicant herein; that he has read the foregoing information supporting Technical Specifications Change Request No. 94-28-0 for Limerick ;

Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85, to revise TS ,

Surveillance Requirements (SRs) concerning the performance of surveillance tests during refueling operations, and knows the contents thereof; and that the statements and matters set forth therein are true t

.i and correct to the best of his knowledge, information, and belief.

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Vice President Subscribed and sworn to !

before me this d day of .

- 1995. ;

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~8 ATTACHMENT 1 l

.i UMERICK GENERATING STATION UNITS 1 AND 2 ,

i Docket Nos. 50-352 50-353 License Nos. NPF-39 ,

NPF-85 TECHNICAL SPECIFICATIONS CHANGE REQUEST No. 94 28-0 ,

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Revise the Tehn! cal Specifications Surveillance Requirements ,

to Delete Specs.1c Requirements to Perform Surveillances Just Prior to Beginning or Resuming Core Alterations or Control Rod Withdrawal Associated with Refueling Activities.

Suppor1lng information for Changes - 5 pages l

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4 Attachment 1 Page 1 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 (TS) contained in Appendix A to the Operating Licenses be amended as proposed herein to modify TS Surveillance Requirements 4.9.1.1,4.9.1.2,4.9.3,4.9.5, and 4.9.8 to delete specific requirements to perform surveillanceslyst gigt to beginning or resuming core alterations or control rod withdrawal associated with refueling activities. This proposed TS change also requests that the phrase "incore instrumentation" he deleted from the footnote in TS Section 3/4.9.5, " Communication." These proposed TS changes are consistent with criteria delineated in the improved Standard TS (Le., NUREG-1433,

" Standard Technical Specifications, General Electric Piants, BWR/4," dated September 28,1992). The proposed changes to the TS are indicated on the attached marked-up TS pages contained in Attachment 2 to this letter.

We request that, if approved, the TS changes proposed herein be issued by January 26,1996, and become effective within 30 days upon issuance.

This TS Change Request provides a discussion and description of the proposed TS changes, a safety assessment of the proposed TS change 3, information supporting a finding of No Significant Hazards Consideration, and information supporting an Environmental Assessment.

Discussion and Descriotion of the Prooosed Chanaes Currently, the Limerick Generating Station (LGS), Ik,lts 1 and 2, Technical Specifications (TS) require that during refueling operations certain surveillance tests he performed just prior to beginning or resuming core alterations or control rod withdrawal, in ado; tion to other periodic surveillance requirements. Specifically, the current TS require that the following surveillances be performed.

1) The reactor mode switch is verified locked in the refuel or shutdown position within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months prior to beginning core alterations and at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

2) Each of the required reactor mode switch refuel position interlocks shall be demonstrated operable by performance of a channel functional test within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to the start of core alteration or control rod withdrawal.

3) All control rods are verified inserted within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months prior to the start of core alterations and at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

4) Direct communications between the control room and refuel floor personnel shall be demonstrated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months prior to the start of and at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months during core alterations.

5) The reactor vessel water level shall be determined to be at least the minimum depth within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months prior to the start of and at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months during handling of fuel assemblies or control rods within the reactor pressure vessel;

6) The reactor mode switch refuel position interlocks shall be demonstrated operable by performance of a channel functional test within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to the start of and at least once per 7 days during control rod withdrawal or core alteration and

7) Direct communication shall be maintained between the control room and refueling floor personnel during core alterations except as indicated in the footnote i.e., "Except the movement of incore instrumentation and control rods with their normal drive system."

Attachment 1 Page 2 This proposed TS change will revise TS Surveillance RequiremenM (SRs) 4.9.1.1, 4.9.1.2, 4.9.3, 4.9.5, and 4.9.8 to delete the specific requirements to perform surveillances relating to refueling activitiesJys.t n!1gr to beginning or resuming core alterations or control rod withc rawal. This proposed TS change also requests that the phrase "incore instrumentation" be deleted from the footnote in TS Section 3/4.9.5, which is consistent the current TS definition of " Core Alteration" as approved by the NRC in a letter dated January 27,1995, issuing Amendment Nos. 87 and 49 to the LGS, Units 1 and 2, Facility Operating Licenses . These proposed TS changes are consistent with criteria delineated in the improved Standard TS (i.e., NUREG-1433, ' Standard Technical Specifications, General Electric Plants, BWR/4,"

dated September 28,1992).

Jafety Assessment The fuel handling system is designed to provide a safe and effective method for transporting and handling fuel from the time it reaches the plant until it leaves the plant after post irradiation cooling. Safe handling of fuel includes design considerations for maintaining occupational radiation exposures as low as reasonably achievable (ALARA) during transportation and handling. Most of the refueling and servicing equipment is manually operated and controlled by the operator's visual observations.

Refueling interlocks are provided for use during planned refueling operations. Criticality is prevented during fuel insertion, provided that control rods in the vicinity of the vacant fuel space are fully inserted during fuel insertion. The interlock systems accomp!!sh this by the following mechanisms.

a. Preventing operation of fuel-loaded refueling equipment over the core whenever any control rod is withdrawn.

b. Preventing control rod withdrawal whenever fuel loading equipment is over the core. j

c. Preventing withdrawal of more than one control rod when the modo switch is in the ,

REFUEL position.

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The refueling interlocks have been designed utilizing redundancy of sensors and circuitry to provide a hl0h level of reliability and assurance that the design bases are met. Each of the individual refueling interlocks considered need not meet the sinDi e failure criteria, since the four (4) essentially independent levels (including precedural control) of protection ensure that the design basis is met. As discussed in Section 7.7 of the LGS Updated Final Safety Analysis Report (UFSAR), a single interlock failure does not cause an accident, result in potential physical damage to fuel, or result in radiation exposure to i personnel during fuel handling operations. l The rod block interlocks and refueling platform interlocks provide two (2) independent levels of interiock action. The interiocks that restrict operation of the platform hoist and grapple provide a third level of interlock action because they would be required only after a failure of a rod block and refueling platform interlock. The strict procedural control exercised during refueling operations is a fourth level of backup, even though this is actually the primary means of control.

This proposed TS change does not make any physical modifications to any fuel handling equipment, nor does it eliminate any refueling interlocks or procedural controls. Therefore, the potential for an inadvertent criticality as discussed in Sectice 15.4.1.1, " Control Rod Withdrawal Error During Refueling,'

is not altered. The probability of the initial causes of this transient alone are considered low enough to warrant its being categorized as an infrequent incident, since there is no postulated set of circumstances that results in an inadvertent rod withdrawal error while in the refueling mode. The refuelin0 i nterlock

Attachment 1 Page 3

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system combined with strict procedural controls provide sufficient barriers to preclude an inadvertent criticality, in addition, the potential for a Fuel Handling Accident as discussed in Section 15.7.4 of the '

UFSAR is not increased since this proposed TS does not support any physical modifications to plant ;

equipment, and this accident is assumed to occur as a consequence of the falure of the fuel handling mechanism resulting in a dropped fuel bundle. l Information Suncortino a Findino of No Sionificant Hazards Consideration We have concluded that the proposed changes to the Limerick Generating Station (LGS), Units 1 and 2, 1 Technical Specifications (TS) Surve81ance Requirements (SRs) 4.9.1.1,4.9.1.2,4.9.3, 4.9.5, and 4.9.8 to -

delete the specific requirements to perform surveillancesjuggkg to beginning or resuming core -

alterations or control rod withdrawal, and to eliminate the phrase "incore instrumentation" from the :

footnote in TS Section 3/4.9.5, do not involve a Significant Hazards Consideration. These proposed TS changes are consistent with criteria delineated in the improved Standard TS (i.e., NUREG-1433, i

, " Standard Technical Specifications, General Electric Plants, BWR," dated September 28,1992). In .._

support of this determination, an evaluation of each of the three (3) standards set forth in 10 CFR 50.92 l Is provided below. .

1. The orooosed Technical Scecificetions ITS) chances do not involve a sionificant ;

increase in the orobability or consecuences of an accident previously evaluated.

The proposed TS changes do not involve any physical changes to plant systems or i equipment. The proposed TS chan0es only delete those Surveulance Requirements f !

(SRs) pertaining to the performance of testsjuggkg to beginning or resuming core ;

alterations or control rod withdrawal, and revises a footnote description to be consistent j with the current TS definition of " Core Alteration." . The proposed TS changes do not ;

revise any of the other applicable periodic SRs, or modify any procedural controls j currently in place goveming fuel handling operations. i The periodic survellance test frequencies provide adequate assurance that the equipment wRl remain in an operable condition. The normal periodic survegiance :

Intervals bound those surveulance intervals for the tests that are being altered by this i proposed TS change. In the event that one of the periodic surveillances has not been j performed within the specified time interval, entry into the specified condition (i.e., l performance of core alterations, control rod withdrawal, or handling of fuel or control i rods) is not permitted as required by TS 4.0.4 untR the surveillance has been _ .

satisfactorly completed. .

The consequences of an accident are not increased by the proposed TS changes, since ,

the changes only involve revising the frequency of conducting surveillance tests. The !

method of operation or performance of plant structures, systems, or plant components !

are not affected by the proposed TS changes. The proposed TS changes wNl not !

impact the operation of any fuel handling equipment, and therefore, the potential for a .

Fuel Handling Accident as described in Section 15.7.4 of the LGS Updated Final Safety l' Analysis Report (UFSAR) is not increased.

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. Attachment 1 ' I Page 4 ,

. In addition, 'any unexpected reduction of water level in the reactor cavty or fuel pool at j the start of fuel handling or control rod handling wNl be immediately apparent to operators by direct observation, Plant procedures utlized by the refueling personnel require the suspension of core component transfers in the event of loss of water Inventory. l Therefore, the proposed TS change does not involve an increase in the probablity or .!

consequences of an accident previously evaluated. j i

2. The sic-:= ' TS d.-.as do not cr- " the r =t"-4 of a new or d%rit kind of -!

accident from any accident previously evaluated. j The proposed TS changes only involve changes to the frequency in which the specified surveillance tests are performed. The proposed TS changes do not revise any of the other applicable periodic SRs, or modify any procedural controls currently in place !

governing fuel handling operations. The periodic surveillance test frequencies provide ;

adequate assurance that the equipment wNI remain in operable condition. The periodic surveillance intervals bound those surveillance intervals for the tests that are being ;

altered by this proposed TS change. The refueling interlock system combined with strict procedural controls provide multiple barriers to preclude an inadvertent crticalty. ,

The proposed TS changes do not involve any physical changes to plant systems or !

equipment. The proposeJ TS changes do not alter the configuration of the plant or the way that the plant is cperated. The associated plant equipment wNl continue to function i as designed. This equipment is not designed to perform any other function than it is !

presently capable of, and therefore, wNi not affect the operation of any other plant equipment.

Therefore, the proposed TS change does not create the possibuky of a new or different i kind of accident from any previously evaluated.

3. Ibt Dronosed TS channes do not involve a sionificant reduction in a maroin of safety.

The proposed TS changes do not involve any physical changes to plant systems or ;

equipment. The reactor wNi continue to be maintained subertical during refueling +

operations and reactor water level wNl be maintained at the required level (i.e., above the - ,

vessel flange). The proposed TS changes do not affect the operation of other plant systems and equipment essential in maintaining reactor water temperature during l refueling operations, or the capablity in responding to a postulated Fuel Handling .

Accident. l l

The proposed changes do not adversely affect reliabNity of the refueling interlocks or .

refuel platform communications equipment. Since the proposed changes only impact :

the frequency in which certain survellance tests are performed, and do not change the plant configuration or setpoints, there is substantial assurance that the reactor wNl be -

maintained subcrtical during refueling. .

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

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Attachm:nt 1 Page 5 Information Sucoortina an Environmental Assessment An Environmental Assessment is not required for the changes proposed by this Change Request because the requested changes to the LGS, 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 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 effluent that may be released offsite. In addition, the proposed changes do not involve a significant increase in Individual or cumulative occupational radiation exposure.

Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed change to the 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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i ATTACHMENT 2 i

UMERICK GENERATING STATION !

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UNITS 1 AND 2 '

i Docket Nos. 50 352 50-353 Ucense Nos. NPF-39 NPF-85 f

l TECHNICAL SPECIFICATIONS CHANGE REQUEST No. 94-28-0 UST OF AFFECTED PAGES i (MARKED-UP PAGES) l Unit 1 Unit 2 l l

3/49-2 3/49-2 !

3/4 S 5 3/4F5 l 3/49-7 3/497 ,

3/4 9-11 3/4 9-11 ;

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ML20086U482

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