ML20092J318

Application for Amends to Licenses NPF-39 & NPF-85,revising TS to Remove Secondary Containment Isolation Valve Tables

ML20092J318
Person / Time
Site:	Limerick
Issue date:	09/14/1995
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20092J321	List: ML20092J318 ML20092J328
References
NUDOCS 9509220064
Download: ML20092J318 (5)

Text

Ctation Support Deprrtm:nt I g

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.. I 10 CFR 50.90 i J y l PECO ENERGY 5 .2 i="Le,,

965 Chesterbrook Boulevard Wayne. PA 19087-5691 l

September 14,1995 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 U.S. Nuclear Regulatory Cornmission Attn: Document Control Desk Washington, DC 20555 Subject

• Limerick Generating Station, Units 1 and 2 Technical Specifications Change Request No. 95-15-0 Removal of Secondary Containment isolation Valve Tables Gentlemen:

PECO Energy Company (PECO) Is submitting Technical Specifications (TS) Change Request No. 95-15-0, in accordance with 10 CFR 50.90, requesting a change to TS (i.e.. Appendix A) of Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2.

The purpose of the proposed TC changes is to remove the Reactor Enclosure and Refueling Area Secondary Containment isolation Valve Tables 3.6.5.2.1 1 and 3.6.5.2.2-1 from TS in accordance with NRC Generic Letter (GL) 91-08, " Removal of Component Lists from Technical Specifications."

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.

The TS change information is being submitted under affirmation, and the required affidavit is enclosed.

We request that if approved, the TS Change 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, l j: q G. A. Hunger, Jr.,

Director-Licensing Enclosure, Attachments cc: T. T. Martin, Administrator, Region I, USNRC (w/ enclosure, attachments)

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

R. R. Janatl, PA Bureau of Radiation Protection (w/ enclosure, attachments) 9509220064 950914

PDR ADOCK 05000352 . gi P._..-... _ . . ._.PDR._ -

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- COMMONWEALTH OF PENNSYLVANIA  :

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COUNTY OF CHESTER  :  ;

f W. H. Smith, Ill, being first duly swom, deposes and says: That he is Vice President of PECO Energy Company, the Applicant herein; that he has read the enclosed Technical Specifications Change Request

' No.95-154 " Removal of Secondary Containment Isolation Valve Tables," for Limerick Generating Station, l

f Unit 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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- Vice President l'

Subsc'.oed and swom to before me this day ap.souoe5.

JAth Notary Public Notarial Seal -

Mary Lou Skrocki. Notary Public Tredyffrin Twp., Chester County My Comm;ssion Expires May 17,1999 runber,Pennsytverna Assooston of Notarks

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t ATTACHMENT 1 ,

UMERICK GENERATING STATION .

UNITS 1 AND 2 Docket Nos.

50-352 i

50-353 License Nos.

NPF49 NPF-85

" Removal of Secondary Containnunt isolation Valve Tables from Technical Specifications" Infonnation Supporting Changes - 2 pages 4

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' - . Page 1 of 2 DISCUSSION AND DESCRIPTION OF THE PROPOSED CHANGES

' PECO Energy Company (PECO Energy) is requesting Technical Specifications (TS) changes which wDi  :

remove the Reactor Enclosure and Refueling Area Secondary Containment Isolation Valve Tables

' (3.6.5.2.1-1 and 3.6.5.2.21) from TS in accordance with NRC Generic Letter (GL) 91-08, " Removal of Component Lists from Technical Specifications."

The velves and their associated isolation signals are currently identified in the LGS Updated Final Safety i Analysis Report (UFSAR) and wHl also be contained in a plant procedure. Both the UFSAR and the plant '

procedure are subject to the change control provisions described in the Administrative Controls Section of TS. Therefore, removal of the tables from TS wNI permit administrative control of future changes to the tables without processing a licensing amendment. ,

. TS SAFETY ASSESSMENT

' Generic Letter 91-08 provides guidance to remove compcnent lists frorr the Technical Specifications.

This is acceptable provided that TS requirements are stated in genera! terms that describe the types of components to which the requirements apply, and because the removal of component lists do not alter .

' existing TS requirements or those components to which they apply, in addition, the removed lists must '

be included in a plant procedure that is subject to the change control provisions for plant procedures in '

the Administrative Controls Section of TS, and it is permissible to reference the location of removed lists In the TS Bases Section.

l LGS TS Sections 3.6.5.2.1 " Reactor Enclosure Secondary Containment Automatic Isolation Valves," and 3.6.5.2.2 "Refusiing Area Secondary Containment Automatic Isolation Valves," provide a description of '

- the components to which the TS requirement applies. The valves are contained in TS tables 3.6.5.2.1 1, c _ and 3.6.5.2.2-1, are currently contained in the UFSAR and wul be incorporated into a plant procedure.

Both documents are subject to the change control provisions of the Administrative Controls Section of TS, and the location of the removed tables wul be described in LGS TS Bases Section 3/4.6.5, E " Secondary Containment." Therefore, the proposed changes are in accordance with the guidance l provided by NRC GL 91-08.

INFORMATION SUPPORTING A FINDING OF NO SIGNIFICANT HAZARDS CONSIDERATION We have concluded that the proposed changes to the Limerick Generating Station (LGS) Unit 1 and Unit .

j 2 TS, which wRl remove the Reactor Enclosure and Refueling Area Secondary Containment Isolation i Valve Tables (3.6.5.2.1 1 and 3.6.5.2.21) frorn TS in accordance with NRC Gl. 91-08, do not involve a  ;

! Significant Hazards Consideration. In support of this determination, an evaluation of each of the three '

l (3) standards set forth in 10 CFR 50.92 is provided below.

1. The oronn=M TS chanoes do not involve a sionificant increase in the orobabilite or

.CQDeeauences of an accident oreviousiv evaluated.

The proposed changes will remove component tables from TS. The component lists wul i be retained in licensee controlled documents (UFSAR and a plant procedure) which will be maintained under the requirements of TS Admin'.3trative Controls Section 6.0 and the

! provisions of 10CFR50.59. Since any changes to licensee controlled documents are

required to be evaluated per 10CFR50.59, no increase (significant or insignificant) in the  !

j probability or consequences of an accident previously evaluated wul be allowed. ,

o in addition, these proposed changes wHl not affect any equipment important to safety, in 1 structure or operation. These changes WH1 not alter operation of process variables, structures, systems, or coiriponents as described in the safety analysis and licensing ,

basis. The changes will not increase the prdcbRity or consequences of occurrence of a.

malfunction of equipment important to safety previously evaluated in the SAR.

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2. The oranaamd TS channes do not craata the nossibuity of a new or different kind of  ;

accident from any accident previously evaluated.

The proposed changes wHl not alter the plant con'iguration or change the methods goveming normal plant operation. The changes wul not impose different operating ,

requirements and adequate control of information wRl be retained. The changes wHl not j alter assumptions made in the safety analysis and licensing basis. Since the proposed changes cannot cause an accident, and the plant response to the design basis events is ,

unchanged, the changes do not create the possibuity of a new or different kind of '

accident from any accident previously evaluated.

3. The orooosed TS chanoes do not involve a sieniT,c.ent reduction in a maroin of safety.

The proposed changes to remove the component tables from TS have been performed under the guidance of NRC GL 91-08. The component lists wul be retained in licensee controlled documents (UFSAR and a plant procedure) which will be maintained under the requirements of TS Administrative Controls Section 6.0 and the provisions of i 10CFR50.59. These changes WHI not reduce the margin of safety since they have no .

impact on any safety analysis assumptions. Since any future changes to the removed tables will be evaluated under the requirements of 10CFR50.59, no reduction (significant or insignificant) in a margin of safety will be aHowed. Therefore, the proposed TS changes do not involve a significant reduction in a margin of safety.

INFORMATION SUPPORTING AN ENVIRONMENTAL ASSESSMENT ,

An Environmeat i Assessment is not required for the Technical Specifications changes proposed by this ,

request because the requested changes to the LGS, Units 1 and 2, TS conform to the criteria for I

" actions eligible for categorical exclusion," as specified in 10 CFR 51.22(c)(9). The requested TS changes wHl have no impact on the environment. The proposed TS changes do not involve a Significant Hazards Consideration as discussed in the preceding section. The proposed changes do not involve a I

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

CONCLUSION The Plant Ope'ations Review Committee and the Nuclear Review Board have reviewed these proposed changes to the LGS Units 1 and 2 TS, and have concluded that the changes do not involve an unreviewed safety question, and will not endanger the health and safety of the pubilc.

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