ML20107M506

TS Change Request 95-08-0 to Licenses NPF-39 & NPF-85, Relocating TS 3/4.7.7 Re Traversing in-core Probe LCO

ML20107M506
Person / Time
Site:	Limerick
Issue date:	04/25/1996
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20107M512	List: ML20107M506 ML20107M514
References
NUDOCS 9604300427
Download: ML20107M506 (6)

Text

-. i2 Station Support oopartment g 10 CFR 50.90 iECO NUCLEAR I?ATl&"a*o"se,,

A UMr or PECO ENrecy 965 Chestertwook Boulevard Wayne, PA 19087-5691 April 25,1996 .

Docket Nos. 50-352

{

50-353 i License 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 Request No. 95-08-0 Relocation of Traversing in-Core Probe Umiting Condition For Operation Gentlemen:

PECO Energy Company (PECO) is submitting Technical Specifications (TS) Change Request i No. 95-08-0, 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 Umerick Generating Station (LGS), Units 1 and 2.

The purpose of the proposed TS changes is to relocate the TS Traversing In-Core Probe (TIP)

System Umiting Condition For Operation (LCO) 3/4.3.7.7 and its Bases 3/4.3.7.7, and modify . l Note (f) of TS Table 4.3.1.1-1 " Reactor Protection System Instrumentation Surveillance Requirements" to remove its reference to the TIP System in accordance with NRC NUREG-1433

" Standard Technical Specifications, General Electric Plants, BWR/4". .

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 June 10,1996, and become effective within 30 days of issuance.

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

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

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

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

R. R. Janati, PA Bureau of Radiation Protection (w/ enclosure, attachments) s- 9604300427 960425 Ool PDR ADOCK 05000352 P PDR. Ig

COMMONWEALTH OF PENNSYLVANIA  :

ss.

COUNTY OF CHESTER  :

D. B. Fetters, 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. 9548-0 " Relocation of Traversing In-Core Probe System Limiting Condition For Operation" for Limerick Generating Station, 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 l l

the best of his knowledge, Information and belief. l 9 I k i -

Vice President Subscribed and sworn to before me this o'? ay of 1996.

U

&c)I Notary Public Notarial Seal Mary Lou skrocki. Notary Public Tredyttrin Twp , Chester Coun My Commission Expires May 17,g999 1;...:1:r, PennsyMai Awnton omM

l l

ATTACHMENT 1  ;

I LIMERICK GENERATING STATION UNITS 1 AND 2 ,

Docket Nos.

50-352 50-353 License Nos.

NPF-39 NPF-85

" Relocation of Traversing In-Core Probe System Umiting Conditions For Operation" Infortnation Supporting Changes - 3 pages i

I i

l

1

Page 1 of 3

, DISCUSSION AND DESCRIPTION OF THE PROPOSED CHANGES ,

1 PECO Energy Company (PECO Energy) is requesting Technical Specifications (TS) changes which wHi relocate TS Requirements 3.3.7.7 and 4.3.7.7, " Traversing in-Core Probe (TIP) System" and its Bases 3/4.3.7.7, and modify Note (f) of TS Table 4.3.1.1 1 " Reactor Protection System Instrumentation Survetlance Requirements" in accordance with NRC NUREG-1433 " Standard Technical Specifications, General Electric Plants, BWR/4".

The purpose of this TS Change Request is to remove the TIP system requirements, and limiting conditions for operation (LCO) from TS Sections 3.3.7.7,4.3.7.7 and Bases 3/4.3.7.7 and relocate them (in their entirety) to the LGS Technical Requirements Manual (TRM) in accordance with NUREG-1433. In l addition, the TIP system is detaled as the method for performing Local Power Range Monitor (LPRM) I calibrations as dcscribed in Note (f) of TS Table 4.3.1.1-1 and will be modified in accordance with l NUREG.1433. Both the TRM and plant procedure goveming surveulances are subject to the change control provisions described in the Administrative Controls Section of TS. Therefore, removal of the TIP LCO and surveulance requirements from TS wHl permit administrative control of future changes to the relocated items without processing a licensing amendment. i l

TS SAFETY ASSESSMENT l This activity does not alter existing TS requirements or those components to which they apply. The removed requirements will be located in a licensee controlled document (i.e., TRM) and any future changes will be subject to the requirements specified in the Administrative Controls Section of TS in accordance with the provisions of 10CFR50.59.

The Updated Final Safety Analysis Report (UFSAR) section 7.7. " Control Systems Not Required For Safety" and UFSAR section 7.7.1.6.3 describe the TIP system as an operational system which has no safety function. The system allows calibration of LPRM signals by correlating TIP signals to LPRM signals as the TIP is positioned in various radial and axial locations in the core. The TIP system has no ,

safety setpoints. Other TS TIP requirements (e.g., TIP shear valve) not relevant to LCO 3.3.7.7 are i unaffected by this change.

The NRC guidance provided in NUREG 1433 for relocated requirements is based on the NRC interim policy statement as documented in the General Electric Topical Report NEDO-31466, " Technical Specification Screening Criteria Application and Risk Assessment" and NRC review of this report in an NRC letter dated May 9,1988. The NRC May 9,1988 letter concluded that the TIP LCO may be relocated. In addition, this proposal for relocation of LGS TIP TS requirements is based on the application of the NRC Final Policy Statement noticed in the Federal Register on July 22,1993. The 1993 Final Policy Statement allows for "line item improvements", and delineated four criterla whereby LCOs i being considered for relocation which do not meet any of the criteria may be removed from TS and relocated to licensee controlled documents. The criteria are as follows.

Cr/teria 1 - Installed Instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Criteria 2 - A process variable, design feature, or operating restriction that is an Initial condition of a DBA or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criteria 3 - A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a DBA or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterla 4 - A structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.

Page 2 of 3 Based on the four criteria, we have concluded that the LGS TIP System LCO is not used to prevent degradation of the reactor coolant boundary, not a condition of a DBA or transient analysis that is based

, upon the integrity of the fission product barrier, not a portion of the primary success path of a safety sequence analysis, and has not been shown to be significant to public health and safety.

In addition to the citeria contrined in the NRC Policy Statement, the proposed changes to relocate TS 3/4.3.7.7 LCO and eliminate the TIP system details of Note (f) of TS Table 4.3.1.1 1 are in accordance with 10 CFR 50.36 " Technical Specification". The relocated and removed information was determined not to be required to obviate the threat to the public health and safety.

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 2 TS, which will relocate the Traversing In-Core Probe (TIP) LCO (3.3.7.7 and 4.3.7.7) from TS to the TRM, and the modification of Table 4.3.1.1 1 Note (f) does not involve a Significant Hazaids 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 orocosed TS chances do not involve a sianificant increase in the orobability or conseouences of an accident oreviousiv evaluated.

The proposed changes will relocate requirements from TS to a licensee controlled i document (i.e., TRM) and delete surveillance details pertaining to the TIP system which are already contained in licensee controlled documents. The relocated requirements will 3 be retained in licensee controlled documents which will be maintained under the requirements of TS Administrative 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 probability or consequences of an accident previously evaluated will be allowed.

In addition, these proposed changes will not affect any equipment important to safety, in

structure or operation. These changes will not alter operation of process variables, structures, systems, or components as described in the safety analysis report and licensing basis. The changes will not increase the probability or consequences of occurrence of a malfunction of equipment important to safety previously evaluated in the SAR.

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

The proposed changes will not alter the plant configuration or change the methods governing normal plant operation. The changes will not impose different operating requirements and adequate control of Information will be retained. The changes will not alter assumptions made in the safety analysis report 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 possibility 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.

The proposed changes to relocate requirements from TS to a licensee controlled document and modify surveillance details pertaining to the TIP system which are already contained in other licensee controlled documents have been performed under the

i e o e Page 3 of 3 4

~ guidance of NRC NUREG-1433, and the NRC Final Policy Statement noticed in the Federal Register on July 22,1993 ' Final Policy Statement on Technical Specifications improvements for Nuclear Power Peactors." PECO Energy has concluded that the TIP LCO and surveulance detaus do not meet any of the four criteria delineated in the NRC's i Policy Statement and therefore, may be removed from TS. The relocated requirements will be retained in licensee controlled documents which wRI be maintained under the requirements of TS Administrative Controls Section 6.0 and the provisions of 4

10CFR50.59.  !

l The existing requirements for NRC review and approval of revisions (in accordance with l 10 CFR 50.90), pertaining to the details and requirements proposed for relocation, do l

- not have a specific margin of safety upon which to evaluate. However, since the .

proposed changes are consistent with the BWR improved Standard Technical Specifications (NUREG-1433, approved by the NRC Staff) and the change controls for i proposed relocated requirements provide an equivalent level of regulatory authority,-  !

revising the TS to reflect the approvt d level of detail and requirements ensures no reduction in the margin of safety. l These changes will not reduce the margin of safety since they have no impact on any safety analysis assumptions. Since any future changes to the removed TIP System requirements wHi be evaluated under the requirements of 10CFR50.59, no reduction (significant or insignificant) in a margin of safety will be allowed. Therefore, the proposed TS changes do not involve a significant reduction in a margin of safety.

INFORMATION SUPPORTING AN ENVIRONMENTAL ASSESSMENT An Environmental Assessment is not required for the Technical Specifications changes proposed by this request because the requested changes to the LGS, Units I and 2, TS conform to the criteria for

" 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 significant change'in the types or significant increase in the amounts of any effluent that may be released offsite. In addition, the proposed TS changes do not involve a significant increase in individual ,

or cumulative occupational radiation exposure. l CONCLUSION The Plant Operations 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 public.