ML20127G093

Suppls 920403 TS Change Request 90-20-0,changing TS SR for Standby Liquid Control Sys,Per NRC 920716 Request That Util Consider Substituting Pertinent Sections of Sys Requirements in Draft Improved STS (NUREG-1433)

ML20127G093
Person / Time
Site:	Limerick
Issue date:	01/12/1993
From:	Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20127G098	List: ML20127G093 ML20127G103
References
RTR-NUREG-1433 NUDOCS 9301210143
Download: ML20127G093 (8)

Text

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PilILADELPillA ELECTRIC COMi%NY 10CPR50.90 NUCLliAR GROUP lillADQUARTliRS 955-65 CllliSTl!RilROOK llLVD.

WAYN!!, PA 19087-5691

"*" January 12, 1993 NucttAR $1:RVirl.S !)l fwl4 MENT DOchot Hon. 50-352 50-353 Licensu Noo. NPF-39 NPP-85 U.S. Nuclear Regulatory Commianlon ATTH: Document Control Desk washington, DC 20555

Subject:

Limerick Gonorating Station, Units 1 and 2 Technical Specifications Chango Roquest Incorporation of Changos Roquestod by the NRC Gentlemon:

Our lotter dated April 3, 1992, oubmittod -Technical Specifications (TS) Chango Roquest No. 90-20-0, That submittal requested that the TS Survoillanco Roquiremonto (SRs) for the Standby Liquid control (SLC) system be changed to: 1) uno the daily check of the SLC syatem pump suction piping temperature to verify system operability, rather than verifying heat tracing operability; 2) verify that the SLC oystem piping in not blocked by pumping the SLC system solution from the storage tank to a test drum, rather than to the test tank; and 3) requiro only ono SLC ntorage tank heater to be operabla for system operability, rather than the two heators that are currently required.

The NRC responded to our April 3, 1992 TS Change Roquest by lottor dated July 16, 1992, and requestod that we considor substituting the portinent sections of the SLC system requiromonto in the draf t improved Standard TS (STS) (i.e., NUREG-1433). As otated in tho. Ju)y 16, 1992 NRC letter, substitution of the portinent SRs specy fietl in-the draft improved STS would provido more flexibility wn.L mspect to verifying system operability since the STS requiromonto focus on the paramotorn important to safety, such as verifying that the temperature of the sodium pontaborate solution is above the point where it would precipitate out of solution, rather than-the various means of achieving this result.

l In kooping with this focus, the STS doen not contain SRs for the heat tracing or storage tank heators.

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. j U.S. Nuclear Regulatory Commission Pago 2 Because of the clear benefits that would result from adopting the portinent STS SRs, we agrood to the NRC requestod substitution.

Accordingly, we re-evaluated the incorporation of the portinent STS  :

SRs into our April 3, 1992 Chango Roquest, and datormined that our  !

original conclusions with respect to the Significant- Ilazards Consideration of the proposed changes remained valid. .Thoroforo, thir; lotter submits the requested substitution of the portinent STS '

SLC system SRs to replace the proposed changes in our April 3, 1992 Chango Roquest.

. Information supporting our conclusion that substitution of the portinent STS SRs in place of our originally proposed changes is bounded by our original consideration of significant hazards is contained in Attachment 1 to this lettor. The proposod roplacement pages for the 14S, Unit 1 and Unit 2 TS are contained in Attachment ,

2. We request that, if approved, the Amendments bo issued by  ;

February 5, 1993, and bo immediately offectivo, in order to take advantage of the . STS improvements during the second Unit 2 i refueling outage scheduled to begin on January 23,-1993. -The ability to use the STS SR' 1 r establishing and maintaining the SLC .

system operability will .. a substantial bonofit with respect to i the outage schedule.

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

Very truly.yours, ,

/ Gk G. Dock, Manager Licensing Section GJB:on Attachments cc T.T. Martin, Administrator, Region I, USNRC (w/ attachments)

T.J. Kenny, USNRC, Senior Resident Inspector, LGS (w/ attachments)

W.P. Dornolfo, Commonwealth of Pennsylvania (w/ attachments) liquid.ltr

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COMM0!iWEALTi{ OF PElitiSYLVAliIA I ss.

COUllTY OF CliESTER t D. R. 11elwig, being first duly sworn, deposos and sayst That he is Vice President of Philadelphia Electrio Company; the Applicant heroint that he has road the foregoing revised-Application for Amendments to Facility Operating Licenso lios.

IIPF-39 and fiPF-85 (Technical Specifications Change Roquest 11o.

90-20, Rovision 1) to change the Standby Liquid control system survoillance requirements, and knows the contents thoroof; and that tho statomonts and matters not forth thoroin are true and correct to the best of his knowledge, information and belief.

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-Vice Pros t Subscribed and sworn to beforo f mo this . }b- -

< - day of MIA . 1993.

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'I ATTACllMENT 1 LIMERICK GEllERATIllG STATION UNITS 1-AND'2  ;

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Docket Nos. 50-352  !

50-353 License Nos. NPF-39 i llPF-85 F

i REVISED TECIINICAL-SPECIFICATIONS CilANGE REQUEST- i No.-l90-20-0, Revision;1

" Revision of' Standby Liquid Control

.Surveillanco.Roquirements" Supporting Information for Chang 0s - 4-pagos '

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Attachment 1 pago 1 This revised Technical Specifications Chango Roquest substitutos the pertinent Standby Liquid control (SLC) system  ;

Surveillanco Requirements (SRs) from the draf t improved Standard TS  !

(STS) (i.e., NUREG-1433) in place of the changes proposed in our lotter dated April 3, 1992. This substitution was requested by the NRC in its lottor dated July 16, 1992. This substitution of the STS SRs results in the following proposed changes.

1) Allow the flexibility in the method (s) used to verify that the heat traced SLC system piping is unblocked rather than ,

specifying a test flow path. *

2) Doloto the requirement to maintain both of the SLC system storage tank heaters operable, since operability of tho 1 SLC system is based in part on the temporature of the sodium pontaborato solution in the SLC system storage tank rather than the method used to achiavo a particular temperaturo (i.e., verifying operability of the tank heaters).  !

3) Clarificationc with respect to when and the period within ,

which certain SRs are to be performed.

A description of the proposed TS changes, and a discussion of applicability of the information supporting a finding of No Significant Hazardo Considoration and information supporting an t Environment Assessment provided in our April 3, 1992 Change Request to the revised proposed TS changes, are provided below.

We request that, if approved, the Amendments to the Limerick i Generating Station (LGS), Unit 1 and Unit 2 TS be issued by February 5, 1993, and bo immediately offectivo in order to support ,

the scheduled activities during the Unit 2 second refueling outage.

This refueling outage is scheduled to_begin on January 23, 1993.

Dgscription of the Proposed Changer 2 The following is a- description of the proposed. .changos, including identification of those proposed changes that have been revised to incorporate the pertinent STS SRs.

1) Change TS- SR 4.1.5.a.3 from requiring that the SLC system heat tracing circuit be demonstrated operable, to requiring that tho temperature of each SLC; pump suction

i. piping be greater than or equal to 70*P.

2) Revise the original proposed change to add the following to the footnote for TS SR 4.1. 5.b. 2 : "within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after water or boron addition or solution temperature is i restored."

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Attachment 1 page 2

3) Reviso tho original proposed chango to TS SR 4.1.5.d.2 and associated footnote to require that all heat traced piping betwoon the SLC system storage tank and SLC system pump

( suction piping is veriflod to be unblocked, and that thi.

verification shall also bo performed whenover SLC system pump suction piping temperature drops below 70'F, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after solution temperature is rantored.

4) Reviso the original proposed change to TS SR 4.1.5.d.3 to requiro that only the "A" storago tank heater bo demonstrated operable by deleting the requiremont to demonntrate that the SLC system storago tank hohtors are operablo.

b plncussion of Apolicability of Original Information GupnortiDG_a l'iDt11Ag_ of No SiG Dificant Hazards Consideration to ti l o Revised Proposed TS ChangCR The information supporting a finding of No Significant 11azards Consideration provided in our April 3, 1992 Chango Roquest was ovaluated with respect to the revised TS changos proposed hero.

The basis of our original conclusion that the proposed changes do not involve a Significant llazards considoration reflected the recognition that the verification of SLC system operability should focus on maintaining or recovering the required temperature of the sodium pontaborate solution, and not on the means of achieving the solution temperature required to provent precipitation. Sinco the-revised proposed changos are consistent with this focus, our original conclusion that the proposed changes do not involve a.

Significant flazards Consideration remains unchanged based on the information provided below.

1) The revised nronosed TS chancos do nn.t__involvo a sionificant increase in the probability or consecuences of v

an_ngcident nrg,iousiv ovaluated.

The revised proposed SR to verify that the SLC system pump suction lino is unblocked does not delineate a specific flow path.

The current TS SR specified flow path from the SLc system storago tank to the test tank croatos a largo amount of liquid wasto requiring special handling as a result of the pcst-test pipe flushing. An alternativo testing method would be to pump solution from the storage tank to a test drain. This would reduco the amount of piping and equipment subjected to the flow of the sodium pontaborate solution and the subsequent required flushing.

Accordingly, the result of performing the proposed SR would be equivalent to performing the current. SR; affected heat traced piping would continuo to be verified unblocked. The revised proposed SR dolotes'the prescribed method specified in tho current and originally proposed TS,_and thereby allows flexibility in the

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4 Attachment 1 Page 3 methods employed to perform this SR verification. The revised proposed SR also includes a clarification of the period during which this SR is required to be performed if the piping temperaturo drops below the low temperaturo limit (i.e., 70*F).

The revised pro?osed SR changes includo dolotion of the required demonstratnon of SLC system storage tank heater operability. This proposed chango is based upon the ultimate objective of datormining SLC system operability as a function of the temperature of the sodium pontaborato solution in the storage tank, which the TS will continue to require to be checked daily, and not on the method of achieving this verification.

Specifically, the storage tank heators are the "A" heator, a 10KW cycling heater (i.e. , controlling solution temperaturo betwoon 75* F and 85'F), and the "B" heater, a 40KW manually oporated heator used primarily during solution mixing activities. The storage tank is located within heated spaces of the Reactor Enclosure that are normally maintained at or above the "A" heator low temperature activation sotpoint of 75'F. Furthermoro, low storage tank solution temperaturo (i.e., 70'F) is alarmed in the Main Control Room.

In addition, the revised proposed SR includes clarification of the period within which the verification of solution concentration is required to be performed after water or boron is added to the storage tank, or .f the solution temperature drops bolow 70'F.

This clarification is based on the recognition of realistic tino limits to perform actions to preclude precipitation of the sodium pontaborato.

Based on the above discussion, our previous concluuion that the proposed changes do not involvo an increase in the probability or consequences of an accident previously evaluated remains unchanged.

2)- The= revised nronosed TS chances da not creato the possibility of a new or different kind of accident fr2m any accident nreviously evaluateh The revised proposed changes to the SLC system SRs do not add or doloto any equipment, and do not involve any systems or equipment that would creato an accident. Thorofore, our previous-conclusion that the proposed changes da not create the possibility of a new or different kind of accident from any accident previously evaluated remains unchanged.

3) The revised nronosed TS chances do not involve a sinnificant reduction in marain of safety.

The revised proposed changes to the SLC system SRs do not involve physical changes to the system, and continuo to provido an 1

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Attachmont 1 page 4 equivalent level of assurance that the SLC system will be capable of performing its safety function. Thorofore, our previous-conclusion that the proposed changes do not reduce the margin of safety remains unchanged.

Dj ecussion_ of Appligability of. original Information Supnpitino an EnvironmorttalAgngEment to the Revised _Fronosed TS_ Chanti qg our conclusion that an environmental assessment is not required for the changes proposed in our original Change Roquest dated April-3, 1992, remains unchanged with respect to the revised changes proposed here. The revised proposed changes do not involve a significant flazards Consideration as discussed in the preceding section. The revised proposed changes still do not involve a significant change in the types or significant increaso - in the amounts of any offluents- that may be reloaned offsite. In addition, the revised proposed changos still do not involve an increano in the individual or cumulative occupational radiation exposure. Thorofore, the revised proposed TS changes continue to conform to the critoria for " actions eligiblo for categorical exclusion" as specified in 10CFR51.22 (c) (9) .

Conclusion The Plant Operations Review Committoo and the Nuclear Review ,

Board have reviewed those revised proposed changes-to the LGS Unit i

- 1 and Unit 2 TS, and have concluded that they do not involve-an  ;

unreviewed safety question, or a Significant flazards Considoration, and will not endanger the health and safety of the public. 1-1

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