ML20138A050

Forwards Amend 1 to License NPF-39 & Related SER Supporting Amend,In Response to 860305 Request

ML20138A050
Person / Time
Site:	Limerick
Issue date:	03/07/1986
From:	Rutberg J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Cole R, Linenberger G, Smith I Atomic Safety and Licensing Board Panel
References
CON-#186-356 OLA, NUDOCS 8603140014
Download: ML20138A050 (13)

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UNITED STATES

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Ivan W. Smith, Chairman Mr. Gustave A. Linnenberger Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory Commission U.S.

Nuclear Regulatory Commission l

Washington, D.C.

20555 Washington, D.C.

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Dr Richard F. Cole Administrative Judge l

Atomic Safety and Licensing i

Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

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In the Matter of PillLADELPillA ELECTRIC COMPANY (Limerick Generating Station, Unit 1)

Docket Nos. 50-352-OLA (Check Valves)

Dear Administrative Judges:

This letter is in response to Chairman Smith's letter dated March 5, 1986.

Chairman Smith requested the Staff to provide the Licensing Board with a copy of the amendment that was issued on February 6, 1986, to which the Staff referred in its response to the Licensee's motion to defer filing answers to FOE's proposed contentions.

I have enclosed a copy of a letter dated February 6, 1986 sent to Mr. Edward G. Bauer, Jr., Vice-President and General Counsel, Philadelphia Electric Company from Walter R.

Butler, Director, IlWR Project Directorate No.4.

Mr. Butler's letter encloses a copy of Amendment No. I to Facility Operating License No. NPF-39 and a copy of the related safety evaluation supporting this amendment.

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The Staff will make every effort to assure that the Licensing Board is provided with copies of all documents referenced in its filings.

Sincere l

J h Rutherg Assistant Chief Ilear g Counsel

Enclosures:

As stated cc y/o enclosures: Service List

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Docket No. 50-352

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11r. Edward G. Bauer. Jr.

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Vice President and General Counsel Philadelphia Electric Company V

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2301 liarket Street

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Philadelphia, Pennsylvania 19101

SUBJECT:

ISSUANCE OF AMENDMENT N0. 1 TO FACILITY OPERATING LICENSE NO. HPF-39, LI!!ERICK GENERATING STATION, UNIT 1 The Nuclear Regulatory Commission has issued the enclosed Amendment No. I to Facility Operating License No..NPF-39 for the Limerick Generating Station, Unit 1.

This amendment is in response to your letter dated Decerrber 18, 1985.

The amendment extends on a one-time-only basis the surveillance requirements in the Technical Specifications for excess flow check valves which must be perfonned nominally every eighteen months and which can be done only when the plant is shutdown.

Your reason for this extension is that Limerick, Unit I has experienced an extended startup program schedule and has been shutdown for much of the first eighteen mcnth surveillance interval. Therefore you have requested a temporary extension of fourteen weeks in the surveillance testing to allow the testing to be performed during a maintenance and surveil-lance testing outage which will begin on or befere May 26, 1986.

A copy of the related safety evaluation supporting Amendment No. 1 to Facility Operating L.fcense NPF-39 is enclosed.

Sincerely,

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Walter R. Butler, Director BWR Project Directorate No. 4 Division of BWR Licensing

Enclosures:

1.

Amendment No. 1 to NPF-39 2.

Safety Evaluation cc:

See next page

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Mr. Edward G. Bauer, Jr Limerick Generating Station Philadelphia Electric Company Units 1 & 2 CC*

Troy B. Conner, Jr., Esquire Nr. Marvin I. Lewis Conner and Wetterhahn 6504 Bradford Terrace 1747 Pennsylvania Ave, N.W.

Philadelphia, Pennsylvania 19149 Washington, D. C.

20006 Zori G. Ferkin Frank R. Romano, Chairman Assistant Counsel Air & Water Pollution Patrol Goverror's Energy Council 61 Forest Avenue 1625 N. Front Street Ambler, Pennsylvania 19002 Harrisburg, Pennsylvania 17105 Federic M. Wentz Charles W. Elliott, Esquire Ccunty Solicitor Brose & Poswistilo, 1101 Bldg.

County of Montgomery 325 N.10th Street Courthouse Easton, Pennsylvania 18402 Norristown, Pennsylvania 19404 Eugene J. Bradley Ms. M. Mulligan Philadelphia Electric Company Linerick Ecology Action Associate General Counsel 762 Queen St.

2301 Market Street Pottstown, Pennsylvania 19464 Philadelphia, Pennsylvania 19101 Mr. Karl Abraham Thomas Gerusky, Director Public Affairs Officer Bureau.of Radiation Protection Recion I Dept. of Enviromental Resources U.S. fluclear Regulatory Commission 5th Floor, Fulton Bank Bldg.

631 Park Avenue Third and Locust Streets King of Prussia, PA 19806 Harrisburg, Pennsylvania 17120

!!r. Gene Kelly' Senior Resident Inspector U.S. huclear Regulatory Commission P. O. Box 47 Sanatoga, Pennsylvania 19464 w

Philadelphia Electric Company Limerick Generating Station 1/2

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Sugarman, Denworth & Hellegers Director, Pennsylvania Energency 16th Floor Center Plaza Management Agency 101 North Broad Street Basement, Transportation &

Philadelphia, Pennsylvania 19106 Safety Building Harrisburg, Pennsylvania 17120 Robert L. Anthony Angus Love, Esq.

Friends of the Earth 107 East Main Street of the Delaware Valley Norristown, Pennsylvania 19402 103 Vernen Lane, Box 186 Moylan Fennsylvania 19065 Helen F. Hoyt, Chairman Kathryr. S. Lewis, Esq.

Administrative Judge Municipal Services Bldg.

Atomic Safety & Licensing Board 15th and JFK Blvd.

U.S. Nuclear Regulatory Commission Philadelphia, Penrsylvania 19102 Washington, D. C.

20555 David Ucrsan, Esq.

Dr. Jerry Harbour Assistant Consumer Advocate Administrative Judge Office of Consumer Advocate Atomic Safety & Licensing Board 1425 Strawberry Square U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17120 Washington, D. C.

20555 Steven P. Hershey, Esq.

Dr. Richard F. Cole Community Legal Services, Inc.

Administrative Judge Law Center North Central - Bevry 5109 Atomic Safety & Licensing Board 3701 North Board Street U.S. Nuclear Regulatory Commission Philadelphia, Pennsylvania 19140 Washington, D. C.

20555 Mr. J. T. Robb, NS-1 Mr. Spence W. Perry, Esq.

Philadelphia Electric Company Associate General Counsel 2301 Market Street Federal Emersency Management Agency Philadelphia, Pennylsvania 19101 Room 840 500 C St., S.W.

Timothy R. S. Campbell, Director Washington, D. C.

20472 Department of Emergency Services 14 East Biddle Street West Chester, Pennsylvania 19380

Philadelphia Electric Corapany Linerick Generating Station Ur.its 1 and 2 l

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Chairr.an Board of Supervisors of Limerick Township 646 West Ridge Pike Limerick, Pennsylvania 1946E Governcr's Office of State Planning and Development ATTri: Coordinator, Pennsylvania State Clearinghouse P. O. Box 1323 Harrisburg, Pennsylvania 17102 Dept. of Environmental Resources XTTN: Director, Office Radiologic Health P. O. Box 2063 l

Harrisburg, Pennsylvania 17105 l

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NUCLEAR REGULATORY COMMISSION UNITED STATES 8-i wasumorow, p. c.zosos

• 5 PHILADELPHIA ELECTRIC COMPANY DOCKET N0. 50-352 LIHERICK GENERATING STATION, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 1 License No. NPF-39 1.

The Nucleer Regulatory Comission (the Comission) has found that:

A.

The application for amendment filed by the Philadelphie Electric Company dated December 18, 1985, complies with the standards and requirements of the Atomic Energy Act of 1954', as amended (the Act) and the Comission's regulations as set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the regulations of the Comission; C.

There is reasonable assurance:

(1) that the activities authorized by this amendment can be conducted without endangering the. health and safety of the public, and (ii) that such activities will be conducted in compliance with the Comission's regulations set forth in 10 CFR Chapter Il r

D.

The issuance of this license amendment will not be inimical to the comon defense and security or to the health and safety of the public; E.

The issuance of this amendment is in accordance with 10 CFR Part 51 l

of the Comission's regulations and all applicable requirements have j

been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifi-l cations as indicated in the attachment to this amendment and Paragraph j

2.C(2) of Facility Operating License No. NPF-39 is hereby amended to read as follows:

(2) Technical Specifications i

The Technical Specifications contained in Appendix A and the Environ-U mental Protection Plan contained in Appendix B, as revised through Amendment No. 1, are hereby incorporated in the license. PECo shall r,

a operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

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. 3.

This amendment is effective imediately and is to be fully-implemented within 30 days of the cate of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Walter R. Butler, Director Project Directorate No. 4 Division of BWR Licensing

Attachment:

Changes to the Technical

..Speci fica tions Date of Issuance:'

FEB 0 6.1986 1

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ff ATTACHf1EllT TO LICENSE AMENDMENT NO. 1 FACILITY OPERATING LICENSE NO. NPF-39 DOCKET NO. 50-354 i

Replace the folicwing pages of the Appendix A Technical Specifications with the enclosed pages. The revised pages are identified by Amendment number and contain vertical lines indicating the area of change. Also to be replaced are the following cycrieaf pages to the amended pages.

Amendment Pages Overleaf Pages l

3/4 6-18 3/4-6-17 l

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CONTAINMENT SYSTEMS 3/4.6.3_ l'RIMARY CONTAINMENT ISOLATION VALVES 1.lMlllNG CON 0lll0N 10R OPERAl10N 3.6.3 1he primary containment isolation valves and the reactor instrumentation-line excess flow check valves shown in Table 3.6.3-1 shall be OPERABLE with isolation times less than or equal to those shown in Table 3.6.3-1.

APPLICABILITY:

OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

a.

With one or more of the primary containment isolation valves shown in Table 3.6.3-1 inoperable, maintain at least one isolation valve OPERABLE in each affected penetration that is open and within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> either:

1.

Restore the inoperable valve (s) to OPERABLE status, or 2.

Isolate each affceted penetration by use of at least one de-activated automatic valve secured in the isolated position," or 3.

Isolate each af fected penetration by use of, at least one closed manual valve or blind flange."

4.

The provisions of Specification 3.0.4 are not appilcable provided that within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> the affected penetration is isolated in accordance with ACTION a.2. or a.3. above, and provided that the associated system, if applicable, is declared inoperable and the appropriate ACTION statements for that system are performed.

Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTOOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, b.

With one or more of the reactor instrumentation line excess flow check valves shown in Table 3.6.3-1 inoperable, operation may continue and the provisions of Specifications 3.0.3 and 3.0.4 are not appilcable provided that within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> either:

1.

The inoperable valve is returned to OPERABLE status, or 2.

The instrument line is isolated and the ass'ociated Instrument is declared inoperable.

Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUIDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

• lsolation valves closed to satisfy these requirements may be reopened on an intermittent basis under administrative control.

LIMERICK - UNIT 1 3/4 6-17

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORT AMEN 0 MENT NO. 1 TO FACILITY OPERATING LICENSE NO. NPF-39 PHILADELPHIA ELECTRIC COMPANY j

LIMERICK GENERATING STATION. UNIT NO. 1 DOCKET NO. 50-352 1.0 Introduction 5

By letter dated December 18, 1985, the Philadelphia Electric Company (the licensee) requested a one-time-only approval for temporarily extending certain surveillance requirements in the Technical Specifications, which must be

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performed nominally every 18 months and which can only be'done when the plant

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is shutdown. The change would extend the 18 month s'arveillance interval by 14 weeks beyond the' maximum 25 percent extension allowed by the Technical Specifications. This would permit the licensee to delay performing this i

testing until a maintenance and surveillance outage which will begin.on or before May 26, 1986.

j 2.0 Evaluation i

4 Technical Specification (TS) 4.6.3.4 requires that instrumentation line excess flow check valve surveillance tests be perforued at a nominal frequency of i

j once per 18 months. Since the Limerick Unit 1 plant has been through an I

extended startup program schedule, which included relatively little startup testing program activity from about April to early August 1985, the scheduled surveillance tests fall in a kriod of what would otherwise be a continuation 2

i of first fuel cycle power operations.

Since the plant must be shutdown for '

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about two weeks to perfor1n these tests and since the ' licensee plans to shut the plant down on or before May 26, 1986 to perform other surveillance tests and maintenance activities the licensee proposes to extend the surveillance i

interval for the excess flow checkvalves to allow those tests to also be performed during the outage to begin on or before May 26, 1986.

The 18 month surveillance interval was selected to be consistent with the maximum anticipated interval between refueling outages.

However, TS 4.0.2 j

does allow the time interval between surveillance testing to be extended by 25 percent in order to provide flexibility in operations scheduling. The end i

of the most limiting surveillance interval, including the allowable 25 percent

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extension for the excess flow checkvalves in TS 4.6.3.4 (Table 3.6.3-1) is j

February 19, 1986. Therefore, the temporary TS change would extend the per-missible time to perform these tests from approximately 23 months to approximately 26 months.

l The requirements of the TS for testing nominally every 18 months for which i

extensions are proposed and the reason these tests can only be perforined while 1

the reactor is shutdown are as follows.

The excess flow check valves in TS

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Table 3.6.3-1 are provided in instrumentation lines for the purpose of checking flow in the line when subjected to an excessive differential pressure.

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l i Testing of the valves to verify that they check flow involves opening of the

' instrumentation line downstream of the valve with the reactor coolant system cold and pressurized and verifying that the valves check flow.

This operation cannot be performed during normal power operation for the following reasons:

(1) the performance of the test with the reactor coolant system hot, pressurized and at power would involve potential hazards to testing personnel upon opening of the line in the unlikely event that one of the valves fails to check and releases fluid that is both at a high temperature and radioactive, and (2) the opening of the instrumentation line, since the line may serve an instrumentation manifold with multiple transmitters, would result in multiple engineered safety feature system and/or reactor protection system actuations which would either constitute conditions prohibited by Technical Specifications or result in a shutdown of the reactor.

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j The " safety related aspects of extending this ' surveillance interval on a one r

l time basis for about three months are insignificant for the following reasons.

(1) Flow through the valves or from the lines in which they are located will be limited by the small line size and the provision of flow restricting orifices to further reduce potential flow rates, (2) Any leakage from these lines outside of primary containment would be contained in the secondary containment and processed by the standby gas treatment system. The analysis of such an event has already been performed and is included in the Final Safety Analysis Report in Section i

15.6.2.

As indicated in the FSAR there would likely be a variety of' indicators to the operator of a failed instrument line thus alerting plant staff to the need to isolate the line by use of other manual valves in the line. The staff has i

previously reached the conclusion in section 15.6 of the SER that the Limerick 3

instrument line design is acceptable.

(3) The licensee has examined the records of the initial flow testing performed on these valves and found that all valves were tested successfully.

The licensee further states that, based on available data, the valves are believed to be highly reliable in performing their function i

of checking flow. The staff concludes that the condition of the valves is not expected to change significantly during the short extension period.

Based on the above, the NRC staff concludes that extension.of the interval for j

the surveillance testing by 14 weeks on a one-time-only basis is acceptable because the increased surveillance interval does not significantly increase j

the possibility that an undetected failure will occur in the instrumentation j

line excess flow check valves covered by this Technical Specification.

3.0 Environmental Consideration j

This amendment changes some surveillanc'e requirements on a one-time-only basis.

The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may i

be released offsite and that there is no significant increase in individual or l

cumulative occupational radiation exposure. The Comission has previously l

1ssued a proposed finding that this amendment involves no significant hazards considerationtand there has _bten_no__publ.ic_comen on such finding within the l

i time provided by thelederal Regliter_ notice._of_ cons it Jipr___Df;the FcEsee~'s i

ymerfdment request _Jhm there is_nn_need_to_make_a_, final determiiia'tibn regarding j

nTirgnifEnt hazards consTdeEion., Accordingly, thTsTmehanieWt meets the-~ ~

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o eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact statement nor environmental assessment need be prepared in connection with the issuance of this amendment.

4.0 Conclusion The staff has concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security nor to the health and safety of the public.

Principal Contr'ibutors:

R. E. Martin, S. Kucharski, J. S. Guo, J. Page Dated: FEB 06 $86 4

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