ML20151X609

Application for Amend to License NPF-39,revising Tech Spec Limiting Conditions for Operation & Surveillance Requirements to Reflect Addition of RHR Svc Water High Radiation Indicating Light to Remote Shutdown Sys

ML20151X609
Person / Time
Site:	Limerick
Issue date:	04/28/1988
From:	Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20151X602	List: ML20151X598 ML20151X609 ML20151X615
References
NUDOCS 8805040196
Download: ML20151X609 (11)

Text

_ _ _ _ _ _ _ _ _ - _ _____-- - ___________-__ _____ - ___-___________ ____ . . - _ _ _ _ - _ _ _ _ _ - __ ___ _-_ _.

BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of  :

,  : Docket No. 50-352 PHILADELPHIA ELECTRIC COMPANY APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSE NPF-39 Edward G. Bauer, Jr.

Eugene J. Bradley i 2301 Market Street Philadelphia, Pennsylvania 19101 Attorneys for Philadelphia Electric Company pggsagagegigagjg2 P

F BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of  :

Docket No. 50-352 PHILADELPHIA ELECTRIC COMPANY APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSE NPF-39 Philadelphia Electric Company, Licensee under Facility Operating License NPF-39 for Limerick Generating Station Unit 1, hereby requests changes to the Technical Specification Limiting Conditions for Operation and Surveillance Requirements contained in Appendix A of the Operating License to reflect the addition of a Residual Heat Removal Service Water high radiation indicating light to the Remote Shutdown System. Proposed changes are indicated by a vertical bar in the margins of the attached copies of pages 3/4 3-77 and 3/4 3-83.

DISCUSSION:

The Residual Heat Removal Service Water (RHRSW) system is designed to provide a reliable source of cooling water for all operating modes of the RHR system, including heat removal under

' post-accident conditions. It also provides water to flood the reactor core or to spray the primary containment after an accident, if necessary.

The RHRSW system is designed to be common to the two reactor units and consists of two independent loops. Each loop takes suction from the spray pond, services one RHR heat exchanger.per. unit, and. discharges to..the spray _ pond... Radiation levels in each loop are monitored via radiation monitors.

The RHRSW radiation monitoring system includes four channels to monitor discharge from each of the four heat exchangers and two channels to monitor the common RHRSW discharges from Units 1 and 2 to the spray pond. Each channel includes a scintillation detector and radiation monitor.

l Presently, high radiation in the RHRSW discharge from the Unit 1. loop 'A' RHR heat exchanger (IAE205) outlet and the common RHRSW discharge line to the spray pond is indicated by annunciators in the Main Control Room. Additionally, an amber indicating light on the Remote Shutdown Panel 10C201 indicates a high radiation condition at the Unit 1 loop 'A' RHR heat exchanger (IAE205) outlet.

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In the event that the main control room becomes uninhabitable and a controlled shutdown of the plant must be performed remotely, control will be transferred to the Remote Shutdown Panel located in the Auxiliary Equipment Room. Manual transfer of control to the Remote Shutdown Panel disables the trip functions from the radiation monitors associated with the loop 'A' RHR heat exchanger (lAE205) and the loop 'A' discharge to the spray pond. The existing amber light on the Remote Shutdown Panel provides the operator with the high radiation 1

condition information necessary to manually isolate the 'A' loop of RHRSW should a high radiation condition exist at the outlet of the heat exchanger.

The addition of the amber indicating light to the Remote Shutdown Panel provides indication to the operator of a high radiation condition in the RHRSW loop 'A' (only loop 'A' can be controlled from the Remote Shutdown Panel) discharge line to the spray pond. This additional indication ensures that the operator l

will be provided the opportunity to isolate the RHRSW system

( should a high radiation condition exist in the RHRSW discharge line to the spray pond.

l Based on the design and installation described above in regard to the Remote Shutdown System (RSS) and the RHRSW system, Licensee proposes to list the additional indicating light in the tables of Remote Shutdown System Instrumentation and Controls contained in the Technical Specifications such that the additional RHRSW loop 'A' high radiation indicating light on the Remote Shutdown Panel will be included as a Limiting Condition

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for: Operation and-routinely surveillance tested to demonstrate

. operability.

List of Proposed Changes Page 3/4.3-77 Changes are to add RHRSW Table 3.3.7.4-1 Loop 'A' Return High Radiation Indication Page 3/4 3-83 Changes are to add RHRSW Table 4.3.7.4-1 Loop 'A' Return High Radiation Indication SAFETY ASSESSMENT:

c A discussion of the Safety Significance of the proposed changes to the Technical Specification follows. Following the discussion of the safety significance, a separate discussion is presented for each of the three standards as set forth in 10 CFR Section 50.92 to support the Licensee's conclusion that the changes do not involve any Significant Hazards Considerations.

o The modification will enhance the ability to safely >

shutdown the plant from the Remote Shutdown Panel.

In the event that the main control room becomes uninhabitable and a controlled shutdown of the plant must be performed from the remote shutdown panel, as a result of an accident as evaluated in FSAR Section 15.9.7, Event 52, "Reactor

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Shutdown from Outside Control Room", the additional RHRSW high radiation indicating light will serve to enhance the sale

performance of the remote shutdown procedure. In the event that high radiation levels are detected in the RHRSW system an

. automatic isolation of the RHRSW will not occur while con, 04Aing the unit from the Remote Shutdown Panel. This indicating lamp will provide the operator a redundant means of monitoring loop

'A' of the RHRSW system for high radiation from the Remote Shutdown Panel. The signal to the indicating lamp originates from an existing detector which currently provides the high radiation signal to the Main Control ..oom only. The additional high radiation indication lisht for the RHRSW loop 'A' discharge to the coe'ing pond together with the existing high radiation indicating light from the Unit i loop 'A' RHR heat exchanger lAE205 will ensure that plant operators can take the appropriate steps, such as manual isolation of the system, to mitigate the 4

consequences of such an incident.

o The design of the modification meets all required design ef teria.

i The modifications to the plant meet the design requirements of the guidelines of Standard Review Plan Section 7.4.2.3, 7.6.1 and 11.5. The design and implementation of this

- adific'stion has ao negative effect on the ability to safely

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chvidov ' + plant in the event of a fire as required by Appendix

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• Section 50. The performance of design verification

/. scordance with the Technical Specification surveillance t

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requirements for the Remote Shutdown System instrumentation and controls have demonstrated the operability of the modified system a

in accordance with General Design Criteria 19, "Control Room",

design requirements as interpreted by SRP Section 7.4.

CONCLUSION - SAFETY ASSESSMENT:

The plant modifications to the Remote Shutdown System meet the requirements of the applicable General Design Criteria.

The purpose of this amendment is to add the testing of the indicating light to the existing surveillance requirements for the remote shutdown system. Based on the design and fact that this modification provides indication of.a parameter at the remote shutdown panel which is currently monitored during normal Operation in the contcol room, it does not pose a safety concern. j I

SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION:

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(1) The proposed changes to the Technical Specifications to list the additional indicating lamp do not involve a significant increase in the probability or consequences l 1

of an accident previously evaluated. I l

Aa evaluated in Section 7.4.1.4 of the FSAR, the main objective of the RSS provides a means to carry out the reactor  !

shutdown functions including manual isolation of the RHRSW system l

"' from outside the main control room and bring the reactor to a cold condition in a rafe and orderly fashion. The design, which

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includes the additional indicating lamp on the remote shutdown panel, is in compliance with the General Design Criteria 19, "Control Room", and its inclusion into the existing list of Remote Shutdown System Instrumentation and Controls Technical Specification requirements, therefore will not increase the probability or consequences of an accident as evaluated in FSAR Section 15.9.7, Event 52.

(2) The proposed changes to the Technical Specifications to list the additional indicating lamp do not create the possibility of a new or different kind of accident trom any previously evaluated.

l The modification to the RHRSW system and the Remote Shutdown System provides a redundant means of monitoring high radiation in the RHRSW system from the Remote Shutdown panel.

This indicating light performs a monitoring function only and its inclusion into the list of Remote Shutdown System Instrumentation and Controls Limiting Condition for Operation and Surveillance Requirements does not create a new or different kind of accident i

than that which was previously evaluated in FSAR Section 15.9.7, Event 52.

(3) The proposed enanges to the Technical Specifications to list the additional indicating lamp do not involve a significant reduction in a margin of safety.

4 The Remote Shutdown ~ System is designed to provide a means to carry out the reactor shutdown functions from outside the main control room and bring the reactor to a cold condition in a safe and orderly fashion. This is accomplished by the remote shutdown panel in the auxiliary equipment room. This

. indicating light provides a redundant means of monitoring high radiation of the RHRSM at the remote shutdown panel. This redundant monitoring capability will serve to enhance the margin of safety and ensure that operators have the ability to isolate the RHRSW system if required during a remote shutdown event.

Therefore, the inclusion or the additional indicating light into the list of Remote Shutdown System Instrumentation and Controls Limiting Conditions for Operation and Surveillance Requirements does not involve a reduction in the margin of safety.

CONCLUSION:

1 Based on the discussion above, operation of the facility under the proposed Technical Specifications with regard to the l addition of the indicating light to the Remote Shutdown System l

list of Limiting Conditions for Operation and Surveillance Requirements does not involve Significant Hazardo Consideration.

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ENVIRONMENTAL CONSIDERATION:

i This amendment would include an additional RHRSW High Radiation Light to the list of Remote Shutdown Ljstem Instrumentation and Controls Limiting Conditions for Operations I

l and Surveillance Requirements in the Technical Specifications.

Licensee has determined that the proposed amendment involves no increase in the a' nts and no change in the types of any effluents that may be released offsite and has also determined that there is no increase in the individual or cumulative occupational radiation exposure. Therefore, there is no environmental consideration involved and consequently an environmental report is not submitted.

L conclusion:

The Plant Operations Review Committee and the Nuclear

.. . Review Board.have reviewed.these+ proposed changes to the Technical Specifications and have concluded that they do not involve unreviewed safety questions or involve significant hazards considerations or an environmental consideration and will not endanger the health and safety of the pub 1!.7.

Respectfully submitted,

, PHILADELPHIA ELECTRIC COMPANY l

i' M L LVice Presid6At l

l 9_

J COMMONWEALTH OF PENNSYLVANIA  :

I ss.

COUNTY OF PHILADELPHIA  :

i J. W. Gallagher, being first duly sworn, deposes and says:

That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing Application for Amendment of Facility Operating License DPR-44 and knows the contents thereof; and that the statements and

- matters. set forth therein-are-true and correct to the best of his knowledge, information and belief.

Mv bh u Vice President '

ii t

i Subscribed and sworn to 1

before me this 2D,day W of April, 1988

,M't e- e' -

++$' d {

Notary Public MELANIE R. CAMPANELLA Newy Pbbte. PMadelpMs. PhaadelpNa Co.

Mr Com%sion Expires Februesy 12,1990 y- y - - - - - - - - - ,,-r -y- --wr-- -------wor--- - - -

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