ML20153C203

Application for Amend to License NPF-39,changing Tech Specs for Clarification,To Correct Errors to Achieve Consistency or for Editorial Changes

ML20153C203
Person / Time
Site:	Limerick
Issue date:	02/13/1986
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20153C202	List: ML20153C198 ML20153C203 ML20153C207
References
NUDOCS 8602190035
Download: ML20153C203 (22)

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BEFORE THE 1

! UNITED STATES NUCLEAR REGULATORY COMMISSION i

l In the Matter of  :

Docket No. 50-352 l PHILADELPHIA ELECTRIC COMPANY t

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APPLICATION FOR AMENDMENT f

t OF' FACILITY OPERATING LICENSE NPF-39 a

i Edward G. Bauer, Jr.

Eugene J. Bradley

2301' Market Street j Philadelphia, Pennsylvania 19101 i

j Attorneys for 1

Philadelphia Electric Company 1

8602190035 860 $52 i PDR ADOCK O PDR l

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BEFORE THE UNITED STATES NUCLEAR R$GULA'IORY COMMISSION

! In the Matter of  :

Docket No. 50-352 PHILADELPHIA ELECTRIC COMPANY

.I APPLICATION FOR AMENDMENT

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, OF i FACILITY OPERATING LICENSE t

NPF-39 y. , ,

i Philadelphia Electric Company, Licensee under Facility Operating License NPF-39 for Limerick Generating Station Unit 1, hereby requests that the Technical Specifications contained in i

Appen' dix A of the Operating License be amended as indicated on the attached proposed revised pages of Appendix A. The proposed changes are indicated by a vertical bar in the margin of the page. -

The changes to the Technical Specifications proposed I

herein generally consist of changes needed for clarification, for I correction of errors or to achieve consistency, or are changes of an editorial or administrative nature. The need for the proposed l

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changes has been identified as experience is gained. operating under the Technical Specifications.

The proposed achanges to the Technical Specifications are described more specifically below, together with a discussion of their significance with particular emphasis on the Commission's guidance on Significant Hazards Considerations (48 Fed. Reg. 14870).

Items 1 thru 3 Item 1 Page 3/4 7-22 Delete Reference to 5% Power (*)

l Item 2 Page 6-14 Delete Reference to 5% Power (*)

2 Item 3 Page 3/4 3-85 Delete Reference to Criticality (t) and Page 3/4 3-85 Add "/" Between "1" and " 'oc'ation" i -

'+ The Commission has provided examples of amendments not likely to involve Significant Hazards Considerations. One l1 example, (i) would be, "A purely administrative change to Technical Specifications . . . to achieve consistency throughout l.

b the Technical Specifications, correction of an error, or a change in nomenclature."

Items 1 thru 3 listed above fall in the example category of being purely administrative in nature or typographical errors l and therefore do not involve Significant Hazards Considerations.

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I Item 4, Page 3/4 3-21 and l' Item 5, Page 3/4 3-22 .

.g To eliminate ambiguity, Licenhae proposes that the

. engineering units " inches of H20" be added to the primary and l secondary containment isolation trip function on the reactor and refuekingdifferentialpressure,lowTRIPSETPOINTandtothe 6

ALL'OWABLE VAFJES as. indicated in Table 3.3(2-2, pages 3/4 3-21

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and 3/4 3-22.

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f These changes are justified as they eliminate ambiguity

, and the possibility for incorrect interpretation and are purely

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an administrative change for correction of anserror, by omission

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.[ of the correct engineering units as,tociated with the specified

\ ru 3 value. Based on the examples given'ty( the Commission for '

u j amendments that are consideYed not likely to involve Signif 'ca'nt Hazards Considerations, the proposed-change is within the scope of example (i) as being a correction of an error, i Item 6, Page 3/4 3-23 i6

[ The addition of TABLE NOTATIONS " (a)" and (**) which

, Licensee proposes to a5S-to page 3/4 3-2s adds further

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, clarification to include < 13 seconds response time for ' .

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j; associated valves (10 seconds diesel generator starting and 3

v seconds sequence loading delays). This change is consistent with

j. .the specifications for the Reactor vessel Water low, low-level 2 and the Main Steamline isolation response times for radiation, i'

flow, and pressure which also includes the < 13 seconds response time.

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'l These added notations eliminate ambiguity and allow for j consistent interpretation. The change -is justified as a

'i clarification of the existing specifications to allow for consistency.

This proposed change falls within the example category 1

(i) of those provided by the Commission for amendments that are

not likely to involve Significant Hazards Considerations, as the proposed change allows for consistency throughout the Technical Specifications, t

! Item 7 - Page 3/4~4-19 The deletion of reference to Figure B 3/4 4.6-2 on page 3/4 4-19 is proposed because Figure B 3/4 4.6-2 does not presently exist in the Technical Specifications. As the -

i reference is superfluous, Licensee proposes its deletion. The I change to page 3/4 4-19 clearly falls within the scope of the examples provided by the Commission of amendments that are

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- considered not likely to involve Significant Hazards Considerations indicated in example (i), as being purely an administrative change to correct an error.

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Item 8, Page 3/4 4-23 The main steam isolation valves which are included in

' Specification 3.4.7 in order to test their closing times at 3 to 5 seconds are also included in Specification 3.6.3 as primary containment isolation valves. The present Specification 3.6.3 on page 3/4 6-17 includes an action statement which allows four

. hours to restore an inoperable MSIV, while Specification 3.4.7 on page 3/4 4-23 presently has a requirement which includes an action statement with a requirement for eight hours to restore an inoperable MSIV.

, The proposed change would allow both Specifications

} 3.6.3 and 3.4.7 to be consistent by revising 3.4.7 to four hours i

l from the existing eight-hour requirement.

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j The proposed change falls into the example category of examples (i) for consistency and example (ii) for being more conservative, constituting an additional limitation than the

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j. existing specification and therefore would not involve any Significant Hazards Considerations.

Item 9, Page 3/4 5-4 and Item 10, Page 3/4 5-5 Allowance was made ( 1 the Technical Specifications by

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the note "**" - at the Lg'. tat .. ? pages 3/4 5-4 and 3/4 5-5 for entry into an operational condition which would allow for sufficient steam for surveillance testing of the HPCI pump .and the ADS. ~ Directions were not given, however, for the condition

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, whereby the surveillance fails and/or HPCI/ ADS operability cannot

! be demonstrated during the twelve-hour period following the i

! availability of sufficient steam supply.

The proposed change adds,a clarifying sentence to the

existing note. The added sentence requires that in the event that HPCI operability is not successfully demonstrated during the twelve-hour period, then the reactor dome pressu're is to be reduced to less than 200 psig. In the event that ADS cannot be

! demonstrated operable during the twelve hour period, then the reactor dome pressure is to.be reduced to 100 psig.

As the proposed change allows for consistency of

.i interpretation, it falls within the scope of example (i) of those examplesprovidedbytheCommissionasexamplesofamendmbts i that are not likely to involve Significant Hazards .

j Considerations.

Item 11, Page 3/4 6-9 and Page B 3/4 6-2 l

The Bases for Specification 3/4 6.1.6 (which discusses the Drywell and Suppression Chamber internal pressure) limits the initial containment pressure prior to a LOCA in order to ensure that the containment peak pressure would not exceed 44.02 psig.

The Limiting Condition for Operation on page 3/4 6-9, however, 'is not in accordance with the Bases and incorrectly restricts the internal pressure to be between 0.0 and +2.0 psig, l while the Bases calls for -1.0 to +2.0 psig. The FSAR Section 1

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V 6.2.1.1.4 evaluated negative pressure in the containment and determined that the primary containment was designed for a negative pressure of -5 psig. In order to achieve consistency and correct these errors, a change is proposed to page 3/4 6-9 to have it agree with the' Bases by cilanging the limitations of the Limiting ' Condition for Operation to -1.0 to +2.0 psig.

Further, the Bases for the drywell and suppression chamber specify that " . . . -1.0 to +2.0 psig. (is) for initial positive containment pressure ...." As the allowable containment

pressure range is actually both negative and positive, the

-deletion of~the word " positive" on page B 3/4 6-2 is proposed as it is incorrect.

The -1.0 psig limit, when viewed from the Bases, Is'more conservative in that a higher additive pressure would now be-required in order to exceed the 44.02 psig peak pressure than was previously required. This proposed change therefore falls into the example category of amendments that are considered not likely to involve Significant Hazards Considerations, as described in paragraph- (i) as " purely administrative change to ... achieve consistency ... (and for) ... correction of an error ...." The proposed change also falls into the example category indicated in-q- example (ii) of those amendments that constitute an additional limitation.

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1 i.y' Item 12, Page 3/4 6-10 The drywell average air temperature is the calculated volumetric average of the-temperature readings at four drywell elevations. At elevation 330' th,ere are three install ~d e

1 temperature sensors, and there are also three sensors installed at elevation 320'; three at 260' and six at 248'.

i The volumetric. calculation requires only that one sensor.

4 at each elevation plane be read, without regard to the sensor

,i (compass) location, i.e. only the elevation location is of interest in the calculation and not the azimuth location.

,i The azimuth has been listed, however, in the surveillance requirements as an informational guide so that the exact location of each sensor may be readily ascertained even though the azimuth of each sensor is not a factor in the actual I calculations. ecause the azimuth of each sensor is listed, the relocation of any of these sensors would require an amendment to

l the Technical Specifications, even though the intent of the Technical Specifications clearly does not require this information as a limit.

Further, some readings taken from'these sensors would be

f. erroneous if the sensor azimuth was not changed due to the close proximity of pipes to some of the sensors. Some of these pipes are substantially different in temperature than the ambient drywell air.

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y Licensee proposes to revise the nomenclature of the j drywell temperature sensors from " azimuth" to " quantity" to allow

! sensor azimuth relocation and preclude erroneous drywell readings

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j relocation of a temperature sensor. In order to allow for physical ~ limitations in the installation of equipment, we propose

to add the word " Approximate" before elevation.

As this proposed change merely changes the information

only designations of " azimuth locations" to " quantity at each elevation" and adds " approximate" before elevation, it falls within the example category of amendments that are considered not likely to involve Significant Hazards Considerations as they,

, constitute "a purely administrative .. . change in nomenclature".

Item 13, Page 3/4 6-12 i

There are eight locations in the suppression pool where i

temperature instruments are located. More than one temperature

, instrument is located at each location. The existing

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.; specification calls for the operability of at least eight I

indicators without a specification as to their location.

Licensee proposes to add an additional limit by adding to paragraph 3.6.2.1.c "... one in each of the eight locations."

so that two at each of four locations, or some other combination of sensors and locations, is not mistakenly recorded and subsequently used during surveillance testing.

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,C Further, as this change constitutes an additional limitation,. restriction or control not presently included in the i technical specification and corrects a typographical error, it i

falls within the scope of examples (i) and (ii) of those examples provided by the Commission that a'er considered not likely to involve Significant Hazards-Considerations.

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Item 14, Page 3/4 6-47 Item 15, Page 3/4_6-52 l The "*" note on the bottom of page 3/4 6-47 and 3/4 6-52 i

I is ambiguous and we propose to revise the note by the use of "or" type logic statements rather than the existing "and" type ~ logic.

This proposed change would then correctly define a period.pthen either the refuel area Secondary containment Integrity or the Standby Gas Treatment Systems are required to be maintsined.' The "and" type logic in the existing specifications -is incorrect.

Based on the examples provided by the Commission that l

are considered not likely~to involve Significant Hazards considerations, the proposed changes are " correction of an error" and fall inside the scope of example (1).

1 Item 16, Page 3/4 6-23

! and Item 17, Page 3/4 6-42 The proposed typographical corrections on pages 3/4 6-23 and 3/4 6-42 to correct "035A" to "035B" are examples of "a change to correct an error" as indicated in example (i) of those

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47 examples provided by the Commission which would be considered not likely to involve Significant Hazards Considerations.

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l Item 18, Page 3/4 6-42 The notes for Table 3.6.3-1 on pages 3/4 6-41, 3/4 6-42 and 3/4 6-43 include directions that designate when "no Type C" testing is required on specific valves listed in the table. Type C testing is indicated as "not required" in notes 1, 10, 12 and

23. The notes are based on 10 CFR 50, Appendix J, Paragraph

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.i The instrument line excess flow check valve which is referenced in note 17, page 3/4 6-42, is installed in a closed cooling water system within containment. Based on the requirements of 10 CFR 50, Appendix J.II.H, these type exceas flow valves do not require " Type C" testing. Due to an oversight, note 17 does not indicate that " Type C" testing is 1 "not required". Therefore, we propose to add a statement in note 17 that " Type C" testing is not required for the instrument line l

excess flow check valve. The addition of this statement would avoid incorrect interpretation of the note.

3 The proposed change would achieve consistency throughout i

the Technical Specifications and falls within the scope of 4

example (i) of the those examples provided by the Commission that are con'sidered unlikely to involve Significant Hazards considerations.

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<w, l Item 19, Page 3/4 6-17 i

Item 20, Page 3/4 6-18 The instrumentation lines inside containment include lines for Reactor Water Cleanup, Reactor Core ' Isolation Cooling,

! High Pressure Coolant Injection, and Drywell Sump level.

l Although all of these instrument lines might be indirectly described as " reactor" instrument lines, they are generally l described by their own system name such as RWCU instrument, or i

RCIC instrument line.

The Technical Specifications on pages 3/4 6-17 and 3/4

, 6-18 refer to " reactor" instrument lines listed in Table 3.6.3-1 and do not reference the other system instrument lines such as RCIC, HPCI and RWCU that are also listed in Table 3.6.3-1.

i, Therefore, Licensee proposes-to delete " reactor" and reference only " instrumentation" line excess flow check valves.

f This proposed change would then allow all of the instrument lines i to be referenced, rather than only the reactor instrument lines. I i

This change conforms to example (ii) of the Commission's guidance in that it is a change that constitutes an additional j limitation, restriction or; control not presently included in the

! Technical Specifications: for example, a more stringent surveillance requirement.

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Allowance was made in the Technical Specifications by I, the note "*" at the bottom of pag'es 3/4 7-9 and 3/4 7-10 for

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entry into an operational condition which would allow for

? ' sufficient steam for surveillance testing of the RCIC system.

1, Directions were not given,-however, for the condition whereby the i

i surveillance fails and/or RCIC operability cannot be demonstrated i subsequent to the twelve-hour period following the availability i

of sufficient steam supply.

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,'- The addition of another sentence to the note "*" at the

': bottom of pages 3/4 7-9 and 3/4 7-10 is proposed to give directions in the event that RCIC operability is not successfully i demonstrated following the twelve-hour period, by direbting that

! in this case, Reactor Steam Dome pressure is to be reduced to

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'l less than 150 psig.

l' As the proposed change allows for consistency of interpretation, it falls within the scope of example (i) of th'se- o

, examples provided by the Commission as examples of amendments that are not likely to involve Significant Hazards Considerations.

Item 23, Page 3/4 8-1 l

L A purely administrative change to the Technical I Specifications is proposed by adding a note to " action b" on page i i

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} 3/4 8-1 to reference the further actions required by " action e" 1

j on.page 3/4 8-2. The existing Technical Specifications do not reference " action e" in " action b",_and therefore " action e"

could be overlooked during performance of " action b".

This proposed' change meets the criteria of example (i) of.those examples of amendments that are considered not likely to

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involve Significant Hazards Considerations as provided by the Commission as an administrative change.

Item 24, Page 6-16 The proposed address change on page 6-16 to correct the l U.S. Nuclear Regulatory Commission address is purely an i

j administrative change as indicated in example (i) of those examples provided by the Commission which would be considered not likely to involve Significant Hazards Considerations.

i Item 25, Page 3/4 1-2 Surveillance requirements on reactivity anomalies require that the reactivity equivalence of the difference between

the actual Rod Density and the predicted Rod Density shall be verified to be less than or equal to 1% delta K/K. However, the reactor must first be in operational condition 1 or 2 in order to l

carry out the surveillance. Therefore, we propose to add " note c" under paragraph 4.1.2 on page 3/4 1-2 to indicate that 1

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• specification 4.0.4 is not applicable. Specification 4.0.4

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" Entry into an operational condition or other specified applicable condition sha11 not be made unless the surveillance requirement (s) associated with the Limiting Condition for operation have been performed within the applicable aurveillance interval or as otherwise specified."

The proposed change would allow entry into conditions 1 or 2 prior to the completion of the surveillance requirements.

Based on those examples provided by the Commission that j are considered not likely to l'nvolve Significant Hazards considerations, the proposed change would meet the criteria of example (i) as an administrative change to correct an error in the Technical Specifications.

I Item 26, Page 3/4 3-8 i

The Reactor Protection System Instrumentation Surveillance Requirements include those under paragraph (g) which calls for verification of core flow. In order to verify core flow, baseline data is needed which can only be obtained during the startup testing program.

The proposed change would add a continuation to I

1 paragraph (g) on page 3/4 3-8 to give direction and exempt the

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b il s specification from surveillance testing until after the.

- completion of the startup testing program so that the baseline data may be obtained.

The proposed change is a, purely administrative change to correct an oversight in the Technical Specifications and would fit into the category of example (i) of those examples provided by the Commission of examples of amendments that are not likely to involve Significant Hazards Considerations.

Item 27, Page 3/4 3-100 The gamma analysis required for the radioactive liquid waste sampling and analysis program (per page 3/4 11-2) stipulates that the lower limit of detection (LLD) repres$ht'ing the capability of a measurement system for Gamma activity would

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.tm 5 X 10-7 microcuries/ml.

The Action Statement 101 on page 3/4 3-100 however l

stipulates an LLD for Gamma at 1 X 10-7 microcuries/ml. In order

,1 j to maintain this lower limit of detection (LLD) , it is presently t'

necessary to first concentrate the liquid sample and then extrapolate the measured results in order to calculate the amount

of. activity.

t' c- The proposed change to page 3/4 3-100 would allow pages i

,j- 3/4 11-2 and page 3/4 3-100 to be consistent so that both l! section" of the Technical Specifications indicate that the LLD

!s for Gamma detection is 5 X 10-7 microcuries/ml. This consistency l' would lessen the possibility for analysis error created by the i

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r i present need to first concentrate the sample and then calculate ff I! the results by extrapolation, fh Example (1) of the Commission's guidance on Significant I

-Hazards Considerations allows adm,inistrative changes'to Technical

Specifications to achieve consistency. The proposed amendment to page 3/4 3-100 would be such a change to achieve consistency'and '

therefore would not involve Significant Hazards Considerations.

Item 28, Page 3/4 3-94 Fifteen heat detectors are listed as being installed in i non-PGCC flooring on page 3/4 3-94, Zone 25. However, two of the fif teen heat detectors are on the Unit 2 side and should not have been included in the Zone 25 listing. Licenseeproposes$d*

4 remove two of the detectors from the list and revise the number

[ from 15 to 13.

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[i Example (i) of those examples provided by the Commission

which 'would be unlikely to involve Significant Hazards Considerations includes changes made to correct an error.

(- Changing the total number of heat detectors (non-PGCC floor) in Fire Zone 25 from fifteen to thirteen would correct an error as

two of the heat detectors are' physically inside Unit 2 and were included due to~ oversight. Therefore, this change would not involve any Significant Hazards Considerations.

4 The Plant Operating Review Committee and the Nuclear Review Board have reviewed the proposed changes to the Technical Specifications, and have also concluded that they do not involve

4 l; an unt'eviewed safety question or a-significant hazards

?! consideration, and will not endanger the health and safety of the public.

Respectfully submitted, PHILADELPHIA ELECTRIC COMPANY

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COMMONWEALTH OF PENNSYLVANIA : ,

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COUNTY OF PHILADELPHIA  :

l S. L. Daltroff, being first duly sworn, deposes and says:

1 That he is Vice President of Philadelphia Electric

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Company, the Applicant herein; that he has read the foregoing

! Application for Amendment of Facility Operating License 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.

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j Subscribed and sworn to 4 e.

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\ of YC- (93{

i k i g ia 'N (O Notary PtIb ic V

PATRICtA A JONES

' Notary Pubhc Phila Phil a Co My Commission Espires Oct 13.1986 3

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COWISSION Before the Atomic Safety and Licensing Board In the Matter of  : -Docket No. 50-352 PHILADELPHIA ELECIRIC COMPANY  :

(Limerick Generating Station,  :

Unit No.1)  :

CERTIFICATE OF SERVICE I hereby certify that copies of Philadelphia Electric Company's Application for Amendment of Facility Operating License NPF-39 in the above-captioned matter was served on the following by deposit in the United States mail, first-class postage prepaid on this 14th day of February,1986.

Kathryn S. Lewis, Esquire Atomic Safety 6 Licensing Municipal Services Building Appeal Board Panel 15th 6 JFK Blvd. U. S. Nuclear Regulatory Commission Philadelphia, PA 19107 Washington, D.C. 20555 Ann P. Hodgdon, Esquire Robert J. Sugarman, Esquire Counsel for NRC Staff Sugarman, Denworth 4 Hellegers Office of the Executive Legal Director 16th Floor, Center Plaza U. S. Nuclear Regulatory Commission 101 North Broad Street Washington, D.C. 20555 Philadelphia, PA 19107 Angus R. Love, Esquire Troy B. Conner, Jr., Esquire Montgomery County Legal Aid Conner 6 Wetterhahn, P.C.

107 E. Main Street 1747 Pennsylvania Avenue, NW Norristown, PA 19401 Washington, D.C. 20006

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Docket 6 Service Section Timothy R. S. Campbell, Director U. S. Nuclear Regulatory Commission Department of Emergency Services Washington, D.C. 20555 - (3 copies) 14 East Biddle Street West Chester, PA 19380 Mr. Robert L. Anthony 103 Vernon Lane, Box 186 Director Moylan, PA 19065 Pennsylvania Emergency Management Agency i Basement, Transportation 6 Safety Building David Wersan, Esquire Harrisburg, PA 17120 l Assistant Consumer Advocate Office of Consumer Advocate Jay M. Gutierrez, Esquire 1425 Strawberry Square U. S. Nuclear Regulatory Commission Harrisburg, PA 17120 Region 1 631 Park Avenue Atomic Safety 4 Licensing Board Panel King of Prussia, PA 19406 U. S. Nuclear Regulatory Commission .

Washington, D.C. 20555 Phyllis Zitzer Limerick Ecology Action Mr. Frank R. Romano P.O. Box 761 61 Forest Avenue 762 Queen Street Ambler, PA 19002 Pottstown, PA 19464 Barry M. Hartman, Esquire Charles W. Elliott, Esquire Office of General Counsel Counsel for Limerick Ecology Action P.O. Box 11775 325 N. 10th Street Harrisburg, Pennsylvania 17108 Easton, PA 18042 Mr. Thomas Gerusky, Director E. M. Kelly i Bureau of Radiation Protection Senior Resident Inspector Department of Environmental Resources U. S. Nuclear Regulatory Commission t

Fulton Bank Building, 5th Floor P.O. Box 47 l

Third 6 Locust Streets Sanatoga, PA 19464 Harrisburg,PA 17120 Spence W. Perry, Esquire Associate General Counsel FEMA, Room 840 500 C Street, SW t

Washington, D.C. 20472

&_AN Il .//

Eugene /J. Byadley /

Attorrpy for Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 i

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