ML20203L125
| ML20203L125 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/19/1986 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20203L123 | List: |
| References | |
| NUDOCS 8608250015 | |
| Download: ML20203L125 (10) | |
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s BEFORE THE
- s UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket 50-352 PHILADELPHIA ELECTRIC COMPANY APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSE NPF-39 Eo.tard G. Bauer, Jr.
Eugene J. Bradley 2301 Market Street Philadelphia, Pennsylvania 19101 Attorneys for Philadelphia Electric Company 8608030015 860319 PDR ADOCK 05000352 P
PDH
BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of i
Docket No. 50-352 PHILADELPHIA ELECTRIC COMPANY APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSE NPF-39 l
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Philadelphia Electric Company, Licensee under Facility Operating License NPP-39 for Limerick Generating Station Unit 1, hereby requests that the Technical Specifications contained in Appendix A to the Limerick operating license be amended as indicated by a vertical bar in the margin of the attached pages 3/4 4-15, B 3/4 4-4 and Page 6-16.
i Licensee proposes to incorporate the NRC model Technical Specifications provided with Generic Letter 85-19 regarding the requirements for reporting of iodine spikes.
The Commission Staff has provided guidance for the reporting requirements of iodine spikes and has determined that because of the improved quality of nuclear fuel during the past decade, normal reactor i - _ _ - -.. - _ _
cbolcnt iodina activity lovalo htva bsen maintain 2d wall b21ow the regulatory limits now in effect.
Safety Significance In an effort to eliminate unnecessary Technical Specification requirements, the Commission Staff in Generic 4
Letter No. 85-10, determined that some of the existing requirements regarding iodine may be eliminated.
The Limerick Technical Specifications require plant shutdown if the coolant iodine activity limits are exceeded for 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in any 12-month period.
In addition to providing for elimination of the existing requirements with regard to plant shutdown, Generic Letter No.
85-19 also provides guidance for the reporting requirements of coolant iodine activity levels, changing the reporting requirements from a short term Special Report or a Licensee Event Report, to an item which is to be included in an annual report, pursuant to the proposed administrative control 6.9.1.6 paragraph (d) on page 6-16.
Further, page 3/4 4-16 has been left intentionally blank in order to maintain the existing pagination throughout the i
Technical Specifications.
Previously, page 3/4 4-16 continued the action items of paragraph 3.4.5, which Licensee proposes to j
eliminate.
Also, page 6-16a has been added because of the additional paragraph (d) on page 6-16.
In order to incorporate the additional paragraph it is necessary to add an additional page 16a.
The (a) designation is used in order to maintain consistent pagination throughout the Technical Specifications..- -__ __ -
Tho cofsty cignifictnce rcgtrding climination of coma of the requirements for Iodine is minimal.
The existing regulations (Title 10 CFR 50.73 Section (b)(1)(li)) requires the Licensee to report fuel cladding failures.
The fuel cladding design improvements have minimized fuel cladding failures which in the past have been the primary cause for high Iodine levels in the reactor coolant.
Further, the specific Iodine activity limitations for the reactor coolant are not being changed and with the existing curveillance requirements, adequate assurance is provided to preclude approaching the specific Iodine limits.
Excessive specific activity levels in the reactor coolant would be detected by the existing surveillance requirements in sufficient time to allow the operators to take corrective actions to minimize the cctivity levels and maintain the Iodine levels below the limits.
Significant Hazards Consideration Determination Examples of amendments that are considered likely, and also not likely, to involve Significant Hazards Considerations
- ,4 were provided by the Commission (48 FR 14870) and include example (iv) as an example of relief granted upon demonstration of acceptable operation from an operating restriction that was imposed because acceptable operation had not yet been demonstrated.
The proposed changes to pages 3/4 4-15, 3/4 4-16, B 3/4 4-4, 6-16, and 6-16a, have been previously justified, and fit into the category of example (iv) as amendments which are not likely to involve Significant Hazards Considerations.
In order to support the No Significant Hazards Consideration datorninstion, n:cacssry brckground cupporting information is provided below, along with an evaluation of each of the three w
ctandards set forth in 10CFR Section 50.92.
(1)
The proposed changes do not involve a significant increase in the probability or consequences'of an accident previously evaluated because during the past decade, the normal coolant iodine activity in Boiling Water Reactors has been maintained at very low levels due to superior fuel and fuel cladding design along with improved operating practices that decrease the probability of cladding failures.
Cladding failures previously caused periodic high iodine levels which are no longer evident in BWR reactor coolant.
Further, the existing regulation, 10CFR Section 50.72(b)(1)(ii),
requires that the Nuclear Regulatory Commission be immediately notified of fuel cladding failures that exceed expected values or that are caused by unexpected factors.
(2)
The proposed change does not create the possibility of a new or different kind of accident from any previously evaluated, because acceptable operation has been demonstrated over the past decade due to improved design and manufacturing of nuclear fuel, demonstrating the capability that reactor coolant iodine levels are being maintained well below the limit; thereby reducing the coolant lodine levels which were common in the period 1965 to 1975 because of fuel cladding failures. i
Changing tha rcporting requiremants doam not creat@ tha possibility for a new type of accident from any previously evaluated.
(3)
The proposed change does not involve a significant reduction in a margin of safety because surveillance l
requirements provide adequate assurance that excessive specific activity levels in the reactor coolant will be l
detected in sufficient time to allow the operators to take corrective action.
The specific iodine activity l
limitations of the reactor coolant have not been changed, and with good fuel management, as has been demonstrated in the past, combined with existing reporting requirements for fuel cladding failures, should preclude ever approaching the specific iodine activity limit.
Environmental Consideration This amendment concerns the reporting requirements of iodine spikes and incorporates the NRC model technical specifications provided with Generic Letter 85-19.
Based on the discussions above in regards to improved fuel cladding design and operating experience over the last decade, the proposed changes to the Technical Specifications involves no sianificant increase in the amount and no significant change in the types of any effluents that may be released offsite and there is no significant increase in individual or cumulative occupational.
rcdiction cxpo2urco.
Th2 proposed chcngas will not rsrult in cny decrease in the safe operation of the plant.
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 and will not endanger the health and cafety of the public.
Respectfully Submitted Philadelphia Electric Company
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Vice' Prpsidenu /
COMMONWEALTH OF PENNSYLVANIA :
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COUNTY OF PHILADELPHIA S.
L. Daltroff, 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 and knows the contents thereof; and that the statements and matters set I
forth therein are true and correct to the best of his knowledge, information and belief.
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Subscribed and sworn to TA beforemethis/fday l
of
- / d s J_,
g Notary Public MELAHit R. CAMPANELLA Notary Puthe, PhiladelpMa. Pful.thlphin Co, Mr Commissin tipats Fettwy 12,1990
UNITED STATES OF AMERICA NUCLEAR REGULATORY CObNISSION Before the Atomic Safety and Licensing Board In the Matter of Docket No. 50-352 PHILADELPHIA ELECTRIC 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 were served on the following by deposit in the United States mail, first-class postage prepaid on this 19th day of August,1986.
Kathryn S. Lewis, Esquire Atomic Safety 4 Licensing Municipal Services Building Appeal Board Panel 15th 6 JFK Blvd.
U. S. Nuclear Regulatory Commission Philadelphia, PA 19107 Washington, D.C.
20555 Benjamin H. Vogler, Esquire Robert J. Sugarman, Esquire Counsel for NRC Staff Sugarman 6 Hellegers Office of the Executive Legal Director 16th Floor, City Place 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 l
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Docket 4 Service Section Timothy R. S. Campbell, Director U. S. Nuclear Regulatory Commission Department of Emergency Services i
Washington, D.C.
20555 - (3 copies) 14 East Biddle Street l
West Chester, PA 19380 Mr. Robert L. Anthony 103 Vernon Lane, Box 186 Director Moylan, PA 19065 Pennsylvania Emergency Management Agency Basement, Transportation 6 Safety Building David Wersan, Esquire Harrisburg, PA 17120 Assistant Consumer Advocate Office of Consumer Advocate Jay M. Gutierrez, Esquire 1
1425 Strawberry Squarc U. S. Nuclear Regulatory Commission Harr a burg, PA 17120 Region 1 631 Park Avenue Atomic Safety 6 Licensing Board Panel King of Prussia, PA 19406 U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Ms. Maureen Mulligan Limerick Ecology Action i
Mr. Frank R. Romano P.O. Box 761 61 Forest Avenue 762 Queen Street Ambler, PA 19002 Pottstown, PA 19464 i
Barry M. Ilartman, Esquire Charles W. Elliott, Esquire' Office of General Counsel Counsel for Limerick Ecology Action l
P.O. Box 11775 325 N. 10th Street liarrisburg, Pennsylvania 17108 Easton, PA 18042 Mr. Thomas Gerusky, Director E. M. Kelly Bureau of Radiation Protection Senior Resident Inspector Department of Environmental Resources U. S. Nuclear Regulatory Commission Fulton Bank Building, 5th Floor P.O. Box 47 Third 6 Locust Streets Sanatoga, PA 19464 Ilarrisburg, PA 17120 Spence W. Perry, Esquire General Counsel l
FEMA, Room 840 l
500 C Street, SW 1
Washington, D.C.
20472 i
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Eugene J./Bradley
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Attatney'for t
Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101
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