ML20210T914
| ML20210T914 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/02/1997 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20210T920 | List: |
| References | |
| NUDOCS 9709160171 | |
| Download: ML20210T914 (7) | |
Text
Clation Support Department
'*4k 10 CFR 50.90 PECO NUCLEAR n eo - c -,,
A Unit of PECO Energy NNMDrY^
September 2,1997 Docket Nos. 50 352 50-353 License Nos, NPF 39 NPF 85 U.S. Nuclear Regulatory Commission
- Attn: Document Control Desk Washington, DC 20555
Subject:
Limerick Generating Station, Units 1 and 2 Technical Specifications Change Request No. 96-20-0 Gentlemen:
PECO Energy Company is submitting Technical Specifications (TS) Change Request No.
96 20-0, in accordance with 10 CFR 50.90, requesting an amendment to the TS (Appendix A) of Operating License Nos. NPF 39 and NPF 85 for Limerick Generating Station (LGS), Units 1 and 2, respectively. The proposed changes to the LGS, Units 1 and 2, TS involve revising TS Section 4.0.5, and Bases Sections B 4.0.5 and B 3/4.4.8, regarding the surveillance requirements associated with Inservice inspection (ISI) and inservice Testing (IST) of American Society of Mechanical Engineers (ASME) Code Class 1,2, and 3 components. The proposed TS changes are consistent with the guidance delineated in NUREG 1482,
- Guidelines for Inservice Testing at Nuclear Power Plants," and NUREG 1433, Revision 1,
- Standard Technical Specifications for,
General Electric Plants BWR/4." As a result, the proposed TS changes will provide for additional flexibility in implementing the LGS, Units 1 and 2, ISI and IST Programs more consistently with current NRC guidance. Information supporting this TS Change Request is contained in Attachment i to this letter, and copies of the marked up TS pages for the LGS, Units 1 and 2, TS are provided in Attachment 2. This TS Change Request is being submitted under affirmation, and the required affidavit is enclosed.
We request that, if approved, the amendments to the LGS, Units 1 and 2, TS be issued prior to February 28,1998, and become effactive withir ** days following issuance.
if you have any questions or require additional information, please do not hesitate to contact us.
Very td surs, A.
nger, Jr.
Director. Licensing
/.
ggy.
Attachments 3enp1y Enclosure U'-
H. J, Miller, Administrator, Region 1. USNRC (w/ attachments, enclosure) cc:
N. S. Perry, USNRC Senior Resident inspector, LGS (w/ attachments, enclosure)
R. R. Jonati, Director, PA Bureau of Radiological Protection (w/ attachments, enclosure) 9709160171 970902
't -
PDR ADOCK 05000352 F
=
u
Ti COMMONWEALTH OF PENNSYLVANIA as.
COUNTY OF CHESTER J. B, Cotton, being first duly sworn, deposes and says:
1 That he is Vice President of PECO Energy Cornpany, the Applicent herein; that he has read the foregoing supporting informat!on for Technical Specifications Change Request No, g6-20 0 for Limerick
- Generating Station, Units 1 and 2, Facility Operating License Nos. NPF 3g and NPF 85, to revise the surveillanos requirements associated with Inservice inspection and inservice Testing actMties, and knows l
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.
k w
/
- Vice President Subscribed and sworn to before me this -
day-
- Gf. h fl4 V~ 1997, I:
1$$]lkldM r
Notary Public Notarial Seat
-y Ca L Wdson, Notary Public
' Tr in Twp., Chester County
- M t.
N,){' ).
Member, Pennsylvania Association of Notaries 4
My Cornmession Expires July 23,2001 a
{.
?
-'h
. - ~
- } +, p ? * ** '
a n
e I
l ATTACHMENT 1 LIMERICK GENERATING STATION UNITS 1 AND 2 Docket Nos.
50 352 50 363 1
License Nos.
NPF 39
- NPF 86 TECHNICAL SPECIFICATIONS CHANGE REQUEST No. 96 20 0
" Revise the Technical Specifications Surveillance Requirements Associated with Inservice inspection and inservice Testing of ASME Code Class 1,2, and 3 Components Supporting Information for Changes. 4 pages
Docket Nos.
50 352 Page i of 4 50-353 PECO Energy Company, Licensee under Facility Operating License Nos NPF 39 and NPF 85 for Limerick Generating Station (LOS), Units 1 and 2, respectively, requests that the Technical Specifications (TS) contained in Appendix A to the Operating Licensos be amended as proposed herein to modify TS Section 4.0.5, and Bases Sections B 4.0.5 and B 3/4.4.8, regarding the su,veillance requirements associated with inservice inspection (ISI) and inservico TestinC (IST) of American Socloty of Mechanical Engineers (ASME) Code Class 1,2, and 3 components. The proposed TS changes are consistent with the guidance delineated in NUREG 1482, *Guidehnes for Inservice Testing at Nuclear Power Plants," and NUREG 1433, Revision i,' Standard Technical Specifications for General Electric Plants BWR/4
- As a result, the proposed TS changes will provide for additional flexibikty in implomonting the LOS, Units i and 2, ISI and IST Programs more consistently with current NRC guidance. The proposed changos to the TS are indicated on the attached marked-up TS pages contained in Attachment 2 to this letter, We request that, if approved, it'e TS changes proposed herein be issued by February 28,1998, and become effective within 30 days following issuance.
This TS Change Request provides a discussion and descrylon of the proposed TS changes, a safety assessment of the proposed TS changes, information supporting a finding of No Significant Hazards Consideration, and information supporting an Environmental Assessment.
QlScuillon and Degerlotion of the ProDQ50d Changes
{
This proposed TS Change Roquest revises TS Sectior,s 4.0.5, and Bases Sections B 4.0.5 and B 3/4.4.8, for 1.imerick Generating Station (LGS), Units 1 and 2, portaining to the surveillance requirement associated with Inservice inspection (ISI) and inservice Testing (IST) activitios for American Society of Mechanical Engineers (ASME) Bollor and Pressure Vessel (B&PV) Code, Class 1,2, and 3 components.
The existing wording in TS Section 4.0.5, and Bases Sections B 4.0.5 and B 3/4.4.8, stipulates that ISI and IST surveillance activities for ASME Code Class 1,2, and 3 components be conducted in accordance with the requirements of Section XI of the ASME Code as required by 10CFR50.55a(g). The proposed changes will revise the applicablo TS sections to only make reference to 10CFR50.55a, since the current regulations have separated the specific requirements for ISI and IST Into sections 50.55a(g) an1 50.55a(f), respectively.
The existing wording of TS Section 4.0.5, and Bases Sections B 4.0.5 and B 3/4.4.8, also requires that ISI and IST surveillance activities be conducted in accordance with the requirements of Section XI of the ASME Boller and Pressure Vessel Code, except where specific written relief has been granted by the NRC. This wording precludes the immediato implementation of attemative testing in the event that a Codo required Inspection has been Identified as clearly impractical. The proposed TS changes will revise the applicable TS sections to eliminate the requirement that writton relief be obtained prioIlo implementation of alternative testing during the initial 120 month inspection interval, and the initial 12 months of subsequent Intervals in cases where the Code required inspections have been found to be clearly impractical. NUREG 1482,
- Guidelines for Inservice Testing at Nuclear Power Plants," discusses impracticality as being a sltuation where a test cannot be performed due to limitations in design (which includes prohibitivo dose rates), construction, or system configuration.
Furthermore, TS Section 4.0.5b. currently discusses the required frequency of ISI and IST surveillance activities required by the ASME Code. The existing TS address testing frequencies of up to one (1) year, in some cases, the ASME Code requires that testing be performod on a two (2) year frequency. The proposed TS changes will also revise the TS to include a reference for tests that are conducted on a
Attachment i Docket Nos.
50 352 Page 2 of 4 50-353 biennlat frequency, inclusion of this reference will permit the application of TS 4.0.2 criteria for ISI and IST surveillance activities. This will permit a 25 percent timo extension to be applied to the surveillance frequency, if necessary, in order to allow for considoration of plant operating conditions when scheduling ISI and IST survolliance tests.
SalekAsiessment The proposed TS changes do not involvo any physical modifications to the plant structuros, systems, or components. The proposed TS changes are considorod administrativo in nature, and are intended to remove inconsistonclos betwoon the LGS TS and requirements stipulated in 10CFR50.55a. The proposed TS changes do not alter the program currently describod in TS Section 6.8,
- Procedures and Programs," for implementing the ISI and IST Programs at LGS. All ISI and IST surveillonen activities will continue to be performed in accordance with the requirements of Section XI of the ASME Code, with the exception of casos where written relief has been previously granted by the NRC. In the event that a Code required inspection or test is found to be impractical due to unforeseen conditions, written relk
- will still be requested from the NRCi however, implomontation of the attemate testing may proccod, if appropriato, it is anticipated that the only time this provision would be utilized would bo in the event that an inspection or test is discovered to be impossible or impractical to perform due to unforeseen or unexpected high radiation conditions, or physical limitations. This change will also clarify the applicability of surveillance intervals to blonnial tests or examinations. No ASME Code required Inspections will be eliminated from the ISI or IST Programs until approval has been granted by the NRC. The proposed TS changes do not reduce any margin of safety as described in the Safety Analysis Report (SAR), or constitute an unroviewed safety question.
In addition, the proposed TS changes are consistent with guidance provided in NUREG 1482,
- Guidelines for Inservice Testing at Nuclear Power Plants," and NUREG 1433 Revision 1 " Standard Technical Specifications for General Electric Plants BWR/4.* In particular, NUREG 1482 discusses impracticality as being a situation where a test cannot be performed due to llmitations in desl n (which includes prohibitivo 0
dose rates), construction, or system configuration.
Thorofore, the proposed TS changes will romove the inconsistencies between the LGS TS and the requirements of 10CFR50.55a, and will also ensure that the implementation of the LGS ISI and IST Progrnms are consistent with current NRC guidance as specified in NUREG 1482 and NUREG 1433, Revision 1.
1Df0fmaMon_SMDporting a Finding.pf_No significant Hazards Consideration We have concluded that the proposed changes to the Limerick Generating Station (LGS), Units 1 and 2, Technical Specifications (TS) Section 4.0.5, and Bases Sections B 4.0.5 and B 3/4.4.8 concoming the survelllance requirements associated with innervice Inspection (ISI) and Inservice Testmg (IST) of American Society of Mechanical Engineers (ASME) Code Class 1,2, and 3 components do not involve a Significant Hazards Consideration, in support of this determination, an ovaluation of each of the three (3) standards set forth in 10 CFR 50.92 is provided below.
1.
The orocosed Technical SRCCifLCations (TS) changes do noUDYolve a sionificant increase in the orobability or cQDstSUCDCus of an accident orevious!v evalugiqd, The proposed TS changes are administrative in nature and do not make physical modifications or changes to the plant structures, systems, or components (SSC). Plant SSC will continue to function as designed. The proposed TS changes will not alter equipment operational practices or procedures.
i Docket Nos.
50-352 Page 3 of 4 50 353 in the event that an ASME Section XI Code required inspection or test is found to bo impractical due to unforosoon conditions, writton relief would still be requestod from the NRC in accordance with established procedures. No code requirod inspection will be eliminated from the ISI or IST Pro 0 rams until written approval has boon Oranted by the NRC as required 10CFR50.55a. It is anticipated that the only time this provision would be utilized would be in the event that an inspection or test is discovered to be impossible or impractical to perform due to unforeseen or unexpected high radiation conditions, or physicallimitations. This change will also clarify the applicability of survoillance Intervals to blonnial tests or examinations.
The proposed TS changen will remove the inconsistencies between the LGS TS and tne requirements of 10CFR50.55a, and will also ensure that the implementation of the LGS ISI and IST Programs are consistent with current NRC guidance as specified in NUREG 1482 and NUREG 1433, Revision 1.
Thorofore, the proposed TS changos do not involve a sign!f, cant increaso in the probability or consequences of an accident previously evaluated.
2.
Ihn.pfopoacd TS changMAo not cro@ ino nossibility ota new or dificInut kind of accident frorn any accidQDLDIRYl0Mly_RYaludi The proposed changes opp'y to the administrativo requiroments for testing of plant systems.
No physical modifications to systems or components are involved. No new failure modes which could cause or contribute to the cause of an accident are being introduced.
The proposed TS changes will remove the inconsistenclos betwoon the LGS TS and the requiromonts of 10CFR50 55a, and will also ensure that the implementation of the LGS ISI and IST Programs are consistent with current NRC guidanco as specified in NUREG 1482 and NUREG 1433, Revision 1, Therefore, the proposed TS changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
The proposed TS changes do not involve a significant reduction in a margin of safety, f
Sysical plant modifications or operational proceduro changes are being modo as a result
(
. proposed TS changes. The proposed TS changes apply to the ISI and IST Programs' so sillance requirements and do not modify the scope or frequency of these Programs as required by 10 CFR 50.5ba. The proposed TS changes will climinate inconsistenclos betwoon curtont TS wording and the requirements specified in 10CFR50.55a. In addition, the proposed changes are consistent with the guidance stipulated in NUREG 1482 and NUREG 1433, Revision 1, No physical plant modifications or operational procedure changes are being l
_ introdJCod as a result of this proposed TS Change.
i Therefore, the proposed TS chan0es do not involve a reduction in a margin of safety.
l l
Docket Nos, 50 352 Page 4 of 4 50-353 Informatlon Suncortina an Environmental Assessment An Environmental Assessment is not required for the t.hanges prooosed by this Change Request because
{
the requested changes to the LGS, Units 1 and 2, TS conform tc rie criteria for " actions eligible for categorical exclusion," as specified in 10 CFR 51.22(c)(9). The requested changes will have no impact ori the environment. The proposed changes do not involve a significant hazards conalderation as discussed in the preceding section, The proposed changos do not involve a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, in addition, the proposed changea do not involve a significant increase in individual or cumulative occupational radiation exposure.
Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed
}_
changes to the LGS, Units 1 and 2. TS and have concluded that they do not involve an unreviewed safety
)
question, and will not endanger the health and safety of the public, I