ML20217M079
| ML20217M079 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/31/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20217M069 | List: |
| References | |
| NUDOCS 9804080003 | |
| Download: ML20217M079 (3) | |
Text
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5 UNITED STATES g
B NUCLEAR REGULATORY COMMISSION T.
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WASHINGTON, D.C. soseH001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RFt ATED TO AMENDMENT NOS.125 AND 89 TO FACILITY OPERATING LICENSE NOS. NPF-39 AND NPF 85 PHILADELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION. UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353
1.0 INTRODUCTION
By letter dated September 2,1997, the Philadelphia Electric Company (the licensee) submitted a request for changes to the Limerick Generating Station, Units 1 and 2, Technical Specifications 1
(TSs).' The requested changes revise 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 licensee proposed the TS changes to remove the requirement that
. written relief approval be obtained prior to implementation of attemative testing during the initial 120-month inspection interval, and the initial 12 months of subsequent intervals in cases where the Code required testing or inspections have been found to be impractical. Furthermore, the existing TS addresses testing frequencies of up to one year, and the proposed TS changes will add a reference for tests that are conducted on a biennial frequency.
2.0 EVALUATION i
The existing TS 4.0.5.a states:
inservice Inspection of ASME Code Class 1,2, and 3 mponents and inservice testing of ASME Code Class 1,2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Code and applicable Addenda as requirod
- by 10 CFR Part 50, Section 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR Part 50, Section 50.55a(g)(6)(i).
i i The proposed TS change deletes the last part of the TS as shown below:
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~ inservice inspection of ASME Code Class ',2, and 3 components and inservice testing of ASME Code Class 1,2, and 3 pu,nps and valves shall be performed in accordance with Section XI of the ASME C6de and applicable Addenda as required L-by 10 CFR Part 50, Section 50.55a.
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-4 2-I Both 181 and IST requirements were addressed under the same paragraph of 10 CFR 50.55a(g),
but the regulations have been revised to separately address IST requirements in 50.55a(f) and ISI requirements in 50.55a(g). Therefore, the change of reference from 50.55a(g) to 50.55a would be consistent with the current regulation and covers both areas of IST and ISI. Thus, the.
staff finds the change to be acceptable.
For prepadng updated IST and ISI programs, the regulations state in 10 CFR 50.55a(f)(5)(iv) and (g)(5)(iv) that the impracticality of code requirements be demonstrated to the satisfaction of the H
Commission no later than 12 months subsequent to the next interval start date. This would allow the licensee up to 12 months after the beginning of the updated interval to obtain the NRC approval of requests for relief from those new Code requirements which cannot be met on basis of lir,pi=2Mi. However, the wording in existing TS 4.0.5 prohibits licensees from implementing altamative testing methods described in IST and 131 program relief requests before receiving NRC approval, even when the altemative testing method meets later Code requirements (that are not yet formally adopted in 10 CFR 50.55a). This has been identified in
. NUREG-1482 as a conflict between TS 4.0.5 and the regulations. The staff recommended in l
Section 6.3 of NUREG-1482 that licensees revise their TS to remove this conflict. The licensee's L
proposal to delete those words in TS 4.0.5 as shown above is consistent with the staffs recommendation and is, thus, acceptable.
The proposed change to add the reference of biennial test to TS Section 4.0.5.b will permit the appuc.euon of TS 4.0.2 criteria to ISI and IST two-year surveillance activities. This will allow, if necessary, a 25-percent time extension to be applied to the two year surveillance test frequency.
This proposed change is consistent with the standard TS for General Electric plants as provided -
in NUREG-1433, Revision 1, and is acceptable. However, as indicated in NUREG-1482, Section 6.2, the 25% extension is not intended to be used repeatedly as an operational convenience to extend surveillance intervals beyond those required by the Code.
The proposed TS changes also revise Bases Section 4.0.5 and 3/4.4.8 to reflect corresponding
. changes in TS 4.0.5. The staffs review found the changes to be consistent with the above discussion and are, thus, acceptable.'
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3.0
SUMMARY
Based on the above evaluation, the staff finds that the proposed TS changes are acceptable because they are consistent with the guidance delineated in NUREG-1482, " Guidelines for -
Inservice Testing at Nuclear Power Plants," and NUREG-1433, Revision 1, " Standard Technical Spedfications for General Electric Plants BWR/4" and NUREG-1433 Revision 1, " Standard H
Technical Specifications for General Electric Plants BWR/4" for ISI and IST." In addition, the proposed TS changes will remove the conflict between the TS requirement and the provisions of 10 CFR 50.55a that allow for the 12 months following the beginning of a new 10-year interval for the licensee to demonstrate the basis for its determination that a pump or valve test required by the Code is impractical.
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4.0 STATE CONSULTATION
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- in accordance with the Commission's regulations, the Pennsylvania State official was notified of i
the proposed issuance of the amendments. The State official had no comments.
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5.0 ENVIRGNENTAL CONSIDERATION The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change the surveilliance requirements. The NRC staff has determmed that the amendments involve no significant.
l increase in the amounts, and no significant change in the types, of any effluents that may be l
released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public l
comment on such finding (63 FR 6990). Accordingly, the amendments meet the 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 or environmental assessment need be prepared in connection with the issuance of the amendments.
6.0 CONCLUSION
The Commission 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, (2) such activities will be conducted in compliance with the l
Commission's regulations, and (3) the issuance of the amendments will not be inimical to the l-common defense and security or to the health and safety of the public.
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Principal Contributor: Y. Huang i
Date: March 31, 1998' i
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