ML20235N520

Application for Amend to License NPF-39,consisting of Tech Spec Change Request 88-13 to Ensure Compliance w/10CFR50.62 Re ATWS for Sodium Pentaborate Solution Temp/Concentration Requirements

ML20235N520
Person / Time
Site:	Limerick
Issue date:	02/22/1989
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20235N524	List: ML20235N520 ML20235N528
References
NUDOCS 8903010265
Download: ML20235N520 (19)

Text

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, ,, 10 CFR 50.90 i

PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 i PHILADELPHIA A, PA.19101 (215)8414000 February 22, 1989 Docket No. 50-352 License No. NPF-39 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555

SUBJECT:

Limerick Generating Station, Unit 1 Technical Specifications Change Request

Dear Sir:

Philadelphia Electric Company hereby submits Technical Specifications Change Request No. 88-13, in accordance with 10 CFR 50.90, requesting an amendment to the Technical Specifications (Appendix A) of Operating License No. NPF-39.

Information supporting this Change Request is contained in Attachment 1 to this letter, and the proposed replacement pages are contained in Attachment 2.

This submittal requests changes to the Technical Specifications to ensure compliance with paragraph (c)(4) of the Anticipated Transient Without Scram Rule, 10 CFR 50.62, and to simplify and improve the Technical Specifications (TS).

In addition, the proposed changes correct a discrepancy between the TS and the Final Safety Analysis Report (FSAR). Although this discrepancy was determined to not present a safety concern, it was reported via telephone notification by Mr. M. J. McCormick, the Limerick Generating Station, Unit 1 Plant Manager, to Mr. J. Linville of the NRC, Region 1, at 11:40 a.m. on December 6, 1988, in accordance with 10 CFR 50.9. As committed in that verbal notification, this TS Change Request is being submitted and will correct the discrepancy.

The discrepancy exists in TS Figure 3.1.5-1, " Sodium Pentaborate Solution Temperature / Concentration Requirements."

The Figure shows an " Operating Limit" line on a plot of temperature vs. sodium pentaborate concentration which is actually the solution " Saturation" line shown on the same plot in the PSAR. Figure 9.3-7 of the FSAR properly depicts the

" Operating Limit" line and the " Saturation" line. This proposed 8903010265 890222 8gi 1 PDR ADOCK 05000352 I i P PNV

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,, .< February.22, 1989 Page 2 J

TS Change Request includes, in part, a revised TS Figure 3.1.5-1, showing.the proper " Operating Limit" line.

If you have any questions regarding this matter, please contact us.

Very truly yours,

. h. fif .

G. A. Hunger, Jr.

Director Licensing Section l Nuclear Support Division-

~ Attachments cc: W. T. Russell, Administrator, Region I, USNRC T. J. Kenny, USNRC Senior Resident' Inspector, LGS-1 T. Gerusky, Director, PA Bureau of Radiological Protection i

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. .. - TECHNICAL SPECIFICATION CHANGE. REQUEST 88-13 I s .

COMMONWEALTH OF PENNSYLVANIA  :

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COUNTY OF PHILADELPHIA  :

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

! 1 That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing Application for Amendment of Facility Operating Licenses, to improve the Standby Liquid Control System Technical Specifications and ensure compliance with paragraph (c)(4) of the Anticipated Transient Without Scram Rule, 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.

NbOC O C/

Vice President Subscribed and sworn to before me this [h bb day of b- 1989.

usa- - . <>

Notary ) lic NOTAR!AL SEAL PATRICIA A. JONES, Notary Public Qty of Philadelph!a,Phila. County W ramrneion Dpires @t 13,101M

ATTACHMENT 1.

l: ~ LIMERICK GENERATING STATION Docket No. 50-352 License No. NPF-39 TECHNICAL SPECIFICATIONS CHANGE REQUEST-

" Changes to Ensure Compliance ~with.the ATWS Rule" Supporting'Information for Changes - 16 pages--

Docket No.-50-352 Philadelphia Electric Company, Licensee under Facility Operating License NPF-39 for Limerick. Generating Station Unit 1, hereby requests that the Technical Specifications contained in

. Appendix A of the Operating License be amended to revise the Standby Liquid Control System Technical Specifications as proposed herein. The proposed changes are indicated by vertical bars in the margin of the pages v, 3/4 1-19, 3/4 1-20, 3/4 1-21, 3/4 1-22, B 3/4 1-4, and provided in Attachment 2.

Philadelphia Electric Company requests these changes to ensure compliance with paragraph (c)(4) of the Anticipated Transient Without Scram (ATWS) Rule, 10 CFR 50.62, and to simplify and improve the Technical Specifications. We request these changes be effective upon issuance of the amendment.

This Change Request provides a discussion of the Standby Liquid Control System (SLCS), a description of the proposed Technical Specification changes, a safety assessment of the proposed changes, information supporting a finding of No Significant Hazards Consideration, and information supporting an Environmental Assessment.

System Discussion The final ATWS Rule, 10 CFR 50.62, requires that Boiling Water Reactors (BWRs) be equipped with a SLCS. Specifically,

Docket No. 50-352 paragraph (c)(4) requires that the SLCS have an equivalent control capacity of 86 gpm of 13 weight percent sodium pentaborate solution. To comply with this requirement, two injection pumps are necessary. The Limerick design, however, includes three pumps, which are designed to operate together to inject boron solution into the reactor vessel. This design provides added reliability and redundancy over the typical two pump design. The system can be initiated either manually or automatically to effect a reactor shutdown. Further description of the SLCS design and ooeration is available in Final Safety Analysis Report (FSAR) Sections 9.3.5 and 7.4.1.2 and also NUREG-0091, Safety Evaluation Report (SER) for Limerick Generating Station (LGS).

Description of Changes The SLCS system design has been approved as acceptable to meet the requirements of the ATWS Rule as detailed in the SER from R. J. Clark (NRC) to E. G. Bauer (PECo) dated November 3, 1987. However, we propose to make changes to the Technical Specifications by raising the minimum requirements to ensure compliance with paragraph (c)(4) of the Rule which requires the SLCS to have an equivalent control capacity of 86 gpm of 13 weight percent sodium pentaborate solution. Technical Specifications currently require two pumps to be operable, each 3

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with a minimum flow rate of 41.2 gpm. Operation at these minimum l

' requirements requires a solution concentration of not less than h _about 13.6%. Maintaining concentration less than 13.6% would result in. noncompliance with the SLCS control capacity requirements of the Rule. Thus,-changes to the Technical Specifications _are needed to prevent this situation. Currently, the SLCS Limiting Condition for Operation does not state minimum operability requirements; therefore, we propose to state these requirements. In addition, we propose to incorporate the latest design specification data from General Electric (GE) where appropriate. All changes are described below.

(1) Surveillance Requirement (SR) 4.1.5.b.2 will be revised to require verification that the SLCS meets the capacity requirements of the ATWS Rule:

C x 0 > 1 13% wt. 86 gpm where, C = Sodium pentaborate solution concentration (% by weight)

Q = Two pump flowrate, as determined per surveillance requirement 4.1.5.c.

l-Docket No. 50-352 (2) SR 4.1.5.b.2 will be revised to require greater than or equal to 5389 lbs. of sodium pentaborate to reflect the latest (GE) design specification data.

(3) Figure 3.1.5-2 will be deleted to simplify the Technical Specifications and the index page, v, revised to show deletion of the figure. Key parameters of the Figure will be relocated as follows:

(a) SR 4.1.5.a.2 will require a minimum volume of 4537 gallons.

(b) SR 4.1.5.b.2 will be revised to require solution concentration to be less than or equal to 13.8%.

(4) Figure 3.1.5-1 will be revised to replace the current

" operating limit" line, which is a saturation curve, with the proposed " operating limit" line, which is several degrees above (more conservative) the current line and will provide consistency with the FSAR. The Figure will also be enlarged to improve readability.

(5) The testing requirements of SR 4.1.5.d.1 will be revised to require that all injection loops be tested within

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, Docket'No. 50-352-i three operating cycles versus the current requirement of l .36' months.

(6) The minimum operability requirements of'the'SLCS will be stated in the Limiting Condition for Operability (LCO) of Specification 3.1.5: "The Standby Liquid Control System, consisting of a minimum of two pumps and corresponding flow paths, shall be Operable."

Safety Assessment Each item referenced above il thru 6) is similarly referenced below and is evaluated to. assess the impact (if any) of the changes on safety.

(1) The proposed equivalency equation, which is similar to that approved for Unit 2 of Peach Bottom Atomic Power Station (PBAPS), ensures the minimum requirements of the ATWS Rule are met. The equation provides a calculational method to ensure compliance with the control capacity requirements where none existed before and, therefore, will provide an incremental improvement in the reliability of the SLCS to perform its intended function. Therefore, there is no adverse impact on  !

safety.

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I Docket No. 50-352 (2) Revising the minimum available weight of sodium pentaborate from 5500 lbs. C 5389 lbs. maintains the design requirement for a 25% excess allowance for potential leakage and imperfect mixing plus allowances based on accuracies associated with the level instrumentation. The current value of 5500 lbs. is overly conservative. The latest design specification f rom GE defines a new minimum weight of 5389 lbs. based on actual LGS level instrumentation accuracies. Since the 25% excess allowance will be maintained, the proposed change will not adversely affect safety.

i (3)

Requirements previously contained in Figure 3.1.5-2 will be relocated to various parts of the SRs as discussed below:

(a) The minimum volume requirement will be relocated to SR 4.1.5.a.2. The minimum volume of 4620 gallons will be revised to 4537 gallons to correspond to the minimum necessary sodium pentaborate weight, (as discussed in item 2) at a preferred solution concentration of 13.4%, in accordance with the latest GE design specifications.

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Docket No. 50-352 (b) The maximum sodium pentaborate concentration will be controlled by SR 4.1.5.b.2 and Figure 3.1.5-1 which provide _a concentration limit of 13.8%.

(c) The minimum concentration requirements will be replaced by the proposed SRs 4.1.5.a and b.

Although no minimum concentration is specified, the requirements for minimum volume, minimum weight of sodium pentaborate and satisfying the proposed equivalency equation will assure an adequate solution concentration is maintained.

(d) The " margin" and " overflow volumes" of the current Figure 3.1.5-2 are not significant solution parameters and therefore can be deleted. These values were provided for information only, and are available in the appropriate Surveillance Tests.

Operation with a solution volume up to the tank overflow nozzle is acceptable from a safety perspective as long as the chemistry requirements of the solution are met. The tank high level alarm establishes a convenient operating limit below the overflow nozzle. In addition, SR 4.1.5.b.2 requires verification of solution chemistry

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Docket No. 50-352 parameters anytime the level is raised by the addition of water or boron.

In summary, the impact on safety of deleting Figure 3.1.5-2 was examined. As previously described, parameters important to safety have been preserved by. relocating them to other SRs. .The relocated parameters are checked and maintained at frequencies consistent with those currently in place. For these reasons, the deletion of Figure 3.1.5-2 and incorporation of the proposed specifications will not adversely affect safety. j (4) The proposed changes to Figure 3.1.5-1 provide a more.

conservative operating restriction than,that currently in place; therefore, the proposed changes will not adversely affect safety.

(5) The testing requirements of 4.1.5.d.1 will be revised to i require that all three injection loops be tested within 1

3 operating cycles, rather than within 36 months. Thus, one loop will be tested during every refueling outage.

1 Technical Specifications SR 4.1.5.d.1 currently requires that one SLCS loop be tested in the reactor vessel i _ _- ____ _ __ _ _ _ _ _ _ _

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, Docket No. 50-352 injection mode every 18 months, and that all loops be f

.1 tested within 36 months. For most BWRs, which have two SLCS pumps, this requirement results in the' testing of one loop during every refueling outage. The Standard Technical Specifications (STS) for BWRs, NUREG-0124, Rev. 3, states, "Both injection loops shall be tested in 36 months." Although'not required to meet system performance requirements, the LGS design includes a third SLCS pump. Thus, to comply with the. current loop-testing requirements, two of the three'1 oops must be tested every other refueling outage. It is apparent then, that the existing Technical Specifications do not properly reflect LGS design. In. addition, the 36 month limit does not allow'for variations in the-length of an operating cycle or the intervening' refueling outage, or for test scheduling flexibility within a given refueling outage (i.e. beginning or end of the outage). It is thus very possible that circumstances could require testing of all three loops during a single outage or could require plant shutdown to meet the test interval requirements.

Quarterly testing required by SR 4.1.5 c verifies operability of each SLCS pump and the associated components and flowpath within the test loop. Eighteen

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, Docket No. 50-352 month testing required by SR 4.1.5.d verifies the suction flowpath for all three pumps, verifies explosive

= valve operability and discharge flowpath for the loop being tested, and verifies the common' discharge flowpath for all three loops. Thus, at the end of each 18 month cycle, only the explosive valves and short segments of associated discharge piping may remain untested for two of three loops.

The short segments of discharge piping are not ~ filled with the sodium pentaborate solution. This piping is only briefly exposed to the solution during suction flow path testing and is normally exposed to demineralized water used in injection tests and flushing of the system and thus does not provide a significant possibility.of becoming blocked by crystallization of sodium pentaborate. The LGS Probabalistic Risk Assessment confirms this position by showing that the availability of the short segments of discharge piping is primarily.

dependent on the reliability of the explosive valves.

Reliability of the explosive = valve is primarily iependent on the explosive actuators, which have a shelf life of 5 years. Surveillance Test (ST) procedure ST 048-320-1 requires verification, at each 18 month I

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Docket No. 50-352-9 testing interval, that'the expiration date of all three

- explosive actuators will not-be' reached during the following operating cycl'e. Actuators.that are g approaching expiration are replaced with fresh actuators l'

L from a successfully tested batch. Thus, the viability of-all three explosive actuators is verified during each 18 month testing interval. 3 (6) The proposed change to add minimum operability requirements within the LCO, provides specifics on what these requirements are, since none are currently stated.

This' change is administrative, since the proposed minimum operability requirements are the same as.those described in the Technical Specification bases and the design bases.

In consideration of the above discussion, the high reliability of the SLCS system will be' maintained. Therefore, incorporation of the proposed changes will not adversely affect safety.

Information to Support a Finding of No Significant Hazards Consideration:

We have concluded that the proposed changes to the LGS Technical Specifications, those to ensure compliance with I

. 1 Docket No. 50-352 paragraph (c)(4) of the ATWS Rule and those which simplify and improve the Technical Specifications, do not constitute a significant hazards consideration. In support of this determination, an evaluation of each of the three standards set forth in 10 CFR 50.92 is provided below.

A. The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

The requested changes do not involve any physical changes to the SLCS or its operation. The proposed changes reflect SRs necessary to ensure compliance with ATWS Rule, relocation of certain SRs in order to simplify the Technical Specifications (TS), and a SR change to reflect actual system design. This latter change extends the SLCS loop testing requirement to three cycles to reflect the LGS three pump design. All testing criteria will continue to be met to ensure the same high degree of reliability for the SLCS. Therefore, the same or better reliability of the SLCS system will result.

The latest General Electric design data is incorporated into the proposed specifications to L____._..___.____ _ _ _ _ _ .

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, Docket No. 50-352 reflect more refined instrument accuracies. Design margins and requirements continue'to be satisfied.

L The proposed change to add minimum operability requirements in the LCO, provides specifics on what these requirements are since none are currently stated. This change is administrative, since the minimum operability requirements are the same as those in the TS bases and the design bases.

The proposed changes described above maintain system desfan criteria and surveillance requirements. In addition, no changes to the system or its operation result and therefore, these changes do not modify or add any' initiating parameters that would significantly. increase the probability or consequences of any accident previously evaluated.

FSAR Sections 9.3.5 and 15.8 were reviewed in making this determination.

B. The proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated. .

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Docket No. 50-352 The proposed changes do not involve any design or physical changes to the SLCS and do not change system operation. The design bases of LGS will remain the same. Therefore, the current FSAR will

-remain complete and accurate in its discussion.of the licensing basis events and in analyzing plant response and consequences. Further, as discussed above, the proposed changes maintain the design basis and testing criteria so that the same level of reliability and performance are maintained.

Therefore, no equipment-is adversely affected, nor-could the proposed changes involve any potential initiating events which would create any.new or different kind of accident. As such, the plant initial conditions utilized for the design basis accident analyses are still valid.

C. The proposed changes do not involve a significant reduction in a margin of safety.

As discussed above, the proposed changes do not change the design bases and continue to ensure a high degree of system reliability. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

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, Docket No. 50-352 Information Supporting an Environmental Assessment An environmental assessment is not required for the changes ~ proposed-by this Change Request because the requested changes conform to the criteria for " actions eligible for categorical exclusion" as specified in 10CFR51.22(c)(F). The requested changes'will have no impact on the environment. This Change Request does not involve a significant hazards consideration as discussed in the preceding section. This Change Request does not involve a significant change in the types or significant increase in the amounts of any effluents that may be released offsite. In addition, this Change Request does 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 Technical Specifications and have concluded that they do not

• avolve any unreviewed safety questions or any significant nazards considerations, and will not endanger the health and )

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. safety of the public.  !

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