ML20244B262

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Application for Amend to License NPF-39,consisting of Tech Spec Change Request 88-02,changing Tech Specs to Reflect two-unit Operation of RHR Svc Water Sys & Emergency Svc Water Sys
ML20244B262
Person / Time
Site: Limerick Constellation icon.png
Issue date: 04/10/1989
From: Hunger G
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20244B264 List:
References
NUDOCS 8904190095
Download: ML20244B262 (28)


Text

_ - __._ _ _ _

<j 10 CFR 50.90 1

e 1

l PHILADELPHIA ELECTRIC COMPANY 23ol MARKET STREET P.O. BOX 8699 PHILADELPHIA A. PA.191o1 (21518414000 April 10, 1989 l

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. 88-02, 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.

This submittal requests changes to the Technical Specifications to reflect two-unit operation of the Residual Heat Removal Service Water System and the Emergency. Service Water System.

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

Very truly yours, fo G. A.

Hunger, Jr.

Director Licensing Section Nuclear Support Division a

i 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 8904190095 890410 h

PLIR ADOCK 05000352 l

P PDC i\\\\

TECHNICAL SPECIFICATION CHANGE' REQUEST.88-02 m-L COMMONWEALTH OF PENNSYLVANIA 1

1 ss.

COUNTY OF PHILADELPHIA J. W. Gallagher, 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 Licenses to' reflect two-unit operation of Limerick Generating Station, 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.

h I

u u

Vice President Subscribed and sworn to before me this /d day i

of 1989.

j NotaryM9lic l

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NOTARAL SEAL

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~ PATR! CIA A. JONES.Nouy Public

' CW of Philadelphia, Pnda. County My Cemmission Dpires O:t 13.19%

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-ATTACHMENT 1 i

i LIMERICK GENERATING STATION i

l

.l Docket No. 50-352 i

License No. NPF-39 4

TECHNICAL SPECIFICATION CHANGE REQUEST "Two-Unit Operation of Residual Heat Removal Service Water. System and the Emergency Service' Water System" Supporting Information for Changes - 26 pages l

1 I

i

a Docket No. 50-352 License No. NPF-39 R

Philadelphia Electric Company, Licensee under Facility Operating License NPF-39 for Limerick Generating Station (LGS) i Unit 1, hereby requests that the Technical Specifications (TS) 1 contained in Appendix A to the Operating License be amended to revise the Emergency Service Water (ESW) and Residual Heat 1

Removal Service Waier (RHRSW) TS to reflect the operation of LGS I

i Unit 2.

The proposed changes are indicated by vertical bars in the margin of pages 3/4 7-1, 3/4 7-2, 3/4 7-3, 3/4 7-4 and Bases page B 3/4 7-1, B 3/4 7-la, and provided in Attachment 2.

The purpose of this amendment application is to request changes,to the present Unit 1 Technical Specifications for the RHRSW system and the ESW system in order to reflect two-unit operation of the LGS.

The RHRSW system and ESW system have been previously evaluated and approved for two-unit operation in the NRC Safety Evuluation Report (SER), NUREG-0991, Sections 9.2.2 and 9.2.1 and the LGS Final Safety Analysis Report (FSAR)

Sections 9.2.3.2 and 9.2.2.6, respectively.

The current TS Limiting Conditions of Operation (LCO) contain special provisions for one-unit operation with a second unit under construction.

We are requesting that the TS LCO be amended to reflect the original design for two-unit operation of LGS.

Accordingly, we request that the proposed changes be effective upon issuance of the Unit 2 Low Power Operating License. <

d E

Docket No. 50-352 License No. NPF-39 The proposed-changes to the Unit 1 TS described in this change request are grouped into two sections; Section 1 -

Residual Heat Removal Service Water System and Section 2 -

Emergency Service Water System.

Each section of proposed changes

- includes:a System Discussion, Description of.the Changes, a Safety Discussion and information to support a finding of No.

Significant Hazards Consideration.

The application concludes with a common Environmental Consideration and a common Conclusion.

Section 1 - Residual Heat Removal Service Water System System Description - Section 1:

The Residual Heat Removal Service Water (RHRSW) system

. is a safety-related system designed to supply cooling water to the RHR heat exchangers of both units.

i The RHRSW system is common La both reactor units and consists of two loops.

Each loop services two RHR heat exchangers (one RHR heat exchanger in each unit) and provides sufficient cooling for safe shutdown, cooling, and accident mitigation of both units.

The two RHRSW system return loops can i

be cross-connected for operational flexibility.

Two valves in series are provided on the cross-connect, so a failure in one loop could be isolated from the other loop and, thus, not affect the operation of the other loop.

Each loop has two pumps located 1 __

1'

){ t, 3.-'

R C Docket'No. 50-352-License No.'NPF-39

.7 in the spray pond pump structure.. One pump has the capability to s u p p l y l 1 0 0 % 'f l o w t o o n'e R H R h e a t ' e x c h a n g e r ' i n t h e ' a s s o c i a t e d
n loop.- During two-unit operation,fthere are two heat exchangers-p r

h (one per unit): required for safe shutdown.and accident mitigation

]

~

d of'both units (see figure 1).

h j

The RHRSW system'is'available for normal shutdown or L

emergencies, and does not.usually operate during power operation.

However,'the RHRSW system can be used in' conjunction with the RHR-system suppression, pool cooling mode to maintain the suppression

~ pool below specified temperature limits.

a The'RHRSW return piping from the RHR heat exchangers and the return. piping from the corresponding Emergency Service Water (ESW) loop share a common return header to the spray pond or y.'

cooling tower.. Loss of one RHRSW/ESW return loop does not affect the capability of the second return loop to safely shut down P

'either or both units.during emergency conditions.-

Following receipt'of. the Unit 2 operating license, emergency backup power for the

'C' and

'D' RHRSW pumps will be supplied from the' Unit 2 j

emergency diesel generators (EDG).

This configuration exists due l

to the common design of the RHRSW system and must be recognized by operators when entering'any ACTION for RHRSW.

The importance of recognizing the. interdependency on the other unit's emergency 3

' diesel generators is reflected in the proposed changes to the Technical Specifications. l

. c.,

c' Docket No. 50-352 License No. NPF-39 System Tie-In Discussion - Section 1:

During the second refueling outage for Unit 1, the Unit 2 portion of the RHRSW system will be tied in to the Unit 1 and Common' portions of the system.

This tie-in will be accomplished by removing the blind flanges present in the RHRSW piping within the Unit 1 Protected Area Boundary (PAB).

Currently, we plan to perform the tie-in on only one RHRSW loop at a time so that the operability of the other loop is 2

maintained in accordance with the applicable requirements of the RHRSW Technical Specification for Unit 1 in the shutdown mode.

Once the tie-in is completed or. LL.c inoperable loop, flow balancing and preoperationaA testing are scheduled to commence.

Upon completion of the-preoperational testing, the system will have satisfied the prerequisites to begin the reviews associated l

with the approval cycle, and if found acceptable, declared operable.

At that time, the other loop will be available for the

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system tie-in.

Once the tie-ins are made on both loops, with flow balancing and preoperational testing complete, the RHRSW system will be in the final two-unit configuration as originally described in the FSAR and evaluated in the SER.

I 1 _ _ _ - _

)

l.

s1 i'1

. Docket'No. 50-352.

he License No. NPF-39 Description of Changes - Section 1

-Page 3/4-7-l' A' change is proposed to the Limiting condition for Operation (LCO) b. which would j

)

add the words " Unit'1".in order to clarify.the fact that this LCO references Unit'1 RER heat.

exchangers.

i Page 3/4.7-1 A' change is proposed which j

would combine old Action-

'l Statement a.1 and old Action i

. Statement a.2 as the new Act' ion St'atement a.l.

This' change

)

I eliminates the difference in I

time to restore theC' or

'D' pump to operable status by f

I decreasing the allowable out of j

service time from 92 days to 30 days (cid Action Statement i

a.2).

Two-unit operation

)

requires two pumps for. safe

]

shutdown necessitating the same availability for the

'C' and

'D' pumps as the

'A' and

'B' pumps.

Since these pumps will : _

2-

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Y'&

Docket No. 50-352'-

Lic3nne No.'NPF-39' be-redundant and'poweredLfrom

'their design. power sources,-the" differences in'the allowable outage" times.are being. removed.

- 'Page 3/4-.7-1

,A' change is. proposed to renumber and reformatLold Action Statement a.3 as'a newt Action' Stat'ement a.2 to reflect-two-unit operation.

Page 3/4 7-l' A change is proposed which would renumber and reformat old Action Statement'a.4.as new Action statement'a'.3'to' reflect

.two-unit operation.

Page 3/4 7-1

.A change is proposed which would renumber and reformat old Action Statement a.5 as new Action Statement a.4 to reflect two-unit operation.

Page 3/4 7-2 Action Statement a.5 verifies the capability of powering the operable ~RHRSW pumps from an operable diesel generator.

l This Action Statement will I

l

i' Dockot No. 50-352 Lican20 No; NPF-39' serve.to. ensure'that plant operators recognize the-interdependency which exists with Unit 2 diesel generators.

Page 3/4 7-2' A change is proposed which would delete Action Statement d.

This-Action Statement will no longer be applicable following the receipt of the Unit 2 Low Power Operating License due to the fact that

'l the Unit 2 portions of the system will then be_ fully operational and contained within the PAB.

Page'3/4 7-2 A change is proposed which would delete surveillance requirement 4.7'.l.l.b which states: "At least once per 18 months d' ring shutdown.by verifying that the' isolation function occurs on a radiation test signal".

This i

l=

surveillance test is already l'

performed once every 92 days as l u-_-L----.-____----.

s*

Docket No. 50-352 Licanno No. NPF-39 b

^

I part of the channel functional l

test required by Technical Specification 4.3.7.11 (Table 4.3.7.11-1).

'B 3/4 7-1 The Bases have been. expanded to discuss two unit operation'and the design bases; requirements.

B 3/4 7-la.

This additional Bases page.was required to accommodate the i

expanded description.

Safety Discussion - Section 1:

The LGS Unit 1 Technical Specifications, as currently written, reflect that LGS Unit 2 is under construction and credit

'is taken for the ability to utilize RHRSW pumps associated with Unit 2 in the Unit 1 Technical Specifications.

Specifically, the if RHRSW Technical Specifications contain special provisions for operation of all four RHRSW pumps while the piping leading to the Unit 2 portion of the RHRSW system is isolated through the use of j

blind flanges within the Unit 1 PAB.

The proposed changes to the Action Statements in the Limiting Condition for Operation and the Surveillance Requirements for the RHRSW system reflect two-unit operation of LGS, including the operability of the Unit 2 electrical sources _ - _ _ _ _ _ _ - _ _.

t Docket No. 50-352 License No. NPF '

which power the

'C' and 'DRHRSW pumps.

In addition, the operability of the Unit 2 emergency diesel-generators and the additional Unit 2 equipment will relieve operating restrictions on-Unit 1, which currently exist due to the interconnection with a unit under construction, and will improve overall system reliability.

This relief is reflected in the proposed changes to the Technical Specifications.

The proposed changes to Technical Specifications also add a new Action statement a.5 which will ensure that plant operators recognize the interdependency which exists on the other unit's diesel generators.

The 3.0.4 exception designated in Action 5(a) would allow OPCON changes for a single configuration of operable RHRSW pumps and inoperable Unit 2 diesel generators (DGs).- This exception is allowable since it can only be applied in a unique case: when both Unit 2 DGs which feed the

'C' and

'D' RHRSW pumps are inoperable with all four (4) RHRSW pumps operable.

Although entry into Action 5(a) may be for other combinations of inoperable DGs or RHRSW pumps, the Unit 1 Action statements which would apply do not allow a 3.0.4 exception.

Therefore, use of a 3.0.4 exception is precluded for all cases except when all four (4) RHRSW pumps are operable with

'C' and

'D' RHRSW pumps not capable of being supplied by the associated DG.

For this unique case, sufficient redundancy and reliability exists to easily meet the heat rejection loads for the design bases scenarios.

The..

q.-

i ai Docket,No. 50-352 Licenso No. NPF-39

~

. Action statement is consistent with this and describes remedial measures, which if compl'ied;with, allow operation to continue indefinitely.

Thus, it'is acceptable to include the 3.0.4 exception as proposed..

.The LGS Residual Heat. Removal Service. Water System, as described in FSAR'Section 9.2.3, has been'previously evaluated

'and approved for two-unit operation in the NRC's SER.section-9.2t2.

The Technica1' Specifications changes, as requested herein, will ensure-that the Limerick Generating Station Unit 1

~

Technical' Specifications' allowable out-of-service times are consistent.with'NUREG-0123, " Standard Technical Specifications" forftwo-unit l operation.

Information. Supporting a Finding of No Significant Hazards Consideration - Section 1 The proposed changes to the Technical-Specifications

-Limiting Conditions for Operation and Surveillance Requirements for the'RHRSW system reflect two-unit operation at Limerick Generating Station and do not involve a Significant Hazards Consideration.

In order to support a No Significant Hazards i

Consideration determination, an evaluation of each of the three j

standards set forth in 10 CFR 50.92 is provided below.

The proposed Technical Specifications changes do not:.

L_--_._.

Docket No. 50-352 License No. NPF-39 i

'l 1.

Involve a significant increase in the probability or consequences of'an accident previously evaluated.

1 l

Since the' proposed Technical Specifications changes l

reflect no functional change to the Unit l'and Common RHRSW system, the system will operate

(

exactly as before.

The system's capability to perform its safety-related functions will be improved due to the additional reliability present from the Unit 2 operable diesel generators.

These Technical Specifications changes are necessary to be consistent with the final two-unit design configuration of the RHRSW system.

All accidents previously analyzed that require operation of this system were evaluated in FSAR Chapter 15 with the system in its two-unit configuration.

2.

Create the possibility of a new or different kind of accident from any accident previously evaluated.

These proposed Technical Specifications changes reflect the final two-unit configuration of the RHRSW system upon which the FSAR Chapter 15 analyses are based.

l i

Docket No. 50-352 Licenns No. NPF-39 The proposed changes to the Limiting Condition for Operation Action statements will result in operational parameters for the RHRSW system which have been previously evaluated in the original NRC SER for the two-unit operation of Limerick Generating Station.

Therefore, these changes do not create a new or different kind of accident that has not been considered in the previously approved two-unit operating system configuration as described in the FSAR.

3.

Involve a significant reduction in a margin of

safety, i

The proposed Technical Specifications changes provide for two-unit operation and eliminate unique requirements which were in place due to single-unit operation.

These changes will result in this Technical Specifications allowable out-of-service times being consistent with NUREG-0123 " Standard Technical Specification".

The capacity of the RHRSW system and its ability to perform its safety-related function will remain unchanged.

Therefore, the applicable margin of safety will not be changed.

The RHRSW system operation during two-i unit operation was previously evaluated and found j l

y, m

' !. ~

Docket No.- 50-3521 Licanse No. NPF-39 acceptable'by the NRC in SER Section 9.2.2.

Therefore, the proposed changes do not reduce this approved margin of safety'.

Section 2 - Emergency Service Water Syst'em System Description - Section 2:

-The Emergency Service Water (ESW) system is a safety-related system, designed to supply cooling water to selected equipment during a loss of offsite power condition and/or loss-of-coolant accident (LOCA).

It is comprised of two independent

. loops

('A' and

'B') with each loop consisting of two pumps

('A' and

'C',

or

'B' and

'D').

Each pump is capable of supplying 100%

flow through its respective loop.

Each pump can supply'four-emergency diesel generators and all other required cooling loads for safe shutdown for both units.

Each ESW pump motor is powered from separate class IE buses with backup power provided by an emergency diesel generator (see figure 2).

l The ESW pumps start automatically on the associated diesel generator start.

The ESW pumps can also be manually started from the control room.

On an ESW pump start the appropriate valves realign to take suction from and discharge to the spray pond.

l..

. l l

L____________________--__

. Docket No. 50-352 License No. NPF-39 ESW loop

'A' and

'B' piping is physically separated or protected so.that no single event can render both loops inoperable.

The

'A' and.'B' pumps are powered from Unit 1 buses.

Precently the

'C' and

'D' pumps are temporarily powered from Unit 1 buses.

Following receipt of the Unit 2 Low Power Operating License, emergency backup power for the

'C' and

'D' ESW pumps will be supplied from the Unit 2 emergency diesel generators.

This configuration exists due to the common design of the ESW system and must be recognized by operators.

The importance of this interdependency to Unit 2 diesel generators is reflected in Action statement a.4 of the proposed Technical Specification.

System Tie-In Discussion - Section 2:

During the Unit 1 second refueling outage, the Unit 2 portion of the ESW system will be tied in to the Unit 1 and Common portions of the system.

This tie-in will be accomplished by removing the blind flanges present in the ESW piping within the Unit 1 Protected Area Boundary (PAB) and opening the flowpaths to the Unit 2 cooling loads.

t Currently, we plan to perform the tie-in with one loop being declared inoperable in accordance with the existing Technical Specifications requirements.

Once the system tie-in is i

completed on the inoperable loop, flow balancing and preoperational testing will commence.

Upon completion of the preoperational testing, the pumps will be returned to the normal - - - - _ - - - - - - _ _ - - - _ _ - _ _ _ _ _ _ _

i

l Docket No. 50-352 l

License No. NPF-39

)

power source and the system will be declared operable, at which l

1 point the other loop will be available for the system tie-in.

Once the system tie-in is complete on both loops, with flow I

l balancing and preoperational testing completed, the ESW system will be in the final two-unit configuration as described an6 l

evaluated in the FSAR, except for the

'C' and

'D' pump power i

supplies, which will not be transferred to the Unit 2 4 kV buses until Unit 2 receives a low power operating license, l

Description of Changes - Section 2:

Page 3/4 7-3 A change is proposed to the i

Limiting Condition for Operation (LCO) b. which would add the words, " Unit 1 and Common" to the phrase in order to assure that a blocked Unit 2 i

flowpath in an ESW loop cannot cause the ESW loop to be declared inoperable for Unit 1 1

since it is still able to perform its Unit 1 function.

Page 3/4 7-3 A change is proposed to Action statement a.3 which would provide consistency for two-unit operation. _ - _ _ - _ _ _

Docket No. 50-352 License No. NPF-39 Page 3/4 7-3' New Action statement a.4 on r

~

page 3/4 7-4 is proposed to verify the_ capability of J.-

powering the operable ESW pumps from an' operable diesel generator.

This Action statementLwill serve to ensure

' hat plant operators recognize the interdependency which exists on Unit 2 diesel generators.

Page 3/4 7-3 Changes are proposed which would reformat Action statement b.l.

Page-3/4 7-3 A change is proposed to the double asterisk footnote to assure that operators refer.to the emergency diesel generator (EDG) Technical Specifications when it is determined that an EDG is not operable.

Page 3/4 7-4 A change is proposed which would renumber old Action statement b.2 to new Action statement col.

In addition, 4

! l I

1 1

C5 4

+*

Docket No. 50-352 l

Licen20'No. NPF-39 a

this Acti'on' statement is'being-1

-reformatted.

l

.Page 3/4 7-4 A change is proposed which would delete old Action t

statement c, on page 3/4 7-4 l

thereby relieving-the restriction on inter-connection with Unit 2 after Unit 2 has been placed within the PAB.

B 3/4.7-1 The Bases have been expanded-to discuss two-unit opertion and the design bases requirements..

B 3/4 7-la This additional Bases page was necessary to accommodate the expanded description.

Safety Discussion:

The Limerick Generating Station (LGS) Unit 1 Technical Specifications, as currently written, reflect that LGS Unit 2 is i

under construction.

Accordingly, this is reflected in the Unit 1 Technical Specifications Action statements as the ability to utilize ESW pumps associated with Unit 2 power supplies.

I Specifically, the ESW Technical Specifications contain special l 1

Docket No. 50-352 License No. NPF-39 provisions for the piping leading to the Unit 2 portion of the ESW system being isolated within the Unit 1 PAB.

The proposed changes to the Action statements of the Limiting Condition for Operation for the ESW system reflect two-unit operation of LGS including the operability of the Unit 2 emergency diesel generators which will power the

'C' and

'D' ESW pumps.

In addition, the operability of the Unit 2 emergency diesel generators and the connection of the Unit 1 and Unit 2 piping will relieve operating restrictions which currently exist due to the interconnection with a unit under construction.

The LGS ESW pumps each have sufficient capacity to supply cooling water to four emergency diesel generators and the associated cooling loads required for safe shutdown for both units.

The proposed changes to Technical Specifications also add an Action statement which will ensure that the plant operators recognize the interdependency to Unit 2 emergency diesel generators.

This addition will ensure that sufficient q

l margin of safety is maintained when an ESW Action statement is

{

1 entered.

The LGS Emergency Service Water System has been described in FSAR Sectisn 9.2.2 and previously evaluated and approved for two-unit operation in the NHC's SER section 9.2.1.

I With a total of eight emergency diesel generators for both units, the ESW pumps have a highly reliable source of emergency power should the station lose offsite power. l l

a' Docket No. 50-352 License No. NPF-39 Information to Support a Finding-of.

1 l

No Significant. Hazards Consideration:

The proposed changes to the Technical Specifications

' Limiting Condition for Operation and Surveillance Requirements for the ESW system reflect the two-unit operation of Limerick Generating Station and do not involve a Significant Hazards Consideration.

In order to support a No Significant Hazards Consideration determination, an evaluation of each of the three standards set forth in 10 CFR 50.92 is provided below.

The proposed Tcchnical Specifications changes do not:

1.

Involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed changes to the Technical Specifications do not reflect a functional change to the Unit 1 and Common ESW System' operation.

The Unit 2 portions of the ESW system were designed, installed, and will be tested to the same requirements as the Unit 1 and Common portions of the system.

The proposed changes to the Technical Specifications are required to reflect the final two-unit configuration of the ESW System as originally designed and described in FSAR Section 9.2.2.

The revised Action statements will make no _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _

L

+;y

>f

-Docket'No.~50-352' License No.s NPF-39 change.in the. system's' capability to operate as designed..

The present Technical Specification restriction exists to provide adequate separation from Unit'2 equipment-outside the PAB.

Since Unit 2 equipment' will be placed;within.the PAB, the restriction is~

no longer needed.

Therefore, the changes do not increase the probability or consequenceslof an l..

accident previously evaluated.

The proposed b,

changes to'the Technical Specifications also assure the availability of emergency power'to the remaining ESW pumps by reminding-operators of'the plant' interdependency on emergency diesel generators.

2.

Create the' possibility of a'new or different-kind of accident from any accident previously evaluated.

The proposed changes to the Technical Specifications provide for two-unit operation as described and evaluated in the SER and the FSAR.

The changes provide relief from the restriction on inter-connection'with Unit 2 following its

' inclusion within the PAB.

In the final two-unit system configuration, there will be no functional 1 1

w.--.-_.-_.-_--_.N..-.-

?.

Docket No. 50-352 License No. NPF ~

i change in the system operation and its ability to perform its intended safety function ~as; described-in the FSAR.

Therefore, the proposed changes do not create a new or different kind of accident from any accident previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The proposed changes to the Technical Specifications are consistent with two-unit operation of Limerick Generating Station.

The two-unit operation of Limerick Generating Station has been previously evaluated in the'.FSAR section 9.2.2 and previously evaluated and approved in SER section 9.2.1.

There is no change in the system's capability and its ability to perform its safety-related function, and consequently in the applicable margin of safety, as a result of these proposed changes to the Technical Specifications.

i Therefore, the proposed changes will not reduce the i

margin of safety. l

=L_-_-__-______

\\

Docket No. 50-352 License No. NPF-39 Information to Support an Environmental Assessment (For Section 1, RHRSW, and Section 2, ESW):

An environmental impact assessment is not required for the changes requested by this Application because the requested changes conform to the criteria for " action eligible for categorical exclusion" as specified in 10 CFR 51.22(c)(9).

The requested changes will have no impact on the environment.

The Application involves no significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and there is no significant increase in individual or cumulative occupational radiation exposure.

Conclusion The proposed changes to the Technical Specifications allow operation of Limerick Generating Station Unit 1 reflecting the operating status of Unit 2.

The tie-in of the Unit 2 side of the RHRSW and ESW systems will not result in any decrease in the level of safe operation of Unit 1.

Description of the two-unit operation of Limerick Generating Station has been previously evaluated and found acceptable.

Additionally, the operating status of the four Unit 2 emergency diesel generators will serve to increase the reliability of emergency power at LGS through a substantial redundancy of emergency power sources available during a plant transient.

q 4

Docket No.,50-352 i.

Licensa No. NPF-39 The Plant Operations Review Committee and the Nuclear Review Board-have reviewed these proposed changes'to the t

Technical-Specifications and have concluded that they do not involve untsviewed safety questions or involve a Significant Hazards Considerations, and will not' endanger the health and safety of the public.

i i

l _

Licensehe.NPI-59 1

FIGURE i RHR Service Water System Simplified Schematic for Units 1 & 2 Operation 1

1A 2A 18 28 f

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RHRSW Pumps Loop A Supply l

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Loop B Supply

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2B 1A 1B RHR Heat 2A Exchangers

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Loop A Lu From ESW Loop A Loop B l Return j

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Loop B Return

[@q7 c. Spray. Pond gin.,rr.-*; Network.

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TIGURE 2 i> 0 e r.e t ' o,

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License Sn. NPF-39 b

a s

Emerc ency Service Water System

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Simplified Schematic for Units 1 & 2' Operation 1A 2C EDGs 1B 2D e

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