ML20244B278
| ML20244B278 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/10/1989 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20244B282 | List: |
| References | |
| NUDOCS 8904190101 | |
| Download: ML20244B278 (13) | |
Text
_ - _ - _ _ _ - - _
d'. '.,
10 CFR'50.90 6'
.j
+
' PHILAD'ELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA A, PA.191o1 b
(2153841-4000 April 10, 1989 Docket No. 50-352.
License No. NPF-39' l
l.
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. 88-14, in accordance with.10 CFR 50.90, requesting an amendment to the Technical Specifications (Appendix A) of Operating License.No. NPF-39.
Information.
L 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 correct technical inconsistencies and also delete the requirement to completa snubber surveillance while shutdown.
If you have any questions regarding this matter, please contact us.
Very truly yours,
. h.
f.
G. A. Hunger, r.
Director Licettsing Section 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 8904190101 890410 i
PDR ADOCK 05000352 P
TECHNICAL SPECIFICATION CHANGE RPOUEST 88-14 s
COMMONWEALTH OF PENNSYLVANIA ss.
COUNTY OF PHILADELPHIA l
J. W. Gallagher, being first duly sworn, deposes and says:
l That he is Vice President of Philadelphia Electric Company, the Applicant herein; that ne has read the foregoing Application for Amendment of Facility Operating Licenses to reflect two-unit operation of Limerf.ck 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.
l
% foJkk c) o Vice President Subscribed and sworn to before me this /
day of 1989.
hU Notary Pq p c NOTARIAL SEAL PATR'OtA A. JONES, Notary Public ct/of Philadetchia Phita Count /
My Commission Expres Oct 13.1990
______.__._____._.-_____m-
(19-!:
g ATTACHMENT 1 1.
LIMERICK GENERATING STATION 1
Docket No. 50-352 License No. NPF-39
. TECHNICAL SPECIFICATIONS CHANGE REQUEST
" Clean-Up of Technical Items" Supporting Information for Changes - 11 pages E.
i 1
Docket No. 50-352 Philadelphia Electric Company, Licensee under Facility Operating License NPF-39 for Limerick Generating Station (LGS)
Unit 1, hereby; requests that the Technical Specifications (TS) contained in Appendix A of the Operating License lx! amended as proposed herein to correct several technical inconsistencies and to revise a surveillance test requirement due to the tie-in and operation of LGS Unit 2.
The proposed changes.are indicated by vertical bars in the margin of the pages 3/4 3-2, 3/4 3-11, 3/4 3-17, 3/4 3-18, 3/4 3-23, 3/4 3-27, 3/4 4-9, 3/4 6-57, 3/4 7-13, 6-5, and provided in Attachment 2.
Philadelphia Electric Company requests the changes proposed herein to be effective prior to the iseuance of the Unit 2 Operating License, to ensure that these inconsistencies do not become part of the Unit 2 Operating License.
This Change Request provides a discussion and description of the proposed TS changes, a safety assessment of the proposed changes, information supporting a finding of No Significant Hazards Consideration, and information supporting an Environmental Assessment.
I Discussion and Description of Changes:
l I
i A total of six (6) changes are addressed in this Change l
Request.
Each proposed TS change is detailed below. _ _ _ _ _ _ _ - - _ - - - _ _ _ _ _ - - _ - - _ -. - - _ - - - _ - _ - - - - - - - - - - - - - -
-- ]
Docket No. 50-352 Item 1 Page 3/4 3-2 Delet' Operation Condition 4 in Table 3.3.1-1, Items 2.a and 2.c.
Currently, TS Table 3.3.1-1 requires operability of the Average Power Range Monitors (APRMs) in Operational Condition (OPCON) 4.
However, this requirement is inconsistent with the corresponding surveillance requirement shown in TS Table 4.3.1-1, which does not specify OPCON 4 testing requirements.
The LGS Unit 1 TS were based upon the Standard Technical Specifications (STS) which do not require operability of the APRMs in OPCON 4.
To correct the error and achieve consistency between TS Table 4.3.1-1 and the requirements specified in the STS, Table 3.3.1-1 Items 2a and 2c should be revised to delete the reference to OPCON 4.
Item 2 Page 3/4 4-9 Revision Action b to specify LCOs "b,
c and/or d" rather than "b and/or c" The Limiting Condition for Operation (LCO) contained in the LGS TS for Reactor Coolant System Operational Leakage are based upon four LCOs specified in the STS.
Of these four LCOs, two are referenced in the STS Action "b"
(5 gpm UNIDENTIFIED LEAKAGE -
item b and 25 gpm total leakage averaged over a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period -
item d).
During the development of the Unit 1 TS an additional LCO was added.
This LCO, "c",
(30 gpm total leakage) specified additional limitations on the amount of reactor coolant leakage l !
9 Docket No. 50-352 allowed during operation.
As a result of this added limitation, the Action "b"
requirements of the LGS TS should have been revised to reflect all three LCOs rather than the two LCOs of the STS.
To correct this discrepancy Action "b"
should be revised to include all three LCO Items "b", "c" and "d".
Item 3 Page 6-5 Add Footnote
- to the SRO position in Table 6.2.2-1.
TS Table 6.2.2-1, of TS Section 6.0,
" Administrative Controls",
specifies the minimum shift crew composition for all operating conditions at LGS.
In the section of this table that applies co Unit 1 in OPCON 1, 2, or 3, with Unit 2 in OPCON 4, 5 or defueled, an asterisk (*) must be added to the SRO position.
The asterisk footnote in Table 6.2.2-1 allows the SRO to fill the same position on Unit 2.
This proposed change will result in consistency with Final Safety Analysis Report (FSAR) revision 18 Table 13.1-2 which is documented as being acceptable in the NRC Safety Evaluation Report (SER), Section 13.1.2.1, issued for LGS Units 1 and 2, and dated August 1983.
Item 4 Pages 3/4 3-11, 3/4 3-17, 3/4 3-18, 3/4 3-23, 3/4 3-27 in Tables 3.3.2-1, 3.3.2-1 (Table Notations),
3.3.2-2,
]
3.3.2-3 and 4.3.2.1-1, respectively, require revision to accurately reflect temperature element locations and
)
l setpoints.
I -__
. Docket'No. 50-352 EThese proposed TS changes will (1) clarify the nomenclature.used in describing instrument locations, and (2). properly' designate the actual locations and setpoints of the leak detection-l instruments currently 'dentified in the TS.
i l
t The proposed changes will cortect' errors in the'TS and thereby make it consistent with the original design and design ~ basis analysis of: the plant.
No. physical changes will.take place.
Technical. Specification Tables 3.3.2-1, 3.3.2-2,,3.3.2-3.andL 4.3.2.1-1 are proposed to be revised indicating two specific R
locations. monitored by the Main Steam Isolation Valve --Leakage Detection' System (MSIV-LDS).
The change revises: Item 1.f'to denote the " Outboard MSIV Room' Temperature High".
The second location is specified by Item 1.g which will continue to denote the " Turbine Enclosure - Main Steam Line Tunnel - High"..
Recognizing that setpoints for the temperature sensors depend upon the area !.n which the sensors are located, Item 1.f~will reflect the four (4) GE temperature sensors located in the-Outboard MSIV Room with a specified setpoint of 192 degrees F.
The minimum operable channels per Trip System will be revised to two (2).
This corresponds to the total number of sensors located in this area.
The remaining twelve (12) GE temperature sensors located in the Turbine Enclosure will be reflected in Item 1.g with a specified setpoint of 165 degF.
The minimum number of operable channels will be revised to fourteen (14). !
e Docket No. 50-352 Item 5 Page 3/4 7-13 Delete "during shutdown" in TS 4.7.4.c TS 4.7.4.e requires that snubbers be demonstrated operable by sampling and performing testing "during the first refueling outage and at least once per 18 months during shutdown".
Scheduling these tests during a refueling outage can be accomplished such that the redundant loop of a given system is available and plant operational requirements can usually be maintained.
A problem arises, however, when testing snubbers of common equipment (equipment used by both units) with only one I
unit of a two unit facility shutdown for refueling.
Since there are common systems supporting both LGS Unit 1 '<nd Unit 2, snubber testing may be required when only one unit is shutdown and therefore would not meet the strict interpretation of "during shutdown".
To allow the flexibility to perform snubber surveillance during operation, surveillance requirement 4.7.4.e should be revised to delete the words "during shutdown".
Item 6 Page 3/4 6-57 Revise the hydrogen recombiner resistance test value specified in 4.6.6.1.b.2 from 100 megohm to 1 megohm LGS has encountered difficulty with Specification 4.6.6.1.b.2 in meeting the 100 megohm heater phase resistance to ground surveillance.
Discussions with the manufacturer have indicated that the 100 megohm value for resistance to ground for the heater l
elements is incorrect.
The correct resistance value is 1 megohm.
l i 7
{
l J
9 Dockst No.-50-352 o
The 100 megohm value reflects the required resistance to ground t
value for other circuits in the recombiner and was erroneously applied ~to the heater elements.
To correct this error, TS 4.6.6.2.b.2 should be revised to 1 megohm.
Safety Discussion:
The proposed revisions, as described above, Items 1, 2,
3, 4, and 6 are necessary to achieve consistency vith plant configurations or the licensing basis, or correct inaccurate information in the TS.
The proposed revisions do not affect plant hardware, plant design, or plant-system operation.
In addition, the proposed revisions do not. result in changes to the design bases.
For Item 5, the proposed revision to delete the words "during shutdown" provides the flexibility to perform snubber testing during operation.
This change allows these snubbers which are accessible dering reactor operation to be tested under the constraints of the existing action statements.
As such, the change does not impact any allowable out-of-service times or any surveillance test intervals and would not adversely impact the ability of the. emergency equipment to safely shutdown the plant.
i {
1
)
l
Docket No. 50-332 Information Supporting a Finding of No Significant Hazards Consideration We have concluded that the proposed changes to the LGS TS, which correct technical inconsistencies and revise the snubber surveillance test requirement due to the tie-in and operation of. Unit 2, do not constitute a significant hazard consideration.
In support of this determination, an evaluation of each of the three standards set forth in 10 CFR 50.92 is-provided below.
1 A.
The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes which correct technical inconsistencies will correct errors currently existing in the TS or achieve consistency throughout the TS.
The proposed change to allow the surveillance testing of snubbers during operation would eliminate the restriction that the 18 month inspections be performed I
while the unit is shutdown.
None of these changes will affect any plant hardware, plant design, safety limit settings, or plant system operation, and therefore do not modify or add any initiating parameters that would significantly increase _ _ _ _ _ _ _ _ _ _ _ - _ _ - - _
l I
Docket No. 50-352 1
the probability or consequences of any previously analyzed accident.
Therefore, the proposed changes will not result in a significant increase in the probability or consequences of any accident previously evaluated.
B.
The proposed changes do not create the possibility of a new or different kind of accident from any accident' previously evaluated.
As discussed in Item (1) above, the proposed TS changes i
correct errors, provide consistency throughout the TS, or are the result of the tie-in and operation of Unit 2.
The proposed changes do not affect any equipment nor do they involve any potential initiating events that would create any new or different kind of accident.
As such, the plant initial conditions utilized for the design basis accident analyses remain valid.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
C.
The proposed changes do not involve a significant reduction in a margin of safety.
As-discussed in (1) above, the proposed changes which correct technical inconsi'etencies, do not affect any i
equipment involved in potential initiating events or l
1 m____
j
Docket No. 50-352 safety limit settings and therefore, do not involve a significant reduction in a margin of safety.
The change to remove the requirement to perform snubber surveillance during shutdown does not involve a significant reduction in a margin of safety, since snubbe operability will continue to be demonstrated in accordance with the existing surveillance test intervals which have not been changed.
The bases establish snubber-functional reliability by specifying testing methods which prescribe sample size and sample acceptance but not the operation status of the associated reactor.
All snubbers are demonstrated to be operable under existing criteria and the guidelines of the current Technical Specifications.
Removing the requirement to perform snubber testing during shutdown does not change the operability or testing requirements for snubbers.
Therefore, the proposed change to remove the r~quirement to perform snubber surveillance during shutdown does not involve a significant reduction in a margin of safety.
I Information Supporting an Environmental Assessment i
l 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 10 CFR Sl.22(c)(9).
The l
,1 t.
.c
. Docket ~No.
50-352 re. quested. 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 <',e.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.
.s Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes to the TS and' have concluded that they do not involve an unreviewed safety question or a significant hazards consideration, and will not endanger the health and safety of the public.
I I
l 1
i
(
l l
-