ML20244D802
| ML20244D802 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/10/1989 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20244D806 | List: |
| References | |
| NUDOCS 8906190266 | |
| Download: ML20244D802 (8) | |
Text
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PHILADELPHIA ELECTRIC COMPANY i
2301 MARKET STREET P.O. BOX 8699 l
PHILADELPHIA, PA.19101 mm 8414000 Docket No. 50-352 l
License No. NPF-39 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 f
SUBJECT:
Limerick Generating Station, Unit 1 Emergency Technical Specifications Change Request Gentlemen:
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Philadelphia Electric Company hereby submits Technical Specifications Change Request No. 89-05, in accordance with 10 CFR 50.90, requesting an amendment to the Technical Specifications (Appendix A) of Operating License No.
Information j
supporting this change request is contained in Attachment 1 to this letter, and the proposed replacement page is contained in.
This submittal requests changes to the Technical Specifications (TS) to specify the applicability of TS Surveillance Requirement 4.1.3.5.b.2.
This Surveillance Requirement specifies the measuring and recording of the time, for up to 10 minutes, that each individual control rod accumulator check valve maintains the associated accumulator pressure above the alarm set point with no control rod drive pump operating.
This proposed change adds a footnote that states that this Surveillance Requirement only applies when the reactor vessel pressure is at or below 600 psig.
10 CFR 50. 91(a) (5) provides the criteria that must be satisfied in order for the NRC to find that a situation exists which justifies the approval of a TS amendment on an emergency basis.
As explained in our letter of June 9, 1989, requesting a temporary waiver of compliance until this proposed change is approved, the surveillance test required by TS 4.1.3.5.b.2 has been performed six times in the past with data being recorded as required, and a number of accumulators' check valves did not 8906190266 890610 fDR ADOCK 05000352
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a maintain pressure above the alarm setpoint for greater than or equal to 10 minutes.
We did not consider these accumulators to be inoperable since our ' interpretation of the basis of this TS Surveillance Requirement was that the test results were to be used -
i for' trending purposes and not to establish operability. ' on June 8,
1989, the NRC Resident Inspector' raised.the question as to the.
applicability of this Surveillance Requirement in the determination of accumulator operability. This matter was subsequently discussed with representatives of the NRC Region I and NRR,- and' agreement was -
reached that PECo would request a TS change on an emergency basis.
The above explanation provides the reason' why this emergency situation-occurred and why'this situation could not be ~
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avoided.
If this proposed change is not approved, the control rod.
accumulators that did not maintain pressureTfor greater thanor l
equal to 10 minutes would be considered inoperable, and the plant
~j would be shut down in accordance with'TS 3.1.3.5, Action 2.
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As stated above, we have submitted ' a ' request for a i
tenporary waiver-of compliance by our letter. dated June 9,.1989,
'to allow time for the processing of this TS change request on an emergency basis.
By letter dated June 9,19'19, the NRC granted our request.
If you have any questions regarding this matter, please.
l contact us.
l Very truly.yours, l
I G.
' Hunger, Jr.
Director
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Licensing Section Nuclear Support Division I
i Attachments j
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I cc:
W. T. Russell, Administrator, Region I, USNRC T. J. Kenny, USNRC Senior Resident Inspector, LGS T. Gerusky, Director, PA Bureau of Radiological Protection l
i RMK8905 l
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COMMONWEALTH OF PENNSYLVANIA.
ss.
'OUNTY OF YORK C
D.'M. Smith being. first' duly-sworn, deposes and says:
That he is.Vice-President - Peach Bottom Atomic Power Station of Philadelphia Electric Company, the' Applicant herein; ~ that' he 'has reviewed the foregoing Technical Specifications Change Request No. 89-05 and knows the contents thereof; and that the, statements and matters
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set forth therein'are true and correct to the best of his knowledge, information and belief.
8 Vice President - Peach-Bottom Atomic-Power Station l
Subscribed and sworn to before me this /v.z/ day
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of June,-1989.
JMj o
1 Docket No. 50-352-License No. NPF-39 i
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Philadelphia Electric Company, Licensee under Facility. Operating License NPF-39 for Limerick Generating Station (LGS) ' Unit 1, herebyt requests that the Technical Specifications ~(TS) contained in Appendix' q
A to the Operating License be amended to revise the Reactivity Control Systems
' Control Rod Scram Accumulators-TS to specify 'the j
applicability of Surveillance Requirement 4.1.3.5.b.2.
The proposed change is indicated by vertical bars in the margin of page 3/4 1-10, _
and provided in Attachment 2.
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The proposed revision to Limerick Unit l' Technical Specifications 4.1.3.5.b.2 is to delineate that ' the surveillance requirement for testing of the control rod SCRAM accumulator check ' valves is only I
applicable when the reactor pressure is less than or equal to 600 psig.
Accordingly, we request that the proposed change be approved on an i
emergency basis and made effective on issuance.
DISCUSSION AND DESCRIPTION OF CHANGES The proposed change to page 3/4 1-10 adds a note to Surveillance Requirement 4.1.3.5.b.2 which states "This surveillance requirement only applies when reactor vessel pressure is at or below 600 psig."
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The surveillance requirement provides assurance that ~the S(' RAM accumulator check valves will not permit the accumulator pressure to 1
l decay to a value such that the accumulators would be unable to assist I
in SCRAMing of the control rods, if the control rod drive pumps were q
not operating. This change ensures that the SCRAM accumulators provide sufficient energy to fully insert control rods at reactor pressures of 600 psig or less.
Above this pressure, reactor pressure provides l
adequate energy to insert the control rod without the assistance of the accumulators.
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INFORMATION SUPPORTING A FINDING OF NO SIGNIFICANT HAZARDS CONSIDERATION l
The proposed change was evaluated according to the standards of j
10 CFR 50.92 to determine if the proposed change constitutes a significant hazard.
The following evaluation of each standard is i
provided to support that conclusion.
(1)
The cronosed chance does not involve a significant increase in the probability or consequences of an accident oreviousiv evaluated.
Since the proposed Technical Specifications change does not affect the safety function of the SCRAM accumulator or control rods, the i
control rods will operate as designed.
With the reactor in power operation and reactor pressure below 756 psig, the Main Steam Isolation 3
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Valves (MSIVs) will isolate.
This isolation will cause a SCRA' on MSIV closure.
Any event which would slowly depressurize the reactor, would cause a SCRAM on MSIV isolation prior to pressure dropping below 600
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I psig.
During depressurization events that would reduce reactor j
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1 pressure below 600 psig, a SCRAM occurs within 5 seconds of event initiation.
This SCRAM at 5 seconds is fast enough to ensure the rods would SCRAM on accumulator pressure even if the control rod drive pump is not-operating and the accumulator begins to_depressurize.
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(2)
The crocosed chance does not' create the possibility of a new
.f or different kiiid of accident from any accident oreviousiv evaluated.
1 The purpose of the SCRAM accumulators is solely to assist in producing a successful SCRAM.
A failure to ' SCRAM is' analyzed' in
-l Section 15.8 of the LGS FSAR.
The FSAR describes, the method to adequately compensate for SCRAM failures in Section 15.8.3.5 by use of I
the standby liquid control system.
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(3)
The crocosed chance does not involve a significant reduction in a marain of safe h The safety function of the SCRAM accumulator is to assist in control rod insertion when reactor pressure alone is insufficient. The capability of the control rod to perform its safety function and provide proper reactivity insertion will remain unchanged.
Therefore, the margin of safety is not reduced.
INFORMATION SUPPORTING AN ENVIRONMENTAL ASSESSMENT The proposed TS changes involve no increase in the amounts and no change in the types of effluents that may be released offsite, and 3
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'g involve no increase in the individual or cumulative occupational radiation exposure; therefore an environmental assessment is not required.
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 a unreviewed safety question or a significant hazards consideration, and will not endanger the health and safety of the public.
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