ML20245F866
| ML20245F866 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/20/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20245F865 | List: |
| References | |
| NUDOCS 8906280273 | |
| Download: ML20245F866 (6) | |
Text
.__ _
- [
UNITED STATES y
g NUCLEAR REGULATORY COMMISSION 5
j
("ASHINGTcN, D. C. 20555
\\...../
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 28 TO FACILITY OPERATING LICENSE NO. NPF-39 PHIL/DELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION, UNIT 1 DOCKET NO. 50-352 i
r
1.0 INTRODUCTION
By letter dated April 10, 1989, Philadelphia Electric Company (the licensee) requested an amendment to Facility Operating License No. NPF-39 for the Limerick Generating Station, Unit 1.
The proposed amendment would revise the Technical Specifications to:
- 1) delete the requirement that the Average Power Range Monitors be operable when the plant i:; in the cold shutdown condition, 2) revise the reactor coolant 1cakage requirements to l
be similar to the leakage rates in generic letter 88-01, 3) modify the table on minimum shift crew composition to permit the SR0 for Unit 1 to serve the same position for Unit 2 when Unit 2 is in cold shutdown, being refueled or is defueled, 4) clarify the location of the temperature sensors used to detect leakage from the main steam lines, 5) permit I
snubber surveillance to be performed when a unit is operating and 6)
I correct an error in the test value listed for the hydrogen recombiner phase, resistance to ground for the heater elements.
2.0 DISCUSSION l
1 A total of six (6) changes are addressed in this requested amendment. Each proposed TS change is detailed below.
J l
Item 1 Page 3/4 3-2 Delete Operation Condition 4 (Cold Shutdown) in i
Table 3.3.1-1, Items 2.a and 2.c.
Currently, TS Table 3.3.1-1 requires operability (OPCON) 4.
of the Average Power Range Monitors (APRMs) in Operational Condition 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, Tab!e 3.3.1-1 1
Items 2a and 2c are being revised to delete the reference to OPCON 4.
-l Item 2 Page 3/4 4-9 Revise Action b to specify LCOs "b, c and/or d" rather than "b and/or c."
.j l
r o
ADOC OO
,P[ I P
- i i
l Specification 3.4.3.2 Reactor Coolant System - Operational Leakage item
- d. does not currently have an associated action if the limit is exceeded.
Consistent with the Standard Technical Specifications, the existing Action "b" should apply when total leakage is greater than 25 gpm averaged over a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. To correct this discrepancy Action "b" is being revised to include all three LCO Items "b", "c" and "d."
The addition of LCO 3.4.3.2 item d. to the associated Action b corrects an administrative oversight. The revised Action is technically consistent with the Standard Technical Specifications and will not adversely affect safety.
Item 3 page 6-5 Add Footnote
- to the SRO position in Table 6.2.2-1.
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 to Unit 1 in Operational Condition 1, 2, w 3, with Unit 2 in Operational Condition 4, 5 or defueled, an asterisk (*) is being added to the SRO position. The asterisk footnote in Table 6.2.2-1 allows the SR0 to fill tM same position on Unit 2.
This change will result in consistency with Final Safety Analysis Report (FSAR) Table 13.1-2 which is documented as being acceptable in the NRC Safety Evaluation Report (SER) Section 13.1.2.1 for LGS Units 1 and 2, dated August 1983.
The NRC has previously reviewed and found acceptable the shift crew composition allowing a single Senior Reactor Operator to satis' minimum manning for two units with a comon control room when one unit is shutdown. Amendment 18 of the LGS FSAR Table 13.1-2 provided for this shif t complement and the NRC Safety Evaluation Report dated August 1983, section 13.1.2.1, documents its acceptability. This change corrects the TS requirements to be consistent with this approved shift crew composition and will not adversely affect safety.
Item 4 Fages 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 and Table Notations, 3.3.2-2, 3.3.2-3 and
{
4.3.2.1-1, respectively, require revision for the Main Steam j
the existing locations and setpoints, (2) ystem to (1) correct Isolation Valve (MSIV) Leakage Detection S i
clarif l
used in describing instrument locations, and (3)y the nomenclature l
increase the total number of leak detection instrument channels required to be operable.
The Leak Detection System (LDS) monitors leakage from the reactor coolant l
pressure boundary and provides input to isolation instrumentation and
,, j annunciators before predetermined limits are exceeded. The MSIV Leakage j
Detection System (MSIV-LDS) is a subsystem of the LDS and provides i
a.1nunciation and isolation on high ambient temperature in areas near the i
main steam lines outside of primary containment High ambient temperatures l
I l
1 l
l l
in these areas could indicate a main steam line leak. To prevent the excessive loss of reactor coolant and the release of significant amounts of radioactive material from the reactor coolant pressure boundary, selected valves are automatically closed upon the detectinn of high ambient temperatures.
The MSIV-LDS consists of temperature sensors located in two distinct areas of the plant, detecting steam leakage through a rise in temperature.
One area is in the Reactor Enclosure and is referred to as the Outboard MSIV Room. The title for Item 1 in the above listed Tables is being revised to be consistent with the actual area nomenclature. The other is in the main steam line tannel located within the Turbine Enclosure.
The Outboard MSIV Room has four (4) sensors yielding two channels per I
trip system with corresponding setpoints of 192*F. The remaining sensors are located in the Turbine Fnclosure and have a setpoint of 165"F. The total number of sensors is also being increased from 28 to 32 (i.e., 2 channels per trip system for the Outboard MSIV Room and 14 channels per trip system for the Turbine Enclosure).
The changes provide more conservative etpoints for several MSIV-LDS instrument channels and increase the total number required to be operable.
These changes are required to reflect the actual p(lant design and design basis. Because the changes are either editorial i.e., revising the area nomenclature) or represent increased requirements and more conservative l
setpoints, consistent with plant design basis, there is no adverse affect on safety.
Item 5 page 3/4 7-13 Delete "during shutdown" in TS 4.7.4.e Snubber testing may result in rendering equipment and/or systems inoperable which are required to be operable during plant operations. Normally it is preferred tc do this testing during shutdown conditions when only one of the two redundant systems is typically required to be operable.
In the LGS design, with two units sharing common equipment, this leads to an impractical situation of requiring both units to be shutdown for
)
surveillance testing.
In the event this equipment and/or system is j
rendered inoperable for testing while one or both units is operating, its associated TS Actions provide appropriate restrictions and compensatory l
mease es to be taken. These Actions allow required snubber testing to be
{
perfonned during unit operation while providing acceptable limitations j
such that there is no adverse affect on safety.
l I
Specification 4.7.4.e requires that stubbers be demonstrated operable by j
sampling and performing testing "during the first refueling outage and at
.,2 lease once per 18 months during shutdown." Since there are common
- l systems supporting both LGS Unit I and Unit 2, snubber testing may be l
required when only one unit is shutdown and therefore would not meet the 4
strict requirement of "during shutdown" for both units. To allow the q
1 l
l l
1
- 1 i
flexibility to' perform snubber surveillance without requiring both units to be shutdown, surveillance requirement 4.7.4;e is being revised to delete the words "during shutdown."
Item 6 Page 3/4 6-57. Revise the hydrogen recombiner resistance test j
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. The 100 l
megohm value for resistance to ground for b M er elements in the existing specification is incorrect. The manufacturer has concurred that the correct resistance value is 1 megohm. The megohm value reflects the required resistance to ground 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 is being revised to 1 megohm.
3.0 EVALUATION Each of the items discussed previously are evaluated below.
Item 1 In OPCON 4 the Reactor Mode Switch is in the Shutdown position which ensures all control rods remain fully inserted. Under these conditions the Shutdown Nargin requirements of specification 3.1.1 will ensure the reactor will not be critical and therefore the scram function from the APRM system is not required. Even though this psition can be applied to the 4RM scram function, it remains required to be operable in OPCON 4 for defense.n depth. The deldion of OPCON 4 requirements for the APRM system is consistent with Standard Technical Specification requirements.
Based on this discussion, the proposed change will not adversely affect safety and is acceptable.
I, tem 2 The addition of LCO 3.4.3.2 item d. to the associated Action b corrects an administrative oversight. The revised Action is technically consistent with the Standard Technical Specifications and will not adversely affect safety. The proposed change is acceptable.
.It.em 3,,
Tt - ;RC has previously reviewed and found acceptable the shift crew composition allowing a single Senior Reactor Operator to_ satisfy minimum manning for two units with a common control room when one unit is shutdown. Amendment 18 of the 1.GS FSAR Table 13.1-2 provided for this shift complement and the NRC Safety Evaluation Report dated August 1983, section 13.1.2.1, documents its acceptability. This change corrects the TS requirements to be consistent with this approved shift crew composition and will not adversely affect safety. The proposed change is acceptable.
l
- J.
+
+
_5 Item 4 The changes provide more conservative setpoints for several MSIY-LDS instrument channels and-increases the total number required to be operable. These changes are required to reflect the actual lai.t design l
and design basis. Because the changes are either editorial 1.e.,
I revising the area nomenclature) or represent increased requirements and l
more conservative setpoints, consistent with plant design basis, there is no adverse affect on safety. The proposed changes are acceptable.
Item 5 I
Snubber testing may result in rendering equipment and/or systems inoperable which are required to be operable during plant operations.
Normally it is preferred to do this testing during shutdown conditions when only one of the two redundant systems is typically required to be
{
ope.able.
In the LGS design, with two units shcring comon equipment, i
this leads to an impractical situation of requiring both units to be shutdown for surveillance testing.
In the event this equipment and/or j
system is rendered inoperab1> for testing while one or both units is operating, its associated TS Actions provide appropriate restrictions and q
compensatory measures to be taken. These Actin ~ allow required snubber j
testing to be performed during unit operation while providing acceptable limitations such that there is no adverse affect on safety. The proposed change is acceptable.
Item 6 The revised value for testing the hydrogen recombiner heater phase resistance to ground is consistent with the manufacture's specified value. This value provides adequate assurance of heater operability such that this change does not adversely affect safety and is acceptable.
l l
4.0 ENVIRONMENTAL C,0NSIDERATION This amendment involves changes to a requirement with respect to the installation or use of a facility component located within the restricted l
area as defined in IC CFR Part 20 and changes to the surveillance I
requirements. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluenus that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation i
exposure. The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has i
been no public coment on such finding. Accordingly, this amendment meets the eli ibility criteria for categorical exclusion set forth in 10 CFR 51.22(c(9). Pursuant to 10 CFR 51.22(b), no environmental impact staternent nor environmental assessment need be prepared in connection with the issuance of this amendment.
I i
l l
I
e,-
i r
6-
5.0 CONCLUSION
The Cor. mission made a proposed determination that the amendment involves no significant hazards consideration which was published in the Federal Register (54 FR 18954) on May 3,1989 and consulted with the State of Pennsylvania. No public comments were received and the State of Pennsylvania did not have any comments.
The staff 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, and (2) such activities will be conducted in compliance with the Commission's.
regulations and the issuance of this amendment will not be inimical to the common defense and the security nor to the health and safety of the public.
Principal Contributor: Dick Clark Dated: June 20, 1989 W
N mm__.__
... _. _. _.. _ _