ML20195E752

TS Change Request 91-08-01 to License NPF-39,reflecting Permanently Deactivated Instrument Reference Leg Isolation Valve HV-61-102 in TS Table 3.6.3-1, Primary Containment Isolation Valves & Associated Notations

ML20195E752
Person / Time
Site:	Limerick
Issue date:	06/07/1999
From:	Geoffrey Edwards PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20195E757	List: ML20195E752 ML20195E761
References
NUDOCS 9906140064
Download: ML20195E752 (7)

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=5!b 10 CFR 50.90

=7 PECO NUCLEAR es m eae m c - ev Nuclear Group Headquarters A UNir or PECO Enrecy - 965 Chesterbrook Boulevard

• Wayne, PA 19087-5691 June 7,1999 Docket No. 50-352 License No. NPF-39 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Limerick Generating Station, Unit 1 J Technical Specifications Change Request No. 91-08-01 ]

Drywell Sump / Equipment Drain Tank Instrument Valve HV-61-102 J

Dear Sir / Madam:

PECO Energy Company (PECO Energy) is submitting Technical Specifications (TS)

Change Request No. 91-08-01, in accordance with 10 CFR 50.90, requesting a change to TS (i.e., Appendix A) of Operating License No. NPF-39 for Limerick Generating Station (LGS), Unit 1.

The proposed TS changes will reflect the permanently deactivated instrument reference leg isolation valve HV-61-102 in TS Table 3.6.3-1 " Primary Containment Iso!ation Valves," and its associated notations.

Information Supporting this TS Change Request is contained in Attachment 1 to this letter, and copies of the " marked-up" and " camera-ready" Technical Specifications

. pages are contained in Attachment 2. This information is being submitted under I affirmation,' and the required affidavit is enclosed.

We request that if approved, the changes be issued by December 7,1999, and become effective 'within 30 days of issuance. '

If you have any questions, please do not hesitate to contact us. /

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9906140064 990607 POR ADOCK 05000352 i

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i June 7,1999 Page 2 Very truly yours, bM TM [A 4 G. D. Edwards Director- Licensing Attachments Enclosure cc: H. J. Miller, Administrator, Region I, USNRC (w/ attachment, enclosure)

A. L. Burritt, USNRC Senior Resident inspector, LGS I

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r COMMONWEALTH OF PENNSYLVANIA  :

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J. J. Hagan, being first duly swom, deposes and says: That he is Senior Vce President of PECO Energy Company, the Applicant herein; that he has read the enclosed Technical Specircations Change Request No. 91-08-01 "Drywell Sump / Equipment Drain Tank Instrument Valve HV 102," for Limerick Generating Station, Unit 1, Facility Operating License No. NPF-39, 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.

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Subscribed and sworn to before me this 7 day of 1999.

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AJAsal Notary Public NOTARIAL SEAL GML R. DAMEL g cwat w , %pm c,,,

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1 ATTACHMENT 1 l

LIMERICK GENERATING STATION UNIT 1 DOCKET NO.

50-352 LICENSE NO.

j NPF-39

" Drywell Sump / Equipment Drain Tank Instrument Valve HV-61-102" information Supporting Changes - 3 Pages I

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Docket No. 50-352 June 7,1999 Attachment 1 Page 1 of 3 DISCUSSION AND DESCRIPTION OF THE PROPOSED CHANGES PECO Energy Company (PECO Energy) is requesting a Technical Specifications (TS) change which will reflect the permanent deactivated configuration of the " wet" instrument reference leg isolation valve HV41-102 which originally connected the Drywell Floor and Equipment Drain Tanks to level instruments outside the containment The TS changes affecting TS Table 3.6.3 .

1 " Primary Containment isolation Valves," and its associated notations will reflect the current plant configuration. The level measurement function of the tanks was changed to a " dry" method,- thornby eliminating the need for the " wet" reference leg. The instrument line was cut and capped downstream of isolation valve HV-61-102. Valve HV-61-102 has been locked closed and de-energized to ensure its containment function is retained.

The feric#,ag TS changes are being proposed

. TS Section 3/4.6.3 "Pnmary Containment isolation Valves," Table 3.6.31, Penetrabon Number 230B will be revised to designate the funcbon of valve HV-61-102 as "Deschvated," the maximum isolabon time for valve HV 60102 will be eliminated, and notations 1,23, and 29 will l be .eplaced with a new notabon indicating the permanent configuration of the subject valve. l SAFETY ASSESSMENT Following a plant modification in 1988, valve HV-61-102 was placed in a locked closed position and its motor operator was de-energized to insure that the penetration's containment function would be retained and would not degrade containment integrity. This configuration of the valve and penetration conforms with the containment isolation requirements contained in 10 CFR 50, Appendix A, General Design Criteria 56 and NRC Regulatory Guideline 1.11 " Instrument Lines Penetrating Primary Reactor Containment," allowing manual isolation capability for penetrating lines that connect directly to the containment atmosphere. The configuration of valve HV 102 exceeds the assurances contained in Regulatory Guideline 1.11 since the valve is locked closed, de-energized, and the motor operator cannot be accidentally actuated since it is isolated at the breaker. The modification also meets the applicable requirements for seismic quaisfication and quality assurance, which includes the deactivated line. The leak tight integrity of the valve will continue to be verified by means of the containment integrated Leak Rate Test (ILRT) and surveillance of the containment atmosphere. Valva HV-61-102 is included in the lLRT valve lineup desenbad in LGS plant procedure ST-1-60-490-1. The current configuration of the valve and penetration conforms with the LGS TS Action Statements and the LGS l Updated Final Safety Analysis Report (UFSAR) Section 6.2.4.1. The HV-61-102 valve position has no interaction with any safety related equipment. The permanent change does not impact the design bases function of limiting the release of radioactive material outside the containment.

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Docket No. 50-352 June 7,1999 l Attachment 1 Page 2 of 3 i

INFORMATION SUFPORTING A FINDING OF NO SIGNIFICANT HAZARDS CONSIDERATION We have concluded that the proposed changes to the Limerick Generating Station (LGS), Unit 1, Technical Specifications (TS) which will make changes regarding the permanent configuration of isolation valve HV-61-102 do not involve a Significant Hazards Consideration.

In support of this determination an evaluation of each of the three (3) standards set forth in 10 CFR 50.92 is provided below.

1. The orooosed TS chances do not involve a sianificant increase in the orch tjbiltror consecuences of an accident oreviousiv evaluated.

The closed valve has no effect on the function of the Drywell Sump / Equipment Drain Tanks, other safety related systems, or other containment penetrations. The potential for

- increased releases outside the containment due to breaching of the valve assembly is no greater than that of the isolation design previously evaluated. The valve is locked closed, de-energized, and the motor operator cannot be accidentally actuated in addition, the line is capped downstream of the isolation valve. The valve configuration is passive, where a malfunction is not expected and cannot cause an increase in the probability of a

' malfunction to itself or other safety related equipment.

Therefore, these changes to TS do not involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated in the SAR.

2. The proposed TS chanaes do not create the possibility of a new or different kind of accident from any accident previousiv evaluated.

The abandoned isolation valve conforms to approved isolation configurations, and its l structural integrity has not been degraded by the modified configuration. Since the valve is specifically designed to isolate and is essentially passive during accident conditions, it has .

no activity that could be the initiator of an accident of a different type. The original function !

of valve HV-61-102 was only to provide isolation to the instrument line. Following the '

modification the valve is independent of the function of the Drywell Sump / Equipment Drain Tanks, other safety related systems, and other penetrations. The valve is passive and has no requirements to be operated. Since the valve is devoid of any active funchon,  !

it cannot create a different type of malfunction on itself or other safety related systems.

Therefore, these changes to TS do not create the possibility of a new or different kind of accident from any accident previously evaluated.

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3. The oronosed TS chances do not involve a sianificant reduction in a marain of safety.

Valve HV-61-102 in its proposed permanent configuration meets the margin of safety desenbod in the TS Bases 3/4.6.3 since it is kept closed under all operational conditions I

. and will not be under the constraint of TS closing times in order to maintain releases within specifications. The proposed changes to TS do not impact any safety assumptions, or f

< potentially reduce any margin of safety as described in the TS bases. The proposed changes have no impact on any safety analysis assumptions. I Therefore, the proposed TS changes do not involve a significant reduction in a margin of safety.-

INFORMATION SUPPORTING AN ENVIRONMENTAL ASSESSMENT An Environmental Assessment is not required for the Technical Specifications changes proposed by this TS Change Request because the requested changes to the Limerick Generating Station, Unit 1, TS conform to the criteria for " actions eligible for categoncal exclusion," as specified in 10CFR51.22(c)(9). The requested changes will have no impact on the environment. The proposed TS changes do not involve a Significant Hazards .

Consideration as discussed in the preceding section. The proposed changes do not involve a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, in addition, the proposed TS changes do 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 Limerick Generating Station, Unit 1, Technical Specifications, and have concluded that they do not involve an unreviewed safety question, they do not involve a Significant Hazards Consideration, and they will not endanger the health and safety of the public.