ML20195G042

TS Change Request 98-09-0 for Licenses NPF-39 & NPF-85, Revising TS Section 3/4.4.3, RCS Leakage,Leakage Detection Systems, by Clarifying Action Statement Re Inoperative Reactor Coolant Leakage Detection Systems

ML20195G042
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
ML20195G047	List: ML20195G042 ML20195G048
References
NUDOCS 9906150198
Download: ML20195G042 (8)

Text

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A 10 CFR 50.90 PECO NUCLEAR es w eoe,9v comnen, Nuclear Group Headquarters A UMr of PECO ENERCy 965 Chesterbrook Boulevard Wayne, PA 19087-5691 l

June 7,1999 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 1

U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

Subject:

Limerick Generating Station Units 1 and 2 Technical Specifications Change Request No. 98-09-0

Dear Sir / Madam:

PECO Energy Company is submitting Technical Specifications (TS) Change Request No. 98 0, in accordance with 10 CFR 50.90, requesting an amendment to the TS (Appendix A) of Operating License Nos. NPF-39 and NPF-85 for Limorick Generating Station (LGS), Units 1 and

2. This proposed change will revise LGS Units 1 and 2 TS Section 3/4.4.3,

• Reactor Coolant System Leakage, Leakage Detection Systems,' to clarify the action statement conceming inoperative reactor coolant leakage detection systems, information supporting this TS Change j/jf  !

Request is contained in Attachment 1 to this letter, and the proposed TS pages (including /

marked-up pages) showing the proposed changes to the LGS Units 1 and 2 TS are contained in Attachment 2. This information is being submitted under affirmation, and the required affidavit is enclosed.

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

Very truly yours,

$Y lFaz Garrett D. Edwards Director- Licensing

Enclosures:

Attachments; Affidavit oc: (w/ enc!) H. J. Miller, Administrator, Region 1, USNRC A. L. Burritt, USNRC Senior Resident inspector, LGS R. R. Janati, PA Bureau of Radiological Protection t[

- P _DP. ,_

M 05000352 F

PDR _

June 7,1999 Page 2 i

bec: G. R. Rainey - 63C-3 (w/o encl)

J. J. Hagan - 62C-3 -

J. D. von Suskil- LGS, SMB1 1 *'

M. P. Gallagher - LGS, GMLS-1

• J. P. Grimes - LGS, SSB3-1 "

T. Neckowicz - 638-3 "

l K. P. Bersticker - LGS, SSB2-4 "

D. P. Holker/MJT - 62A-1 (w/ encl)

B. D. Dolhanczyk - LGS, SSB2-4

• PA DEP BRP inspector - LGS, SSB2-4

• Commitment Coordinator- 62A-1 Correspondence Control Desk- 618-5

• DAC - 618-5

• l 4

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COMMONWEALTH OF PENNSYLVANIA :

1

ss. j COUNTY OF CHESTER  :

{

J. J. Hagan, being first duly swom, deposes and says:

I That he is Senior Vice President of PECO Energy Company, the Applicant herein; that he has read the foregoing Application for Amendment of Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station Units 1 and 2, concerning Technical Specifications I j

}

Change Request No. 98-09-0, " Reactor Coolant System Leakage, Leakage Detection Systems," l l

and knows the contents thereof; and that the statements and matters set forth therein are true  !

l and correct to the best of his knowledge, information and belief.

]

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, W= -

p rV P'esident Subscribed and sworn to before me this day of' 1999.

l Notary Public

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NOTARIAL SEAL Gall R DAN 8F1, Noewy %

c"Y of ~ , - Phm. cowny W-  % Apos.aco2

ATTACHMENT 1 LIMERICK GENERATING STATION UNITS 1 and 2 J

DOCKET NOS. 50 352 50-353 LICENSE NOS. NPF-39 NPF-85 TECHNICAL SPECIFICATIONS CHANGE REQUEST NO. 9849-0

" REACTOR COOLANT SYSTEM LEAKAGE, LEAKAGE DETECTION SYSTEMS" i

Supporting Information for Change - 4 Pages  !

I i

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4-Juns 7,1999 Docket Nos. 50-352 50-353 Attachment 1 IntrMu@n PECO Energy Company, Licensee under Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, requests that the Technical Specifications

-(TS) contained in Appendix A to the Operating Licenses be amended to revise TS Section 3/4.4.3 and its associated TS Bases to reflect changes to refine and clarify the action statement concoming inoperative reactor coolant leakage detection systems. The proposed changes to

- the LGS Units 1 and 2 TS are indicated by markups on TS page 3/4 4-8 and TS Bases page B 3/4 4-3 (Attachment 2). This License Change Application provides a discussion and description of the proposed TS changes, a safety assessment of the proposed TS changes, information -

supporting a finding of No Significant Hazards Consideration and information supporting an 1 Environmental Assessment.

Discussion and Descriotion of the Proposed Chances The proposed Technical Specifications (TS) Change Request involves the change of LGS, Units 1 and 2, TS Section 3/4.4.3 and its associated TS Bases to refine and clarify the action statement cormeming inoperative reactor coolant leakage detection systems.

LGS has for  ; diverse systems which are credited by TS for the purpose of reactor coolant l system leaka, s detection. These systems are: Primary Containment Atmospheric Gaseous - l Radioactivit, lonitoring System; Drywell Floor Drain Sump Flow Monitoring System; Drywell ]

Unit Coolers Londensate Flow Rate Monitoring System; and Primary Containment Pressure  !

and Temperature Monitoring System. The wording of the current TS Action Statement is  !

l ambiguous and may' lead to misinterpretation. The proposed revision will clarify the action-  !

statement conceming inoperative reactor coolant leakage detection systems and is consistent

- with Improved Standard Technical Specifications (i.e., NUREG-1433, Rev.1).  ;

The significant TS Action Statement changes to Section 3/4.4.3 are as follows:

1. Delete the Limiting Condition for Operation (LCO) requirement on the Drywell Equipment Drain Tank Flow Monitoring System since only the Drywell Floor Drain Sump Flow Monitoring System is used to provide indication of unidentified reactor coolant system leakage.- The Equipment Drain Tank portion does not function to indicate potential Reactor Coolant System (RCS) unidentified leakage. However, the Equipment Drain Tank Flow Monitoring System is still used to measure identified leakage and total leakage underTech Spec Section 3/4.4.3.2. This change in system scope is consistent with improved Standard Technical Specifications.

2. Delete the 30 day LCO to restore the Drywell Unit Coolers Condensate Flow Rate Monitoring System. The surveillance requirement frequency to perform a channel check of

. primary containment atmosphere gaseous monitoring system is increased from 12 to every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

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~i. I Juns 7,1999 Docket Nos. 50-352 50-353 Attachment 1

3. Periodic primary containment grab samples will be required every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when there is a loss of the Primary Containment Atmosphere Gaseous Radioactivity Monitoring System.

Current TS requirements require periodic grab samples every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for loss of any RCS Leakage Detection System except the Drywell Floor Drain Sump and Equipment Drain Tank Monitoring System.

4. Establish a 30 day LCO condition when both the Drywell Unit Coolers Condensate Flow Rate Monitoring and Primary Containment Atmosphere Gaseous Radioactivity Monitoring Systems are inoperable. Under current TS, this condition would require a shutdown to Hot Shutdown in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Cold Shutdown within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Since LGS also monitors for evidence of RCS leakage using the Primary Containment Pressure and Temperature Monitoring System, the proposed LGS Technical Specification LCO condition is more conservative than the improved Standard Technical Specification associated condition.

5. Increase the monitoring frequency of drywell unit cooler condensate flow rate from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> during periods when the Drywell Floor Drain Sump Flow Monitoring System is inoperable.

6. Since the Primary Containment Pressure and Temperature Monitoring System is associated with other TS sections, a note was added to state that all other Technical Specification Limiting Conditions for Operation and Surveillance Requirements involving this system still apply. Specifically, the 30 day LCO period only applies with respect to RCS Leakage Detection Requirements and does not supersede or apply to other TS functional requirements.

7. The RCS leakage detection instrumentation surveillance requirements Section (4.4.3.1) was reformatted with each specific surveillance requirement assigned to the type of surveillance test performed rather than by RCS ieakage detection system. The type and standard frequencies of each proposed surveillance requirement remain unchanged from current requirements.

l Safety Assessment The proposed TS changes will revise LGS Units 1 and 2, TS Section 3/4.4.3 and its associated TS Bases to provide clarified directions and surveillance requirements to ensure RCS Leakage i Detection Systems will detect RCS leakage and provide adequate assurance that RCS pressure boundary degradation will be detected in a timely manner. This change does not l make any changes to the design or operational characteristics of any RCS Leakage Detection System discussed in the Updated FinaI Safety Analysis Report (UFSAR). All RCS Leakage Detection Systems will continue to function as described in the UFSAR with no change in associated design basis requirements, i

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1 Juns 7,1999 Docket Nos. 50-352 50-353 Attachment 1 Information Sunoortina e. Findina of No Sianificant Hazards Consideration We have concluded that the changes to the Limerick Generating Station (LGS) Units 1 and 2 Technical Specifications (TS), which will revise TS Section 3/4.4.3, " Reactor Ooolant System Leakage, Leakage Detection Systema," and its associated TS Bases to clarify the action statement concoming inoperative reactor coolant leakage detection systems, 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 chanaes do not involve a sionificant increase in the probability or conseauences of an accident previousiv evaluated.

The proposed TS changes directly establish the minimum acceptable level of Reactor Coolant System (RCS) leakage detection Instrumentation required to support plant power operations. The level of RCS leakage detection capability inherent with the proposed TS change will continuo to provide acceptable early waming detection of potential RCS pressure boundary degradation as required under 10 CFR 50.36 (c)(2)(ii) (A) Criterion 1.

Therefore, the proposed TS changes do not involve an increase in the probability or consequences of an accident previously evaluated.

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

The proposed TS changes only affect systems associated with the detection of accidents

. Involving degradation of the RCS pressure boundary. The proposed TS changes do not

. Involve any physical changes to plant structures, systems, or components. The RCS Leakage Detection Systems will continue to function as designed in all modes of operation.

No new accident type is created as a result of the proposed changes. No new failure mode for any equipment is created. The changes are consistent with the guidance provided in NUREG-1433, Revision 1, pertaining to RCS Leakage Detection.

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

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

The TS Limiting Conditions for Operation (LCO) specify for systems and equipment important to safety, the minimum level of operability required to permit continued power operation. The proposed TS changes revise this minimum level of operability by permitting long term plant operation with the removal of the Drywell Unit Coolers Condensate Flow Rate Monitoring System from service. Currently, this condition would permit the plant to 3

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Juns 7,1999 Docket Nos. 50-352 l 50-353 Attachment 1 continue to operate for up to 30 days. This change is not a reduction in the margin of safety since:

The proposed Technical Specification LCO change for RCS Leakage Detection Systems maintains four (4) diverse methods of detecting RCS leakage and permits continuous operation with the Drywell Unit Coolers Condensate Flow Rate Monitors out of service provided that more frequent surveillance checks are provided for the containment atmosphere monitoring system. The proposed TS change institutes the additional surveillance requirements.

• The LGS reactor coolant pressure boundary was designed to ASME Class 1, Seismic Category I design criteria with no special dispensation which would warrant such additional RCS leakage detection capability or more stringent LCO criteria than those generically approved under the improved Standard Technical Specifications. ,

e Review of the TS Bases Section and UFSAR identifiec' no discussions regarding rnargin 4 of safety for the RCS Leakage Detection Systems, which would be reduced by the proposed Technical Specification LCO change. It is further demonstrated that an acceptable margin of safety exists based on the generic regulatory approval of the Improved Standard Technical Specifications which will remain bounded by the proposed LGS TS changes.

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Therefore, the proposed TS changes do not involve a significant reduction in the margin of safety.

4 Information Suo6ortino an Environmental Assessm9nt An Environmental Assessment is not required for the changes proposed by this TS Change Request because the requested changes to the Limerick Generating Station (LGS), Units 1 and 2 TS conform to the criteria for " actions eligible for categorical exclusion" as specified in 10 CFR 51.22 (c)(9). The requested changes will have no impact on the environment. The proposed changes do not involve a significant hazards consideration as discussed in the preceding l section. The proposed changes do not involve a significant change in the types, or a significant j increase in the amounts, of any effluents that may be released Offsite. In addition, the i proposed changes do not involve a significant increase in individual or cumulative occupational ,

radiation exposure. i l

Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes to the Limerick Generating Station (LGS), Units 1 and 2 TS and have I concluded that they do not involve an unreviewed safety question, and will not endanger the health and safety of the public, j

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