ML20011F654

Application for Amends to Licenses NPF-39 & NPF-85, Consisting of Tech Spec Change Request 89-13,removing cycle- Specific Parameter Limits from Tech Specs Per Guidance Contained in Generic Ltr 88-16

ML20011F654
Person / Time
Site:	Limerick
Issue date:	02/23/1990
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20011F655	List: ML20011F654 ML20011F657
References
GL-88-16, NUDOCS 9003070088
Download: ML20011F654 (10)

Text

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PHILADELPHIA ELECTRIC COMPANY- ,

NUCLEAR GROUP HEADQUARTERS ,

955 65 CHESTERBROOK BLVD.

. WAYNE, PA 19087 5691 (ris) e40 sooo-February 23, 1990 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85

, U'.S. Nuclear. Regulatory Commission Attn: Document Control Desk Washington, DC 20555-

SUBJECT:

Limerick Generating Station, Units 1 and 2 4

Technical Specifications Change Request '

Dear Sir:

Philadelphia Electric Company hereby submits Technical Specifications. >

. Change Request No. 89-13, in accordance with 10 CFR 50.90, requesting an amendment to the Technical Specifications (TS) (Appendix A) of Operating License Nos. NPF-39:and NPF-85. Information supporting this Change Request is contained in~ Attachment.1Lto this letter, and the proposed replacement pages are contained in Attachment 2.

This submittal requests changes to remove cycle specific parameter-

-limits from the TS in accordance with guidance provided in Generic Letter 88-16

" Removal-of Cycle-Specific Parameter Limits from Technical Specifications."

If you have any questions regarding this matter, please contact us.

Sincerely yours.

A.

'll24, G. A. Hunger, Jr.

Director TT Licensing Section

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W. T. Russell, Administrator, Region I USNRC T. J. Kenny, USNRC Senior Resident Inspector, LGS LT. M. Gerusky, Director, PA Bureau of Radiological Protection y

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t ATTACHMENT 1 LIMERICK GENERATING STATION UNITS I and 2

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Docket Hos. 50-352 50-353 License Nos. NPF-39 NPF-85 TECHNICAL SPECIFICATIONS CHANGE REQUEST

" Removal of Cycle Specific Parameter Limits" Supporting Information for Chcnges - 10 pages

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• 3-Docket Nos. 50-352 50-353' i License Nos. NPf-39 j HPF-85 -

H Philadelphia Electric Company, Licensee under Facility Operating Licenses NPF-39 and NPT-85 for Limerick Generating Station (LGS), Unit 1 and l

' Unit 2, respectively, hereby requests that the Technical-Specifications (TS) contained in Appendix A of the Operating Licenses be amended as proposed herein. l to remove cycle-specific parameter limits in accordance with NRC Generic Letter t (GL) 88-16 " Removal of Cycle Specific Parameter Limits from Technical-

' Specifications."

Philadelphia Electric Company (PECo) requests the changes proposed herein to'be effective upon issuance of the Amendments.

This Change Request 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 Environmental Assessment.

. Discussion and Description of Proposed Changes ..

GL 88-16 discusses the fact that License Amendments are required each fuel cycle to update the value of cycle-specific parameter limits in TS.

Further, the methodology used'for determining cycle-specific parameter limits is documented in a NRC approved Topical Report or in a plant specific submittal.

,As a consequence, NRC review of proposed changes to TS for these limits is primarily limited to confirmation that the updated limits are calculated using an NRC-approved methodology and are consistent with all applicable limits of the safety analysis. Therefore, the processing of changes to TS that are developed using a NRC approved methodology and are consistant with applicable limits of

Docket Nos. 50-352 50-353

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License Hos. NPF-39 NPF-85 -

l the safety analysis is an unnecessary burden on licensee and NRC resources. To simplify this process, the NRC provided guidance to all licensees in GL 88-16 which provides an alternative to retaining the values of cycle-specific parameters in the TS. This alternative consists of three separate actions to modify the TSi .(1)the-additionofthedefinitionof named formal report that includes the values of cycle-specific parameter limits that have been established using a NRC-approved methodology and consistent with all applicable limitsofthesafetyanalysis,(2)theadditionofanadministrativereporting requirement to submit the formal report on cycle-specific parameter limits to the NRC for information, and (3) the modification of individual TS to note that cycle-specific parameters shall be maintained within the limits provided in the defined formal report.

We are proposing changes to the TS which are consistent with the

. guidance of GL 88-16, detailed above. Although all proposed changes are consistent with the guidance of GL 88-16, the proposed changes for Unit 1 and Unit 2 TS differ due to unit-specific TS differences. For example, Unit 2

-currently has no lattice-specific Average Planar Linear lleat Generation Rate (APLilGR) . limits. Therefore, no changes to the Unit 2 TS are necessary in this specific area. Ilowever, Unit i TS Figures 3.2.1-6 thru 3.2.1-8, which contain lattice-specific APLilGR limits, are required to be removed. Accordingly, the removal of these figures from Unit 1 TS must also be reflected in the TS Index and results in the elimination of Index page "via."

The description of changes which follows applies to both Units 1 and 2

.with unit-specific exceptions noted. All changes are reflected in the unit specific TS pages contained in Attachment 2. l

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. Docket Hos. _50-352 50-353-

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License Nos.~NPF-39: i NPF-85 .

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The following changes to the TS are proposed.

1-(1) Insert definition 1.7a, " Core Operating Limits Report (COLR)," into Section 1.0, " Definitions."

(2) Revise the Index.

a.- Remove figure references currently in Sections 3/4.2.1, " Average: I Planar Linear Heat Generation Rate," and 3/4.2.3, " Minimum- ,

Critical Power Ratio (MCPR)," for figures which are being U 1

relocated to the COLR. Insert a note on Index pages v and vi which describes the TS pages which have information intentionally.

omitted and references a note on a designated page. This note-lets the reader know that information has been intentionally omitted and also gives a reference where the reader can find further information.

b. Move information (which is not being deleted) on the affected .

Index pages vi and via (for Unit 1 only) to reflect deletion of the figure references.

c. Eliminate page via (for Unit 1 only), since it is no longer required to accommodate references to figures which are being deleted.

d. Insert " Core Operating Limits Report," into the " Administrative '

Controls Section," 6.9, " Reporting Requirements" under Section 6.9.1, "Routina Reports."

(3) Revise Section 3/4.2, " Power Distribution Limits."

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i Docket Nos, 50-352 50-353 l License Nos. NPF-39 - t NPF-85 (a) Revise Section 3/4.2.1, " Average Planar Linear Heat Generation Rate," by deleting the phrase "which have been approved" and inserting in its place the the phrase "detemined by approved '

methodology." Remove all figure references'and add a reference to-the COLR in Section 3/4.2.1 for the limiting values. Remove Figures 3.2.1-1 thru 3.2.1-5, and for' Unit 1 only, also remove Figures 3.2.1-6 thru 3.2.1-8. Insert a note on page 3/4 2-2

.. describing which pages have been removed and that the information previously on pages 3/4 2-2 thru 2-6a (thru 3/4 2-6c for Unit 1) I has been relocated to the COLR. '

(b) Revise Section 3/4.2.3, " Minimum Critical Power Ratio," to remove Figures 3.2.3-la, 3.2.3-lb and Figure 3.2.3-2. Remove figures L .3.2.3-1c and 3.2.3-1d from the Unit 1 TS only. Remove Table L

l 3.2.3-1 from the Unit 2 TS only and note that the page has been intentionally left blank. Remove all figure and table references ,

and add a reference to the COLR for the limiting values and the l'

Kr curve. Insert a note on page 3/4 2-10 describing which pages have been removed and that the information previously on

-pages 3/4 2-10 thru 3/4 2-11 has been relocated to the COLR.

(c) Revise Section 3/4.2.4, " Linear Heat Generation Rate (LHGR)," to '

reference the COLR for limiting values. ,

(d) Revise Section 3/4.3.6, " Rod Block Monitor (RBM)," Table 3.3.6-2, Trip Function 1.a (RBM upscale) by replacing the RBM high flow l

( clamped setpoint of 106 with the constant "H." Revise all other i cycle specific constants to functions of "N" (e.g., change 109 to 1

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=, v Docket Nos. 50-352 50-353

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NPF-85 ,

(N+3)). The value of "N" is a cycle specific limit and is therefore referenced in the COLR.

-(4) Modify Bases 3/4.2.1 and 3/4.2.3 to reference the COLR.

(5) Insert Sections 6.9.1.9 thru 6.9.1.12 into the " Administration .

Controls" Section 6.9.1, " Routine Reports." These Sections specify the information to'be included in the COLR and the requirement to submit the COLR to the NRC.

(6) Move Section 6.9.2, "Special Reports," from page 6-18 to 6-18a to accommodate the addition of Sections 6.9.1.9 thru 6.9.1.12.

Safety Assessment l

[ We have conformed to the guidance of GL 88-16 in preparing this Change Request. As GL 88-16 recommends, we are proposing the following changes to the .

TS: (1) the addition of the definition of a named formal report that includes the valu'es of cycle-specific parameter limits that have been established using a l

l NRC-approved methodology and is consistent with all applicable limits of the safety analysis, (2) the addition of an administrative reporting requirement to submit the formal report on cycle-specific parameter limits to the NRC for

.information, and (3) the modification of individual TS to note that cycle-specific parameter limits shall be maintained within the limits provided in the L

d'efined formal report. The proposed TS changes will not impact safety because the TS will continue to require that the reactor be operated within limits which are established using NRC-approved methodology and are consistent with applicable limits of the Final Safety Analysis Report (FSAR). In addition, the

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Docket-Nos. 50-352-

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NPF-85 i

-requirement to: submit,the COLR will allow the NRC.to continue to trend the

-values of these. limits without the need for prior NRC review and approval of -

these limits. ,

i Information Supporting a Finding of No'Significant Hazards Consideration We have concluded that'the proposed changes to the LGS TS, which remove Tcycle specific parameter limits, do not constitute a Significant Hazards 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) LThe proposed changes do not involve a significant increase in the probability or consequences of an accident'previously evaluated.

The proposed TS changes do not. alter the requirement that the plant be operated within the limits of the cycle-specific parameter limits,: nor- .

do they alter the required innediate actions that must be taken when these limits are not met. These proposed changes will have no effect on plant operations or equipment reliability. No hardware changes are required to any system. Since the parameter limits will continue to be calculated by NRC-approved methodology, and all accidents will remain bounded by the analyses described in the FSAR, the proposed changes do not involve a significant increase in the probability or consequences

-of-any accident-previously evaluated.

2) The proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

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Docket Nos. 50-352 50-353 License Nos. NPF ..

NPF-85 i

No hardware modifications are required to implement this proposed change. The plant will continue to be operated within limits established using NRC-approved methodology and the plant remains bounded by the assumptions and analysis of the FSAR. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3) The proposed changes do not involve a significant reduction in a margin of safety.

The margin of safety relative to each cycle-specific parameter limit is determined by the method of analysis for establishing each limit.

These methods are subject to prior approval by the NRC to ensure that the bases for each applicable TS section will be met by the analysis.

This proposed change requires that the methodology used to establish these. limits be approved by the NRC prior to use and that the methods

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are listed in the Administrative Controls Section of the TS. Since the methodology will maintain the cycle-specific parameter limits within the margin of safety defined in the TS Bases, this change will have no effect on any margin of safety as analyzed in the FSAR or as defined in the TS Bases.

Information Supporting an Environment Assessment 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  :

51.22(c)(9).. The requested changes will have no impact on the environment.

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NPF-85 t

-This Change-Request does not involve a significant hazards' consideration as discussed in the preceding section. This Change Request does 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.

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Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes to the TS and determined that they do not involve an Unreviewed Safety Question and will not endanger the health and-safety of the public.

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