ML20135A384

Application for Amends to Licenses NPF-39 & NPF-85,revising TS SR 4.8.1.1.2.e.2 & Supporting TS Bases Section 3/4.8,to Clarify Requirements Associated W/Single Load Rejection Testing of EDGs

ML20135A384
Person / Time
Site:	Limerick
Issue date:	11/25/1996
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20135A387	List: ML20135A384 ML20135A449
References
NUDOCS 9612030200
Download: ML20135A384 (8)

Text

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.- ctruen rupport o.pretm. t 10 CFR 50.90 4 1 7

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i ' PECO NUCLEAR nco m,w c ,  ;

A Unit of PECO Energy p7$$**'d November 25,1996 Docket Nos. 50452 ,

50453 i

License Nos.' NPF-39 NPF-85

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U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Subject. Limerick Generating Station, Units 1 and 2 Tecnnical SpecNications Change Request No. 96-22-0 Gentlemen-L PECO Energy Company is submitting Technical Specifications (TS) Change Request No.96-224, in accordance wkh 10 CFR 50.90, requesting an amendment to the TS (Appendix A) of Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, respectively. This proposed TS change involves revising TS Surveulance Requirement (SR) 4.8.1.1.2.e.2, and supporting TS Bases Section 3/4.8, to clarNy the requirements associated with' single load rejection testing of the Emergency Diesel Generators (EDGs). SpecNically, this prW TS Change involves modWying the wording in TS SR 4.8.1.1.2.e.2 to remove the specific reference to the Residual Heat Removal (RHR) pump motor and ks corresponding kW rating value, and replace k with wording consistent with that specified in the improved TS (i.e.,

NUREG-1433, Revision 1, " Standard Technical Specifications General Electric Plants").

We request that, if approved, the amendments to the LGS, Units 1 and 2 TS be issued prior to January 24,1997, and become effective within 30 days following issuance.

If you have any questions or require additional information, please do not hesitate to contact us.

Very truly yours,

<4s .

G. A. Hunger, Jr.

Director - Licensing <f

'l c0 l Attachments f

! Enclosure

! cc: H. J. Muler, Administrator, Region I, USNRC (w/ attachments, enclosure)

N. S. Perry, USNRC Senior Resident inspector, LGS (w/ attachments, enclosure) j R. R. Janati, Director, PA Bureau of Radiological Protection (w/ attachments, enclosure)

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' COMMONWEALTH OF PENNSYLVANIA  :

as. .

t COUNTY OF CHESTER  :

D. B. Fetters, being first duly sworn, deposes and says:

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That he is Vice President of PECO Energy Company, the Applicant herein; that he has read the

- foregoing Technical Specifications Change Request No. 96-22-0 for Limerick Generating Station, Units 1 and 2, Facility Operating License Nos. NPF-39 and NPF-85, cor.ce,r.ing Emergency Diesel Generator single load l

rejection testing, and knows the contents thereof; and that the statements and matters set forth therein are l true and correct to the best of his knowledge, information, and belief.

I O f, i h JN Vice President  ;

Subscribed and sworn to before me this Od day W

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t i ATTACHMENT 1 i

UMERICK GENERATING STATION UNITS 1 AND 2 l

l Docket Nos. 50-352 1 50-353 1

Ucense Nos. NPF-39 NPF-85 l

l r TECHNICAL SPECIFICATIONS CHANGE REQUEST 1

i No. 96-22-0 l l

1 " Clarification of Single Load Rejection Testing for  !

l Emergency Diesel Generators" I l

Supporting information for Changes - 4 pages i

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Attachment 1 Page 1 of 4 PECO Energy Company, Licensee under Facilky Operating License Nos. NPF-39 and NPF-85 for  :

Limerick Generating Station (LGS), Units 1 and 2, respectively, requests that the Technical Specifications 1 (TS) contained in Appendix A to the Operating Licenses be amended as proposed herein to revise TS  !

Survellance Requirement (SR) 4.8.1.1.2.e.2, and associated TS Bases Section 3/4.8, to clarify the requirements pertaining to single load rejection testing of the Emergency Diesel Generators (EDGs). I SpecificaNy, this proposed TS Change involves revising the wording in TS SR 4.8.1.1.2.e.2 to remove the  !

apecific reference to the Residual Heat Removal (RHR) pump motor and ks corresponding kW rating value, and replace it with wording consistent with that specified in the improved TS (i.e., NUREG-1433, Revision 1, " Standard Technical Specifications General Electric Plants"). The proposed changes to the TS are shown on the attached mark-up of TS Page 3/4 6-4 and Bases Page B 3/4 8-2 for Units 1 and 2, and are contained in Attachment 2.

PECO Energy is requesting that, if approved, the amendments to the TS be issued by January 24,1997, and become effective within 30 days of issuance.

This TS 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 the Procosed Changes The proposed Technical Specifications (TS) changes to the Limerick Generating Station (LGS), Units 1 and 2, TS involve revising TS Survelliance Requirement (SR) 4.8.1.1.2.e.2, and supporting TS Bases Section 3/4.8, to clarify the requirements associated with performing single load rejection testing of the Emergency Diesel Generators (EDGs). Currently, TS SR 4.8.1.1.2.e.2 stipulates that every 24-months each EDG be tested to verify ks capahalty to reject a load of greater than or equal to that of the Residual ,

Heat Removal (RHR) pump motor whle maintaining voltage and frequency within established parameters. The current TS wording reads as follows:

"Every 24 months verify the diesel generator capabuity to reject a load of greater than or equal to that of the RHR Pump Motor (902 Kw) for each diesel generator whNe maintaining voltage at 4285

• 420 volts and frequency at 60 i 1.2 hz and after steady state conditions are reached, voltage is maintained at 4280

• 120 volts."

The proposed TS changes revise TS SR 4.8.1.1.2.e.2 to remove the specific reference made to the RHR pump motor, and replaces it with wording consistent with that delineated in the improved TS (i.e.,

NUREG-1433, Revision 1, " Standard Technical Specifications General Electric Plants") while maintaining the existing voltage and frequency parameters. The proposed TS wording reads as follows:

"Every 24 months verify each diesel generator's capabNity to reject a load of greater than or equal to that of ks single largest post-accident load while maintaining voltage at 4285

• 420 volts and frequency at 60 i 1.2 hz and after steady state conditions are reached, voltage is maintained at 4280 i 120 volts.'

The proposed TS changes also involve revising TS Bases Section 3/4.8 to include a statement clarifying that the single largest post-accident load on each EDG is the RHR pump motor.

i Safety Assessment

{ The proposed TS changes involve revising TS SR 4.8.1.1.2.e.2, and the associated Bases Section 3/4.8, j to clarify the requirements associated with Emergency Diesel Generator (EDG) testing and the rejection

, of the single largest electrice! load. Specifically, the proposed changes wHl revise the TS wording to remove the specific reference to the RHR pump motor and ks associated 992 kW loading value, and replace it with wording consistent with that described in NUREG-1433, Revision 1, " Standard Technical Specifications General Electric Plants.* The proposed TS SR wording wHI require that the

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• Attachment 1 1 Page 2 of 4 i EDGs be capeble of rejecting the single largest post-accident load whue mairmaining the current voltage  !

and frequency parameters, rather than making the specific reference to the RHR pump motor. The applicable TS Bases wIl be revised to provide the 5Fvpi' " darWication in support of the proposed changes The proposed TS changes wul provide greater flexibilty in performing future plant J maintenance actMties (i.e., replacement of a pump motor or addition of a new post-accident load on the 4W emergency buses) at Limerick Generating Station (LGS), Units 1 and 2.

TS SR 3 8.1.g in NUREG-1433, Revision 1, states the following

" Verify each DG rejects a load greater than or equal to ks associated single largest post accident load, and...."

The supporting Bases for this requirement in NUREG-1433, Revision 1, indicates that each EDG is provided with an overspeed trip to prevent damage to the engine Recovery from a transient caused by the loss of a large electrical load could cause the EDG engine to overspeed, which, if excessive, might result in the trip of the engine This SR demonstrates the EDG load response characteristics and capaNiky to reject the single largest post-accident electrical load Without exceeding predetermined voltage and frequency parameters and maintaining a specified margin to the overspeed trip.

The proposed TS changes are consistent with the guidance stipulated in NUREG-1433, Revision 1, as described above. There are.no changes to the existing voltage and frequency parameters specified in TS SR 4.8.1.1.2.e.2 as a resuk of the proposed TS changes. The current requirement to maintain voltage at 4286 420 volts and frequency at 60

• 1.2 hz and steady state condklons at 4280

• 120 volts will be maintained The proposed TS changes do not modify any existing EDG testing methods or testing frequencies The largest post accident electrical load on each 4kV emergency bus is the RHR pump motor. The RHR pump motors are currently used to perform the single load rejection test for the EDGs in order to satisfy the TS requirements The RHR pump motors wBl continue to be used in poiferireng TS SR 4.8.1.1.2.e.2.

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The largest electrical loads connected to the 4kV emergency buses are the dryweN chillers. However, the dryweN chtlers are non-safety related loads and are shed from the 4kV emergency buses upon receipt of a Loss-of-Coolant-Accident (LOCA) or Loss-of-Offsite-Power (LOOP) signal Also, ll the EDGs are the only source of AC power (i.e., under LOOP conditions), then the dryweN chillers cannot be started due to drywell chtied water process conditions. The drywell chilled water circulation pumps, which provide cooling water to the dryweN chluers, cannot operate during LOOP conditions since their electrical supply is provided from a non-safety related power source. With the drywell chNied water pumps not operating, pressure differential and low-flow switches prevent the starting of the dryweN chillers Although the dryweN chulers are the single largest electrical loads connected to the 4kV emergency buses, they are not considered the single largest post-accident load under LOOP conditions when the EDGs are supplying the 4kV emergency buses. The RHR pump motors are the single largest post-ecident loads on the 4kV emergency buses if non-safety related power is restored whRe the diesel generators are supplying the 4kV emergency buses, esisting administrative controls prevent the drywell chillers from being started unti the normal offdte p.mer is restored to the 4kV emergency buses and the EDGs are disconnected from the emergrex:y buses. The existing administrative controls are contained in procedure E 10/20, " Loss of Offske Power," which requires that offsite power be restored and the EDGs shutdown prior to starting the dryweN chRied water system.

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Attachment 1

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l Infonnation Supporting a Finding of No Significant Hazards Conalderation l We have concluded that the proposed changes to Limerick Generating Station (LGS), Unks 1 and 2, Technical Specifications (TS), and associated TS Bases, to clarify the requirements for perforrning i Emergency Diesel Generator (EDG) single load rejection testing de not involve a Significant Hazards  !

l Consideration. In support of this C^: ,,,;,=^': i, an evaluation of ea':h of the three (3) standards set forth in 10 CFR 50.92 is provided below. I

1. The propomad Technical Soecifications (TS) chances do not im alve a sionificant increase in the orobablity or conssouances of an accident oreviously evaluated.

l The proposed TS changes do not make any physical alterations or modifications to the plant l l systems or equipment. The proposed changes do not adversely impact the operation of any )

l plant equipment. The EDGs wNl continue to function as designed to ensure that the necessary ,

i electrical power is provided to essential plant equipment to mitigate the consequences of an .)

l accident, e.g., Loss-of-Offsite-Power (LOOP) and Loss-of-Coolant Accident LOCA) coincident  ;

l with a LOOP (LOCA/ LOOP). The proposed TS changes do not impact the performance testing  ;

l requirements anaelated with the EDGs. The acciderA mitigating capablittles of the diesel  !

l generators and emergency loads wul remain the same.  ;

The pr@nand TS changes are consistent with the guidance stipulated in NUREG-1433, Revision, l

" Standard Technical Specification General Electric Plants," regarding single load rejection testing j of the EDGs. Specifically, the proposed changes involve revising the wording in TS Surveulance  :

Requirement (SR) 4.8.1.1.2.e.2 to remove the specific reference to the Residual Heat Removal l (RHR) pump motor and anaelated kW loading value (902 kW), and replace it with wording indicating that the EDGs must be cap-ble d rejecting the single largest post-accident load, which is consistent with NUREG-1433, Revision 1, guidance. The proposed changes wil also provide addhional flexibuty for future plant maintenance activities.

l Each EDG wNl continue to be tested by rejecting a load of grower than or equal to that of ks  ;

single largest post-accident load while maintaining voltage and frequency within the current specified parameters. The RHR pump motors are currently used in performing the EDG single load rejection testing The RHR pump motors wiu continued to be used in performing the survelNance testing since they are the single largest post-accident electrical load.The i

, consequences of a malfunction of equipment are not affected. Falure of a EDG or its safety-  !

! related loads is bounded by the loss of a Class 1E electrical power division which has been f previously evaluated as diatamad in LGS Updated Final Safety Analysis Report (UFSAR)

Sections 8.1.5.2.e and 8.3.1.1.3.

l Therefore, the proposed TS changes do not involve an increase in the probablity or ,

l consequences of an accident previously evaluated.

2. The oronosed TS chances do not create the nossibility of a new or different kind of accident '

from any accident previously evaluated.

The proposed TS changes do not make any physical alterations or modifications to the plant systems or equipment The proposed changes do not adversely impact the operation of any i plant equipment. The EDGs wul continue to function as designed to provide essential electrical L power to mitigate the consequences of an accident The proposed TS changes are consistent i with the guidance stipulated in NUREG-1433, Revision 1, regarding single load rejection testing i of the EDGs. The proposed changes do not introduce any new accidents or transients The j proposed TS changes will provide additional flexibilty for future maintenance activities. The

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• Attachment 1 Page 4 of 4 prnpanar8 changes do not alter any EDG testing requirements or frequencies. The RHR pump motors are currendy used in performing the EDG single load rejection testing. _ The RHR pump motors wW continue to be used in performing the survellance testing since they are the single largest posteccident electrical load. The operation of the EDGs and their corresponding safety-related electrical loads remain unchanged as a result of the proposed TS changes-Therefore, the proposed TS changes do not create the possibilty of a now or different kind of accident from any arv4riant previously evaluated.

3. The nrannaari TS charw== do not involve a alanificant rartw*ian in a ,T,.ou;,i of anfatv The proposed TS changes do not involve any physical changes to plant systems or equipment The proposed TS changes are consistent with the guidance stipulated in NUREG-1433, Revision 1, " Standard Technical Specification General Electric Plants," regarding single load rejection testing of the EDGs. The proposed TS changes wlN provide addklonel flexibuty for future plant maintenance activities. The EDGs wHl continue to function as designed to provide essential electrical power to mitigate the consequences of an accident. The operation of the EDGs and their corresponding safety-related electricalloads remain unchanged as a result of the proposed TS changes Therefore, the prnpanart TS changes do not involve a signdicant reduction in a margin of safety, information Supporting an Environmental Assessment An Environmental Assessment is ry]t required for the changes proposed by thie TS Change Request wa= the requested changes to the LGS, Units 1 and 2 TS conform to the crkeria for " actions eligible for categorical exclusion," as specified in 10 CFR 51.22(c)(9).' The requested changes wBl have no impact on the environment. The proposed 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 j types or significant increase in the amounts of any ofnuent that may be released offsite. In addition, the l proposed changes do not Irwolve a significant increase in individual or cumulative occupational radiation awpamme Conclusion l The Plant Operations Review Committee and the Nuclear Review Board have reviewed the proposed changes to the LGS, Unks 1 and 2, TS and have concluded that they do not involve an unreviewed safety question, and wRI not endanger the health and safety of the public.

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I ATTACHMENT 2 l l l UMERICK GENERATING STATION l UNITS 1 AND 2 Docket Nos. 50-352 l 50 353 License Nos. NPF-39 NPF-85 TECHNICAL SPECIFICATIONS CHANGE REQUEST No. 96-22-0 l

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