ML20065T482

Application for Amends to Licenses NPF-39 & NPF-85, Consisting of Tech Spec Change Request 90-021-0,revising Tech Spec Section 4.0.5 to Indicate That Inservice Insp Program Conforms W/Generic Ltr 88-01 & Section 3.4.3.2

ML20065T482
Person / Time
Site:	Limerick
Issue date:	12/21/1990
From:	Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20065T484	List: ML20065T482 ML20065T495
References
GL-88-01, NUDOCS 9012280146
Download: ML20065T482 (7)

Text

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10 CIR 50.90 PHILADELPHIA ELECTRIC COMPANY NUCLEAR GROUP HEADQUARTERS 955 65 CHESTERBROOK BLVD.

December 21, 1000 WAYNE, PA 19087 5691 (ats) eso.sooo Docket Iva. 50-352 50-353 License lios. NPF-39

!(PF-85 U. S.11uc1 car Regulatory Camntission KPIN: Dacunent Control Desk Washirgton, DC 20555 SUIUECT: Limerick Generatify Station, Units 1 n!d 2 Technical Spocifications carne Request Centlemen:

Philadelphia Electric Company is submittity Technical Specifications Charge Request No. 90-21-0, in acconlance with 10 CIR 50.90, requestiin an amerdnent to the Technical Specifications ('IS) (Apperdix A) of Operatirg License Hos. NPF-39 ard NPF-85. Information supportirg this Otarge Request is contained in Attachment 1 to this letter, ard the prorocod replacement pages are containcd in Attachment 2.

'1his subnittal req ests charges to: 1) 'IS Section 4.0.5 to irdicate Inservice Inspection Program conformance with NRC staff positions identified in NRC Generic Intter (GL) 88-01, "NRC Position on IGSOC in IMR Austenitic Stainless Steel Pipiry," 2) TS Section 3.4.3.2 to add a limit of 2 gpn incIvase in UNIDD(FIFIED IIAKAGE over a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, 3) 'IS Section 4.4.3.2 to increase the frequency of nonitoring drywell floor drain sump ard drywell equipment drain tank flos rate to once every eight (8) hours, ard 4) the pertinent 'Is Bases. 'Ihose changes are beirg requested as cmmitted in our June 8,1990 response to NRC GL 88-01.

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

Very truly yours, ,

G. J. Iki k h hbf./$L Manager, Licensity

, Nuclear Engineerirg ard Services GHS/eas:3006 Attachments oc: T. T. !brtin, Administrator, Region I, USNRC T. J. Kenny, USNRC Senior Resident Inspector, IGS T. M. Gentsky, Director, PA Dureau of Radiological Protcction l

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CmONhTRml OF PDulSYLVANIA :

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COUmY OF CilESTER  :

D. R. Helwig, boirs first duly sworn, deposes ard says:

That he is Vice President of lhiladelphia Electric Campany; the Applicant herein; that he has read the forogoing A; plication for Amerdment of Facility Operating License Nos. NPF-39 ard NPF-85 (Technical Specifications Chargo Roquest No. 90-21-0) to conform with the guidanco provided in NRC Generic I.etter 88-01, "NRC Position on IGSCC in BGi Austentic Stainless Stool Piping," the contents thereof; ard that the statomonts and ::atters set forth therein are true ard correct to the tut of his kncwledge, information and belief.

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Vice President Subscribed ard sworn to before me this A l#day of (4u,4,%,1990.

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ATTAQlME2TT 1 12MERICK GDIER1d'I!G ErrATIQi Units 1 and 2 Docket Nos. 50-352 50-35' Licenso Nos. NPF-39 NPF-85 TEQWICAL SPECIFICATIOG OWGE REQUEST "Inservico Inspection Progrant/ Reactor Coolant Syster UNIDDirIFIED IEM7E" Supporting Information f'or Qianges - 5 pages

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! Thiladelphia Electric Cagnny (PECo), Licensee under Facility i

Operatirg Licenses IIPF-39 ard IIPF-85 for Limerick Generating Station (LGS),

Units 1 and 2, respectively, requests that the Teclmical Specifications (IS) contained in Appendix A of the Operating Licenses be aranded as

proposed herein to reflect conformnce with the guidance provided in IEC Generic Intter (GL) 88-01, "lmC Position on IGSCC in B.R Austenitic Stainless Steel Piping," as comitted in our response to imC GL 88-01 dated June 8,1990. The proposed TS changes are irdicated by a vertical bar in the mrgin of TS pages 3/4 0-3, 3/4 4-9, and 3/4 4-10, and fuses pages B 3/4 0-5, B 3/4 4-3, B 3/4 4-4, and B 3/4 4-6 for IES, Unit 1, and TS pages xix (INDEX), 3/4 0-3, 3/4 4-9, and 3/4 4-10, and Bases pages B 3/4 0-5, D 3/4 4-3, B 3/4 4-3a, and B ;/4 4-6 for IES, Unit 2, and are contained in Attachment 2.

We request the changes proposed herein be effective 30 days fram the date of issuance of the Amerdnents.

7his Omnge Request provides a discussion and description of the proposed 75 changes, a safety assessment of the proposed TS changes, infomation supporting a finding of No Significant Hazattis Consideration, and informtion supporting an Environmental Assessment.

pJmission and Descrintion of the Proponed chanaes

!RC GL 88-01, iss. icd January 25, 1988, provided guidance in the form of NRC positions regarding Intergranular Stress Corrosion Cracking (IGSCC) problers in Boiling Water Reactor (BE) piping made of austenitic stainless steel that is four (4) inches or larger in nominal diameter and contains reactor coolant at a temperature above 200 degrees F during reactor power operation regardless of ASME Code classification. 7hese ime positions were the result of research and development sponsomd by the BG Owners Group, along with other related work by vendors, consulting fims, and confirmtory researt:h sponsored by the IRC. lEC GL 88-01 requested licensees of operating SGs and holders of construction pemits for Dms to l provide information regarding conformance with the IRC positions. Two of the items which the GL requested licensees to address were: 1) a TS change to include a statement in the 75 section on Inservice Inspection (ISI) that the ISI Program for piping covered by the scope of IRC GL 88-01 will be in confomance with the imC positions on schedule, methods ard personnel, and sample expansion included in the GL, and 2) confitution of the licensees plans to ensure that the TS related to leakage detection will be in conformance with the NRC positions on leak detection included in the GL.

The IRC position on leakage detection specifically stated that unidentified leakage be limited to an increase of 2 gpm over a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, and that leakage be monitored every four (4) hours.

For ISS, Units 1 and 2, we responded to imC GL 88-01 by letters dated August 2, 1988, April 28, 1989, May 30, 1989, and September 11, 1989. Our msponses took exception to requesting any TS changes on the basis that:

1) the ISI section of TS will be relocated to the Administrative controls section of TS under the TS Improvement Program, and the imC staff positions on IGSCC were incorporated as augmented inspection require.monts in the ISI Program, and 2) the existing TS for leak detection are adequate to meet the intent of the NRC staff positions on leakage detection included in the GL.

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. Page 3 Imc letter and associated Safety Evaluation dated March 6, 1990 provided the results of the imC's review of our sulnittals responding to imC GL 88-01. The imC found our responses to IRC GL 88-01 acceptable with some exceptions, which included a rejection of our exceptions to requesting any TS charges rogarding the ISI statement and Icakage detection, and requested that we propoco the appropriate charrJes to the TS for IGS, Units 1 and 2.

Additionally, the Marrh 6,19901RC Safety Evaluation revised the lmC position on monitoring of leakage fram onco every four (4) hours (as stated in GL 69-01) to once every cight (8) hours. Dy letter dated June 8,1990, we addressed the Imc exceptions identified in the Marrh 6, 1990 1RC Safety Evaluation including a commitment to propose charges to the IGS, Units 1 and 2 TS to conform with the guidance in GL 88-01 concerning the statement on ISI, the limit of 2 gpn increase in unidentified leakage over a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, ard the imC position that leakago be tonitored overy eight hours.

Dy letter and associated Safety Evaluation dated October 22, 1990, the IEC found our June 8,1990 response acceptable with ono exception which is unrelated to this Chango Request.

Implementing the guidance of lac GL 88-01 at IES, Units 1 and 2 will involve the proposed TS charges described below. All changes are reflected in the unit specific TS pages contained in Attachment 2.

1. Md new Surveillance Requirement 4.0.5.f to read "Ihe Inservice Inspection (ISI) Program for piping identified in IRC Generic Ictter 88-01 shall be perfomed in accordance with the staff positions on schedule, methods and personnel, and sample c>qnnsion included in the Generic Ictter. D 7. ails for implementation of these requirements are included as augmented inspection requirements in the ISI Program." to require ISI Program conformnce with the guidance provided in Imc GL 88-01.

Mditionally, a revision to Bases Section 4.0.5 is being proposed to irxdicate that such conform nce is as approved in imC Safety Evaluations dated March 6, 1990 and October 22, 1990.

2. Md new Limiting Condition fo" Operation 3.4.3.2.f to read "2 gpn increase in UNIDEtTTIFIED IEAl%GE over a 24-hour period." and corresponding Action statement 3.4.3.2.0 to read "With any reactor coolant system leakago greater than the limit in f above, identify the sourte of leakage within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or be in at least l HCfr SFUrDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in 00ID SFUrDCHN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />." to conform with the guidance provided in imC GL 88-01. Mditionally, a revision to IMses Section -

3/4.4.3.2 is being proposed to address the new Limiting Condition for Operation and corresponding Action statement, and indicate that they conform with the guidance provided in imC GL 88-01.

3. Revise Surveillance Requirunent 4.4.3.2.1.b to read " Monitoring the drywell floor drain sump and drywell equipment drain tank flow rate at least once per eight (8) hours," to conform with the guidance provided in IRC GL 88-01. Mditionally, a revision to Bases Section 3/4.4.3.2 is being proposed to indicate that this Surveillance Requirement confoms with the guidance provided in NRC GL 88-01 as modified by lmC Safety Evaluation dated March 6, l

1990.

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4. Revise Bases Section 3/4.4.8 on Structural Integrity to include the statement " Additionally, the Inservice Inspection Program conforms to the lac staff positions identified in imC Generic Intter 88-01, 'IEC Position on IGSCC in IMR Austenitic Stainless Stool Piping,' as approved in imC Safety Evaluation dated March 6,1990 ard October 22, 1990." 7S Section 3.4.8 requires the structural integrity of AS!E Code Class 1, 2, ard 3 cwponents be maintained in acconlance with Surveillance Requirement 4.4.8 which strictly references TS Section 4.0.5. In light of the proposed change to 7S Section 4.0.5 described in Item #1 above, ,

this revision to Bases Section 3/4.4.8 is beirg proposed '

acconiirgly for completeness. No change is required to Surveillance Requirement 4.4.8 for the reasons stated above.

The proposed charges indicated by a vertical bar in the margin of Bases page B 3/4 4-4 for IGS, Unit 1, ard Index page xix and Bases page B 3/4 4-3a for IGS, Unit 2 are solely the result of infonnation overflow and movement due to the proposed changes described above.

Safety Assessment

%e proposed TS changes conform with the guidance provided in IRC GL 88-01. Wo IRC positions described in the GL were developed as a result of extensivo research into IGSCC problems. 7ho GL states that if the Imc positions are intplemented, adequate levels of piping integrity and reliability can be achieved.. The proposed is changes provide additional and more rustrictive requirements rugardire nonitoring ard responding to reactor coolant system leakzgo as well as examination of piping susceptible to IGSCC. This will ensure the structural integrity of components and piping by early detection of flaws. There are no charges to plant equipment, plant design, limiting safety system settings, or plant system operation. The proposed TS charges enhance recognition and evaluation of potential degradation before a nore severe condition occurs.

IDformatioD_Sitpportina a Findira of No Sianificant Hazards Consideration We have concluded that the proposed charges to the IGS TS, which reflect conformance with the guidance pIUvided in NRC GL 88-01, do not constitute a Significant Hazards consideration. In support of this determination, an evaluation of each of the three stardards set forth in l 10CFR50.92 is prVvided below.

1. The crocosed channes do not involve a slanificant increase in the probability or consecuences of an accident oreviously evaluated2 l The pnposed TS charges conform with the guidance pInvided in NRC l GL 88-01. The proposed TS changes provide additional and more restrictive requirtments in the TS regarding nonitoring ard Itsponding to reactor coolant system leakage as well as examination of piping susceptible to IGSCC. This will ensure the structural integrity of components and piping by early detection l cf flaws. The NRC staff acknowledges in GL 88-01 that if the NRC positions are 12nplemented, adequate levels of piping integrity ard reliability can be achieved. The proposed TS changes do not

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Page 5 affeet any plant hardwam, plant design, plant systems, operating parancters or corditions that would causo a significant increase in the probability or consequences of any accident previously evaluated.

2. 3ho crorecal chames do not crate the rossibility of a new or different kird of accident from any accident oreviously RYalMatEb The proposcd TS changes do not alter the design or function of any plant equipment, nor do they intrtduco any new operatirg scenarios, configurations, or failure modes that would cmato the possibility of a new or different kird of accident from any accident previously evaluated.

t 3. 2he cronceal chames do not involve a sianificant reduction in a mattrin of safAty2 The IRC acknowlcdges in GL 88-01 that if the liRC positions are implemented, adoquate levels of pipirg integrity ard reliability can be achieved. The propoccd is chargos actually enhanco recognition ard evaluation of potential dcgradation before a more severo cordition or accident occurs, ard therefore, do not involvo a significant reduction in a targin of safety.

Informtion Suroortjm an Envi-wiw etal Assessment An environmental asmncmnnt is not required for the chargos proposcd by this Charge Roquest because the requested charges conform to the criteria for " actions eligible for categorical exclusion," as specified in 10CFR51.22 (c) (9) . 7ho requested changes will have no irnpact on the environnent. The rcquested charges do not involve a significant hazards consideration as discussed in the procedirg section. The requested changes do not involve a significant chargo in the types or significant increase in the amounts of any effluents that may be released offsite. In addition, the proposed changes do not involvo a significant increase in irdividual or cumulative occupational radiation exposure, gonclusion o

The Plant Operations Paview Cammittee ard the lhicicar Review Doard have reviewed these proposed chargos to the is and have concluded that they do not involve an unroviewcd safety question, or a significant hazards consideration, ard will not crdarger the health and safety of the public.

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