ML20072P485
| ML20072P485 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/29/1994 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20072P483 | List: |
| References | |
| NUDOCS 9409070314 | |
| Download: ML20072P485 (3) | |
Text
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,j NUCLEAR REGULATORY COMMISSION r
WASHINGTON, D.C. 20555-0001 4
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 75 AND 36 TO FACILITY OPERATING LICENSE NOS. NPF-39 AND NPF-85 PHILADELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION. UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353
1.0 INTRODUCTION
By letter dated January 10, 1994, as supplemented by letter dated July 20, 1994, the Philadelphia Electric Company (the licensee) submitted a request for changes to the Limerick Generating Station (LGS), Units 1 and 2, Technical Specifications (TS). The requested changes would relocate the seismic monitoring instrumentation Limiting Condition for Operation, Surveillance Requirements, and associated Tables and Bases contained in TS Sections 3.3.7.2 and 4.3.7.2 to the Updated Final Safety Analysis Report (UFSAR), Section 3.7.4.
The supplemental letter provided TS and did not change the initial proposed no significant hazards consideration determination.
2.0 BACKGROUND
TS cannot be changed by licensees without prior NRC approval.
However, since 1969, there has been a trend towards including in the TS not only those requirements derived from tha analyses and evaluations included in the safety analysis report, but other requirements governing the operation of nuclear power reactors.
This trend has contributed to the volume of TS and to the increase in the number of license amendment applications to affect changes to the TS.
In the policy statement published in the Eederal Reaister July 22, 1993 (58 FR 39132), dated July 16, 1993, effective, July 22, 1993, " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors," the NRC adopted criteria for defining the scope of the TS as required by 10 CFR 50.36.
These criteria are used by the NRC and each of the nuclear steam sup91y system vendor owners groups to completely rewrite and streamline the existing standard TS. As a result of this process, many requirements are being transferred from the TS to other licensing documents (e.g., the Final Safety Analysis Report (FSAR), Operating Procedures, Quality Assurance (QA) Plan),
which, when transferred, will not require a license amendment or prior NRC approval when changes are needed. The following criteria from the " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors," delineate those constraints on design and operation of nuclear power plants that belong in the TS in accordance with 10 CFR 50.36.
9409070314 940829 DR ADOCK 0500 2
. Criterion 1:
" Installed instrumentation that is used to detect, and indicate in the' control room, a significant abnormal degradation of the reactor coolant pressure boundary."
Criterion 2:
"A process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier."
Criterion 3:
"A structure, system or component that is part of the primary success path and which functions or actuates to mitigate a Design Basis Accident or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier."
Criterion 4:
"A structure, system or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety."
3.0 EVALUATION The staff has reviewed the request to relocate the seismic monitoring instrumentation Limiting Condition for Operation, Surveillance Requirements, and associated tables and Bases contained in TS Sections 3.3.7.2 and 4.3.7.2 to the UFSAR, Section 3.7.4.
The request was evaluated utilizing the four criteria set forth in the above NRC policy statement.
In addition, the proposed amendment does not involve a change in the manner in which the plant will be operated, maintained, or tested.
The requirements described in the affected TS will be maintained and any subsequent changes to the FSAR related to these instruments will be made in accordance with 10 CFR 50.59.
On this basis, the staff concludes that TS LC0 3.3.7.2, Surveillance Requirement (SRs) 4.3.7.2.1 and 4.3.7.2.2, Tables 3.3.7.2-1 and 4.3.7.2-1 and the Bases for TS 3/4.3.7.2, which are related to seismic monitoring instrumentation, do not need to be controlled by TS; changes to these requirements are adequately controlled by 10 CFR 50.59.
Should the licensee's determination conclude that an unreviewed safety question is involved, due to either (1) an increase in the probability or consequences of accidents or malfunctions of equipment important to safety, (2) the creation of a possibility for an accident or malfunction of a different type than any evaluated previously, or (3) a reduction in the margin of safety, as defined for any TS, NRC approval and a license amendment would be required prior to implementation of the change.
NRC inspection and enforcement programs also enable the staff to monitor facility changes and licensee adherence to updated final safety analysis report commitments and to take any remedial action that may be appropriate.
. The staff has concluded, therefore, that relocation of requirements related to seismic monitoring instrumentation (TS LC0 3.3.7.2, SRs 4.3.7.2.1 and 4.3.7.2.2, Tables 3.3.7.2 '1 and the Bases for TS 3/4.3.7.2) is acceptable because (1) their inclusion in technical specifications is not specifically required by 10 CFR 50.36 or other regulations, (2) these requirements are not required to avert an immediate threat to the public health and safety, and (3) changes that are deemed to involve an unreviewed safety question will require prior NRC approval in accordance with 10 CFR 50.59(c).
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments.
The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR-Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, 1
of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation j
exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding-(59 FR 12364).
Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b).no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
J. Harold F. Rinaldi Date:
August 29, 1994
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