ML20212H552
| ML20212H552 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/27/1999 |
| From: | Hutton J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20212H555 | List: |
| References | |
| NUDOCS 9910010183 | |
| Download: ML20212H552 (9) | |
Text
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Station Srpport Department xg-10 CFR 50.90 PECO ENERGY esco emem,c _ -,
Nuclear Group Headquarters 905 Chesterbrook Boulevard Wayne. PA 19087-5691 September 27,1999 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 Technical Specifications Change Request No. 98-03-0 Administrative Changes
Dear Sir / Madam:
PECO Energy Company (PECO Energy) is submitting Technical Specifications (TS)
Change Request No. 98-03-0, in accordance with 10 CFR 50.90, requesting a change to TS (i.e., Appendix A) of Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2.
The proposed changes will revise LGS Technical Specificdons to clarify several administrative requirements, delete redundant requirements, and correct typographical errors.
Information Supporting this TS Change Request is contained in Attachment 1 to this letter, and copies of the " marked-up" and " camera-ready" Technical Specifications pages are contained in Attachments 2 and 3, respectively. This information is being submitted under affirmation, and the required affidavit is enclosed.
We request that if approved, the changes become effective within 30 days of issuance.
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PDR ADOCK 05000352 i
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1 Dock;t Nos. 50-352/50-353 S:pt:mber 27,1999
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If you have any questions, please do not hesitate to contact us.
Sincerely, 1iI ff mes A. Hutton irector-Licensing -
Attachments Enclosure l
cc:
H. J. Miller, Administrator, Region I, USNRC (w/ attachment, enclosure)
A. L. Burritt, USNRC Senior Resident inspector, LGS I
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COMMONWEALTH OF PENNSYLVANIA
- ss COUNTY OF CHESTER J. J. Hagan, being first duly swom, deposes and says: That he is Senior Vice President of PECO Energy Company, the Applicant herein, that he has read the enclosed Technical Specifications -
Change Request No. 98-03-0, " Administrative Changes," for Limerick Generating Station, Units 1 and 2, Facility Operating License Nos. NPF-39 and NPF-85, respectively, and knows the contents thereof, and that the statements and matters set forth therein are true and correct to the best of his knowledge,information and belief.
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3 Senio ice resident l
Subscribed and sworn to before me thi/7 day of 1999.
[ Notary Public~
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ATTACHMENT 1 LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS.
50-352 50-353 j
LICENSE NOS.
NPF-39 i
NPF " Administrative Changes" Information Supporting Changes - 5 Pages i
3
7
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? Att: chm:nt 1 Docktt Nos. 50-352/50-353 i
' Ucense Nos. Ni:F-39/NPF-85 l
. September 27,1999 i:
Page 1 of 5 DISCUSSION AND DESCRIPTION OF THE PROPOSED CHANGES PECO Energy Company (PECO Energy) is requesting Technical Specifications (TS) changes
.which will revise Limerick Generating Station (LGS) TS to clarify several administrative requirements, delete redundant requirements, and correct typographical errors.
An evaluation of the requirements of Section 6.0, " Administrative Controls," of Limerick's TS against current administrative practices was performed to determine opportunities for clarification. As a result of this review, specific issues and recommended changes to TS Section 6.0 were identified. The proposed TS changes are described below.
Chance 1 Unit 1(2) TS Section 6.2.2, " Unit Staff," item f., describes the overtime restrictions for
. station staff who perform safety-related functions. This item indicates the objective is to have operating personnel work a " normal 8-hour day,40-hour week." LGS personnel currently work a variety of scheduled hours during a work day, from 8-hour days to 12-hour days, while maintaining the overtime restrictions specified in TS Section 6.2.2.f. Therefore, TS Section 6.2.2.f will be revised to reference a " nominal" 40-hour week a,1d the specific reference to a " normal 8-hour day" will be deleted.
Chanae 2 Unit 1(2) TS Section 6.5.1.2 describes the composition of the Plant Operations Review i
Committee (PORC). This'section identifies two specific positions that are filled by PORC members as appointed by the Plant Manager, i.e., the PORC Chairman and the Altemate PORC Chairman. This reference implies there is only "one" Attemate PORC Chairman.
Therefore, TS Section 6.5.1.2 will be revised to clarify that several individuals may be
- qualified to fill the position of Altemate PORC Chairman by changing the word " Chairman" to " Chairmen." -
Chance 3 -
Unit 1(2) TS Section 6.8.2 requires that procedures required by TS Section 6.8.1 be reviewed " periodically" as set forth in Administrative procedures. This implies that there is a scheduled periodicity for procedure reviews. By letter dated July 14,1992, the NRC approved a change to the Quality Assurance Program Description in the LGS UFSAR to
' eliminate the scheduled periodic reviews of procedures due to other programmatic controls and processes that assure that procedures are current. Therefore, TS Section 6.8.2 will be revised to eliminate the implication of a scheduled periodic review by deleting the word
" periodically."
Attachm::nt 1 Dock:;t Nos. 50-352/50-353-
[
- License Nos. NPF-39/NPF-85 September 27,1999,
Page 2 of 5. '
IChanoe'4 Unit 1(2) TS Section 6.9.1.5.b requires documentation of all challenges to Safety Relief Valves (SRVs) be included in an annual report to the NRC. This same information is j
c required to be included in the Monthly Operating Reports as specified in TS Section i
6.9.1.6. Therefore, TS Section 6.9.1.5 will be revised to remove this redundant reporting requirement.'
In' addition, typographbal errors were identified in TS Sections 3.8.3.1 and 3.8.3.2. The errors and recommended cnenges are described below.
Chance 5 Unit 1(2) TS Sectio' ns 3.8.3.1.b.7.a) and 8.a), and TS Sections 3.8.3.2.b.7.a) and 8.a) incorrectly identify 125-V DC fuse boxes 2(1)FC and 2(1)FD as 250-V DC fuse boxes. The
~125-V DC distribution panels identified in the same TS Sections are correct. In addition, the as-built condition of the plant is correct. Therefore, TS Sections 3.8.3.1.b.7.a) and 8.a),
and TS Sections 3.8.3.2.b.7.a) and 8.a) will be revised to correctly identify fuse boxes
' 2(1)FC and 2(1)FD as 125-V DC fuse boxes.
Also, the following minor editorial changes will be made.
Chance 6 Unit 1(2) TS Section 3.8.3.1.b.1.b) will be revised to remove the letter "s" from the end of the phrase " Motor Control Centers" since only one motor control : enter is identified. This is consistent with TS Section 3.8.3.2.b.1.b). Unit 1 TS Section 3.8.3.1.b.7.b) will be revised to capitalize the "P"in the word " panels" and replace the semicolon (;) at the end of the phrase with a colon (:) for consistency with the similar Unit 2 TS Section and Unit 1 TS Section 3.8.3.2.b.7.b). Unit 1(2) TS Section 6.2.2.b will be revised to replace the colon (:)
'at the end of this item with a semicolon (;) for consistency with similar items on the affected TS page.' Unit 2 TS Section 6.9.1.6 will be revised to correct the format of the addressee for submittal of the Monthly Operating Reports to the "U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555" consistent with Unit 1 TS.
SAFETY ASSESSMENT
- The proposed changes involve administrative changes to TS to clarify several administrative requirements, delete redundant requirements and to correct typographical errors. The proposed changes do not involve any physical changes to plant structures, systems, or components (SSCs),
or the manner in which these SSCs are operated, maintained, modified, tested, or inspected.
a
Att:chmint i Docktt Nos. 50-352/50-353 License Nos. NPF-39/NPF-85
. September 27,1999 ^
Page 3 of 5 -
phance 1 <
Generic Letter 82-12, " Nuclear Power Plant Staff Working Hours," indicates that station
. personnel performing safety-related functions while in a fatigued condition could significantly reduce their mental alertness or their decision making capability. Therefore, GL 82-12 issued restrictions or limitations that would preclude the use of routine, heavy overtime, and therefore,.
prevent station personnel involved in safety-related activities from working in a fatigued condition. These restrictions, which had previously been incorporated into LGS TS Section 6.2.2,8, items 1. through 4., and are implemented through procedure A-C-40, are not being changed by this activity. In addition, the NRC references 12-hour shifts in 10CFR55.53 concoming the requirement for licensed operators to maintain their license in an active status
~
as a condition of their license. -Therefore, the NRC previously recognized that licensed
. operators, as an example of station staff who perform safety-related functions, may work up to
' 12-hour shifts at some utilities, and that working the additional hours beyond the " normal 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> day" does not cause undue risk due to increased operator fatigue. Therefore, deleting
- the " normal 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> day" statement from the overtime objective in TS Section 6.2.2.f will not result in station personnel performing safety-related functions while in a fatigued condition.
Chance 2 -
For any given PORC meeting, if not chaired by the PORC Chairman, the meeting is chaired by an Altemate PORC Chairman who has been selected from the PORC members and been -
' designated as an Altemate Chairman in writing by the Plant Manager in accordance with TS.
'TS does not stipulate or require that the Altemate PORC Chairman satisfy any additional qualification criteria to serve in this position. The selection of which PORC members serve as
- an Alternate Chairman is at the discretion of the Plant Manager. The qualification criteria and the process for qualification of an individual as a PORC member are not being changed by this activity. As a result, the level of reviews performed by any PORC quorum of plant operations,
- procedures, modifications, tests, or experiments will remain consistent, regardless of who has M
been selected to serve as the Altemate PORC Chairman.
Chance 3 -
The NRC previously reviewed and approved the use of programmatic' controls in lieu of scheduled periodic reviews to ensure that plant procedures are reviewed and appropriately maintained. The existing programmatic controls ensure that the plant continues to be operated in a safe and efficient manner and does not pose any undue risk to the health and safety of the public. These controls are not being changed by the proposed changes.
Chance 4
'SRV challenges do have a direct impact on the plant. Identifying the root cause of the 4
challenges and taking action to.::orrect them and prevent them from occurring in the future are 1
Att:chmInt 1 Dock:t Nos. 50-352/50-353 License Nos. NPF-39/NPF-85 September 27,1999 Page 4 of 5 handled through the onsite corrective action program which is not being changed by the proposed changes. Documentation and reporting of all SRV challenges to the NRC, however, is purely an administrative function that in and of itself has no direct impact on the operation of the plant. Reporting all challenges to SRVs on a yearly basis in an annual report is redundant to reporting all SRV challenges on a monthly basis in the Monthly Operating Report as required by TS. Therefore, deleting the requirement to report all challenges of SRVs in an annual report does not have any safety impact on the plant.
Chanae 5 Correcting the typographical errors in TS Sections 3.8.3.1 and 3.8.3.2 is purely an administrative change. The drawings and procedures associated with the 125-V DC fuse boxes are correct and ensure that the fuse boxes are operated and mainteined appropriately.
In addition, the as-built configuration of the plant is correct. Therefore, correcting these typographical errors does not have any impact on plant safety.
Chanae 6 These minor editorial changes are purely administrative changes for consistency within the TS pages and have no impact on plant safety.
INFORMATION SUPPORTING A FINDING OF NO SIGNIFICANT HAZARDS CONSIDERATION We have concluded that the proposed changes to the Limerick Generating Station (LGS), Unit 1 and Unit 2, Technical Specifications (TS), which will make administrative changes to TS, 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 proposed TS chanaes do not involve a sianificant increase in the probability or conseauences of an accident previously evaluated.
The changes are administrative in nature and do not impact the operation, physical configuration, or function of plant equipment or systems. The changes do not impact the initiators or assumptions of analyzed events, nor do they impact mitigation of accidents or transient events. Therefore, these changes do not increase the probability of occurrence or consequences of an accident previously evaluated.
l
- 2. The proposed TS chanaes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed changes are administrative in nature and do not alter plant configuration, j
require that new equipment be installed, alter assumptions made about accidents previously evaluated, or impact the operation or function of plant equipment. Therefore, these changes do not create the possibility of a new or different kind of accident than il
Attachm:nt 1 Dock!t Nos. 50-352/50-353 License Nos. NPF-39/NPF-85 September 27,1999 Page 5 of 5 -
previously evaluated.
- 3. The proposed TS chanoes do not involve a sionificant reduction in a maroin of safety.
The proposed changes are administrative in nature and do not involve any physical changes to plant structures, systems, or components (SSCs), or the manner in which these SSCs are operated, maintained, modified, tested, or inspected. The proposed changes do not involve a
' change to any safety limits, limiting safety system settings, limiting conditions of operation, or design parameters for any SSC. The proposed changes do not impact any safety analysis assumptions and do not involve a change in initial conditions, system response times, or other parameters affecting any accident analysis. Therefore, these changes do not involve any reduction in a margin of safety.
INFORMATION SUPPORTING AN ENVIRONMENTAL ASSESSMENT in accordance with 10 CFR 51.41, a review was performed to determine the impact of the proposed changes on the conclusions of the NRC's Final Environmental Statement for LGS.
The considerations included in 10 CFR 51.45(b) were used in this review with the following conclusions. Since the proposed changes are administrative only, and there is no impact on the operation of the facility, implementation of the proposed changes has no impact on the environment. Since there is no impact on the environment, there are no adverse environmental effects that cannot be avoided. Since these changes are required to eliminate errors and provide clarification, and there is no impact on the operation of the facility nor on the environment, there are no attematives to the proposed changes. Since the operation of the facility is not affected by the proposed changes, there is no impact on the original assessment of the relationship between local short-term uses of man's environment and the maintenance and enhancement of long-term productivity. Since the operation of the facility is unaffected by the proposed changes, there is no change to the comm!tment of resources and therefore, no irreversible nor irretrievable commitment of resources involved.
CONCLUSION The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes to the Limerick Generating Station, Unit 1 and Unit 2, Technical Specifications, and have concluded that they do not involve an unreviewed safety question, they do not involve a Significant Hazards Consideration, and they will not endanger the health and safety of the public.