ML17222A686

Safety Evaluation Supporting Amend 39 to License NPF-16

ML17222A686
Person / Time
Site:	05000000, Saint Lucie
Issue date:	02/07/1989
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML17222A685	List: ML17222A684 ML17222A686 ML17222A687
References
GL-84-15, NUDOCS 8902150077
Download: ML17222A686 (16)

Text

s ciggll 8ETJy

~4 io

~s

~i no I

us0 V/

~O iymym UNITEDSTATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O. C. 205(MI SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AHENDIsIENT NO. 39 TO FACILITY OPERATING LICENSE NO. NPF-16 FLORIDA POWER IIA LIGHT COMPANY, ET AL.

ST.

LUCIE PLANT UNIT NO.

2 DOCKET NO. 50-389 INTRODUCTION On July 2,

1984, the Nuclear Regulatory Comission issued Generic Letter 84-15 entitled "Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability."

The generic letter concluded that the frequency of diesel gener-ator fast, cold starts from ambient conditions should be reduced to prevent pre-mature diesel engine degradation, and encouraged licensees to amend their Tech-nical Specifications accordingly.

Acceptable Technical Specifications were in-cluded in the generic letter.

On April 25,

1985, the Commission issued Amendment No. 48 to Facility Operating License No.

NPF-7 for the North Anna Power Station, Unit No. 2.

The amendment included a set of acceptable Technical Specifications in response to Generic Letter No. 84-)5.

By letter dated August 27, 1985, the Florida Power and Light Company (FPAL, the licensee) proposed to amend the St. Lucie Plant, Unit No.

2 diesel generator Technical Specifications (TS).

The proposed TS were in response to the generic letter and used both the generic letter and North Anna TS as guid-ance.

The August 27, 1985 submitta Iwas 'noticed in the Federa1

~Re ister on October 9, 1985 (50 FR 41247).

The licensee updated the August 27, 1985 submittal by letter dated Hay 7, 1986, and then superseded the May 7, 1986 submittal by letter dated October 19, 1987.

Therefore, the October 19, 1987 letter superseded both the August 27, 1985 and May 7, 1986 submittals.

The October 19, 1987 letter was renoticed in the Federal

~Re ister on December 2,

1987 (52 FR 45886).

In a separate but related matter, the licensee proposed to amend the Unit 2 fuel oil TS for the diesel generators; The submittal was dated December 12, 1986.

The licensee's proposed change to the fuel oil TS was noticed in the Federa1

~Re ister on January 14, 1987 (52 FR 1549).

8902i50077 890207 PDR ADOCK 050003EI9 P

PNU,'

The following contains the staff's evaluation of thc December 12, 1986 and October 19, 1987 proposed TS changes.

BACKGROUND The St. Lucie Plant is a two unit nuclear plant with a total of four emergency diesel generator (EDG) sets.

Two EDG sets are fully dedicated to each nuclear unit, with one EDG sct assigned to each of the redundant electric power divi-sions of each unit.

There is no nor mal sharing of EDG sets between the nuclear units.

Power from one EDG set to one electrical divis1on of each unit is suf-ficient to provide for either safe shutdown loads or for accident loads.

One EDG set at the Sc. Lucie Plant, Unit No.

1 consists of two diesel engines and one generator between the engines.

The diesel engines are manufactured by General Motors.

The model and type is 654-E4.

One diesel engine has 16 cylin-ders and the, other has 12 cylinders.

The engine speed is 900 rpm, and the method of cooling is air radiators with shaft-driven fans.

There is one fan pcr aiescl engine.

The generators are manufactured by Electric Machinery.

One EDG set at the St. Lucie Plant, Unit No.

2 consists of two diesel eng1nes and one generator between the engines.

The diesel engines are thc same as for Unit No. 1.

However, each diesel engine has two fans, instead of one.

Thc generators are manufactured by General Motors, Electric Product Divis1on.

The EDG sets for Unit 2 are rated for continuous duty at 3685 kw, for 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br />s/year at 3935 kw, and for 30 minutes at 3985 kw.

The initial peak acci-dent load is approximately 3506 kw.

EVALUATION OVERVIEW The following evaluation is divided into two major sections:

Limiting Cond1tion for Operation (LCO)/Action Statement Proposed Changes and Survei llance Require-ments Proposed Changes.

The Surveillance Requirements Proposed Changes are fur-ther div1ded into Surveillance Requ1rements Other Than Fuel 011 and Survc1llancc Rcqu1rements for Fuel 011.

Evaluation -

LCO Action Statement Pry osed Chan es The licensee proposed changes to TS 3.8.1.1 (A. C. Sources - Operating - LCO).

TS 3.8.1.1.a requires two physically independent circu1ts between the offsitc transmission network and the onsite Class lE distribution system.

The licensee proposed to add a footnote to this LCO which states that this operability re-qu1remcnt can be met with one Unit. 2 startup transformer (2A or 2B) inoperable, provided that a Unit 1 startup transformer (1A or 1B) connected to the same A

or B offsite power Qrcuit is administratively available to both units and not requirea for use in Unit 1.

This footnote is essentially the present Action Statement 3.8.1.1.f, which addresses the 1noperability of one of the Unit 2 startup transformers and thc use of one of the two Unit 1 startup transformers.

By making Act1on Statement 3.8.1.1.f part of LCO 3.8.1.1.a, the licensee pro-posed to delete Action Statement 3.8.1.1.f.

The proposed footnote to LCO 3.8.1.1.a is essentially what is required in Action Statement 3.8.1.1.f, there-fore, Action Statement 3.8.1.1.f would be deleted.

One startup transformer for

0 I

Wl r '

r 05,

Unit I, if not required for use in Unit I, is physically capable of completing the connection between the offsite transmission network and the onsite Class 1E distribution system for Unit 2 and supplying the required loads.

There is no need to declare one of the independent circuits inoperable when one of the Unit 2 startup transformers is inoperable.

The staff believes that the use of a Unit I startup transformer for use on Unit 2 is an exception and is more appropriately located as an action statement, instead of making this a part of the LCO.

This was discussed with the licensee and it was agreed to keep this exception as Action Statement 3.8.1.l.f.

No other changes are associated with LCO 3.8. l.l.a and b, or the applicable modes.

The licensee proposed to change Action Statements

a. through e. to reflect the format of the action statements in Generic Letter 84-15 and also to reflect the reduction of starts on the diesel generators, with particular focus on reducing fast, cold starts.

. The format of Generic Letter 84-15 divides the action statements into five 'categories:

one offsite circuit inoperable, one diesel generator inoperable, one offsite circuit and one diesel generator inoperable, two offsite circuits inoperable, and two diesel generators inoperable.

The licensee is proposing this same format sequence.

Generic Letter 84-15 also provided the basis for reduced diesel operator testing because it was determined that fast, cold starts result in undue wear and stress on the diesel engines.

Generic Letter 84-15 also took into account the use of manufacturer-recommended preparatory actions, such as prelubrication of all moving parts and warmup procedures, which are necessary to reduce engine wear, extend life, and improve availability.

This position should not be construed to conclude that fast, cold starts should be completely eliminated, because the design basis for the plant, i.e., large LOCA coincident with loss of offsite power, requires such a capability.

Thus, the frequency of fast, cold starts from ambient conditions should be reduced, not eliminated.

The staff proposed a fast, cold start from ambient conditions at least once per 184 days and all other starts may be preceded by an engine prelubrication period and/or warmup procedures recommended by the manufacturer so that mechanical stress and wear on the diesel engine is minimized.

The licensee's proposed

changes, as discussed in more detail below, reflect this guidance.-

Proposed Action Statement 3.8.l.l.a will address the case in which one offsite circuit is inoperable and Action Statement 3.8.l.l.b will address the case fn which one diesel generator is inoperable.

Present Action Statement 3.8.1. I.a addresses both of these cases and this statement would be deleted as part of this change.

Proposed Action Statement 3.8.1.l.a will retain the same surveil-lance requirement for the offsite circuit and will also retain the 'requirement to return the inoperable offsite circuit to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

The plant shutdown requirement will also remain if the inoperable circuit cannot be made operable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

In particular, the proposed change would reduce the frequency of diesel engine starts and diesel engine fast, cold starts.

The current frequency is to test the diesel generator within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, using the fast, cold start approach.

The licensee proposed to test each diesel within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, if each diesel generator was not successfully tested within the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The provision for reducing the fast, cold starts would also apply.

The reduction of the periodic testing and type of start of the diesel generator during the period of time when an offsite circuit is not operable (up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) is justified on the basis that the operability of both diesel generators is assured because the

Pf' d1esel generators were tested during the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and, if not, they w111 be tested to demonstrate operability with1n 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of declaring the offsite circuit inoperable.

In addition, one offsite circuit would be opera-blc.

The net effect of the change is to reduce the diesel generator testing frequency and type of start (fast, cold start), such that there is still a high degree of assurance that they would operate, if called upon, when one offsite circuit is inoperable.

The reduction of d1esel generator testing frequency ana type of start should increase the rel1abil1ty of the machines because the engines will be properly conditioned before startup and the number of starts will be decreased to reduce wear and tear.

Thus, the proposed action state-ment change discussed above (TS 3.8.1.1.a) is acceptable.

In regard to proposed Action Statement 3.8.1.l.b, 1noperability of one diesel generator, the action statement will retain the same surveillance requirement for testing the uffsite circuits and will also reta1n the requ1rement to re-turn the 1noperable diesel generator to operable status'within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

The.

plant shutdown requirement will also remain if the inoperable diesel generator cannot be brought to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

The proposed change would reduce the frequency of the operable diesel generator starts and diesel engine fast, cold starts, in particular.

The current frequency is to test. the diesel generator within I hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter using the fast, cold start approach.

The licensee proposes to t~st,the operable diesel genera-tor within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, even if the inoperable diesel generator is restored to operability.

The provisions for reducing the fast, cold starts would also apply.

The, reduction of the periodic testing of the operable diesel generator during the period of time when the other diesel generator is inoperable (up to 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />s}

is justifiable on the basis that both offsite power circu1ts are operable while one diesel generator is inoperable, and the other diesel generator will be tested to assure operabi lity, The net effect of the change is to reduce the operable diesel generator testing frequency and type of start such that a high degree of assurance of available AC power remains because two offsite circuits are operable and one diesel generator is operable.

The reduction of the diesel generator test frequency and type of starts should increase the reliability of the machines because the engine will be properly conditio'ned before start'and the number of starts will be decreased to reduce wear and tear.

Thus, the proposed action statement change discussed above (TS 3.8.1.l.b) is acceptable.

In addition, deleting current Action Statement

a. is acceptable because the requirements are now contained in proposed Act1on Statements a.

and b.

Proposed Action Statement 3.8.1.1.c will address the inoperability of one off-site circuit and one diesel generator.

The present Action Statement 3.8.l.l.b covers this case and it will be deleted.

The proposed act1on statement will retain the same surveillance requirement for testing the operable offsite c1rcuit and will also retain the requirement to return one of the inoperable power sources to operable status within I2 hours or shut down the plant as required in the spec1fication.

It will also retain the requirement to make the other inoperable power source operable during the prescribed time.

In.particu-lar, the proposed change would reduce the frequency of the operable diesel generator starts and diesel engine fast, cold starts.

The specification will

0 1

,ie be similar to new action 3.8.1.1.b, bus the diesel engines will have to be started within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, 1nstead of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The new 8-hour start requirement is commensurate with two power sources being inoperable per this specification.

For this reason the staff finds this change acceptable.

Pre'sent statement 3.8.1.l.c requires additional action when a diesel generator is inoperable.

All requ1red

systems, subsystems,

tra1ns, components, and devices that depend on the remaining operable diesel operator as a source of emergency power must also be operable; the steam-driven auxi l1ary feedwater pump must also be operable.

Plant shutdown requirements are specified 1f these added conditions are not met.

The licensee proposes to make this action statement part of new Action Statements b.

and c., arid delete present Action Statemenc c.

This change is administrative in nature and 1s acceptable.

Proposed Action Statement

d. will replace present Action Statement d.

This'tatement deals with the case of two inoperable offsite circuits. It retains the requirement to bring both offsite circuits back to operability status or shut down the plant.

The proposed change is similar to the prop'osed change 1n Act1on Statement

b. above.

Instead of testing the diesel engines within I hour

'nd then once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, the licensee proposes testing. both diesels within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

The proposed change is essentially what was recommended in Generic Letter 84-15, and is acceptable.

Proposed Action Statement

e. will replace present Action Statement e.

Th1s statement deals with the case of two inoperable diesel generators.

It retains the requirement to test the offsite circuits and to restart, one inoperable diesel within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or shut down the plant.

Instead of spec1fy1ng the time required to make the second diesel generator operable, it specifies use of proposed Action Statement b., which is essentially the same requirement.

The proposed change is essentially what was recommended in Generic Letter 84-15, and i s acceptable.

Evaluation-Surveillance Re uirements Other Than Fuel Oil The 11censee proposea a number of changes to the diesel generator surveillance requirements.

The objective of the changes is to reduce the number of fast, cold starts.

Engine preconditioning is proposed to'be allowed.

The diesel generators must be tested for operability on a monthly basis at least, even if the LCO's (two offsite circuits and two diesel generators operable) are met.

As failures occur, an accelerated testing frequency is currently required.

This can lead to testing the engines at least once per 3 days.

The licensee is also proposing to reduce the accelerated testing frequency.

The licensee proposed changing the diesel generator test schedule specified in Table 4.8-1 (TS 4.8,.1. 1.2a).

The present test schedule specifies four testing frequencies (31 days, 14 days, 7 days, and 3 days) based upon the number of failed diesel generator starts over the last 100 attempts.

The licensee pro-posed the same test schedule as contained in Table 4.8-1 of Generic Letter 84-l5.

However, the licensee did not propose Generic Letter 84-15 Table 4.8.2, which calls for add1tional reliab1lity actions based upon the number of failures in the last 20 and 100 valid tests.

~ q

~A 1

Specifically, the licensee proposed a test frequency of once per 31 days for less than or equal to one failure in the last 20 valid tests and a test fre-quency of at least once per 7 days for two or more failures in the last 20 valid tests.

This is acceptable since it is consistent with the staff guidance of Generic Letter 84-15.

The staff is concerned that the licensee did not propose any test schedule based upon the last 100 starts in order to assure Iong-term diesel generator reliability.

This was discussed with the licensee.

In order to address long-term reliability, the staff and licensee agreed to modify proposed Table 4.8-1 to also include a minimum of 7 day testing if the number of failures in the last 100 valid tests exceeds five.

Thus, proposed Table 4.8-1, as modified, is acceptable.

The licensee proposed changing the diesel start requirement (TS 4.8.1.1.2.a.4) in two ways.

The licensee proposed to accelerate the engines to approximately 900 rpm versus at least 900 rpm.

The licensee stated that this change is necessary in order to be consistent with another part of the specification, a

generator frequency of 60

+ 1.2 hertz.

This is acceptable on the basis that the design speed will be maintained and the chance of overspeed with subsequent trip is lowered.

A footnote will be placed on this surveillance requirement, which will, in effect, reduce the number of fast, cold starts and permit engine preconditioning.

The staff amended the warmup part of the footnote to make it clearer that warmup is allowed in order to minimize stress and wear on the diesel generator.

This was discussed with and agreed to by the licensee.

The footnote is consistent with the staff guidance of Generic Letter 84-15, and is acceptable.

The licensee proposed changing the generator loading and load run requirements TS (4.8. 1.1.2.a.5).

The licensee proposed to load the generator to 3685 kw but delete the 60-second requirement.

In addition, once the generator is operating for this 60-minute test run, a load band of 3450 kw to 3685 kw would be specified, instead of the present requirement of maintaining a load of greater than or equal to 3685 kw.

A footnote will be added to specify that the timing for the test shall start with the closing of the breaker and loading will be consistent with manufacturer's receaaendations.

The staff clarified the footnote so that the generator would be loaded within 60 seconds at least once every 184 days.

This was discussed with and agreed to by the licensee.

The licensee's proposed specification is similar to the wording that was approved in the North Anna TS.

The open-ended language "greater than or equal to" has the potential for routine overloading of the generators when operated for appreciable periods of time.

Specifying an upper limit when the generator will be continuously run for more than a few minutes would eliminate this potential.

The proposed load band for the diesel generator s is a plant-specific value and is reasonable (roughly 200 kw) for this engine size.

Although the lower end of the loading band (3450 kw) is slightly less than the peak accident load (3506 kw), the peak accident load occurs over a short period of time and this difference should be inconsequential.

Based upon the above discussion, the licensee's proposed surveillance requirement for the generator loading and load run is acceptable.

The licensee proposed to relocate the automatic load sequence timers surveil-lance requirement and change the test frequency from 12 months to 18 months.

The present requirements are contained in TS 4.8. 1.1.2.d.

The automatic load sequence timers surveillance requirement will be renumbered as 4.8.1.1.2e.

12 and placed under the 18-month test requirement.

This part of the change is

1 E

administrative in nature, and is acceptable.

The. licensee's basis for the test frequency change is that the electropneumatic timing relays were replaced with Agastat DSC solid state devices, which are more accurate and reliable.

The old relays required a 12-month test, whereas the new relays only require an 18-month test.

This change is acceptable because the new timers are more accurate and

reliable, and their need for testing is reduced.

Since TS 4.8.1.1.2d will be addressed elsewhere in the TS, namely, new section 4,8. 1.1.2e.l2, its deletion is acceptable.

The licensee proposed adding a footnote to the various 18-month tests:

loss of offsite power test, ESF actuation test signal test, and loss of offsite power test in conjunction with ESF actuation test signal test.

These TS are 4.8. 1. 1.2e.4.b, 4.8. 1.1.2e.5, and 4.8. 1.1.2e.6.b.

A footnote would also be added to the 10-year or post-modification test of TS 4.8.1.1.2.f.

The footnote would state that the test may be conducted in accordance with the manufacturer's reconmendation concerning engine prelubrication period and/or other warmup procedures.

This is consistent with the intent of 6eneric Letter 84-15 and will reduce the number of fast, cold starts.

However,'he staff is concerned that none of these tests are required to be performed from ambient conditions, because for every test, prelubication and warmup procedures could be used.

This was discussed with the licensee and the licensee agreed to modify the footnote by deleting the warmup provision.

The licensee also pointed out that TS 4.8.1.1.2a.4 also requires a diesel start from ambient conditions at least once per 184 days.

Thus, the staff's concern is resolved.

The proposed foot-

note, as

amended, is acceptable.

The licensee proposed to change the 18-month test which requires operating the diesel generator for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (TS 4.8.1.1.2e.7).

A load band of 3800 kw to 3985 kw instead of a minimum load of 3985 kw is proposed for the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, and a load band of 3450 kw to 3685 kw, instead of 3685 kw, is proposed for the last 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />.'

footnote will also be added to specify that the band is meant as guidance to avoid routine overloading of the engines.

The licensee's proposed specification is similar to the wording that was approved in the North Anna TS, The licensee does not wish to overload the generator and the open-ended language "greater than or equal to" could lead to this.

The proposed loading bands are plant-specific values and are reasonable (roughly 200 kw) for this engine size, The staff noted that the licensee did not request a footnote allowing engine prelubrication.

This was discussed with the licensee and it was agreed that the same footnote discussed above (prelubrication footnote associated with 18-month test) would also be applicable in this case.

Therefore, the licensee's proposed surveillance requirement changes are acceptable.

The licensee proposed to change the 2000-hour rating auto-connect load from 3985 kw to 3935 kw (TS 4.8.1.1.2.f).

The licensee reviewed the vendor's technical manual and determined that the present value in the TS is incorrect.

Since the licensee proposes the correct value in accordance with the vendor's technical

manual, the change is acceptable.

The licensee proposed to make an editorial change to TS 4.8.1.2 (AC Sources-Shutdown - Surveillance Requirement).

Presently, a diesel generator failure is required to be submitted under Surveillance Requirement 4.8.1.2.

The licensee proposed to make this reporting requirement TS 4.8.1.2.2, using the same words as TS 4.8. 1.1.3.

Present TS 4.8. 1.2 would also become TS 4.8.1.2.1.

This editorial change is acceptable.

0

~

~ ~

( ~

~ ~

pe Evaluation - Surveillance Re uirements for Fuel Oil The licensee proposed to delete existing TS Surveillance Requirements 4.8.1.1.2b and c, and substitute new Surveillance Requirements 4.8.1.1.2b, c

and d.

The licensee's proposal is identical, with one minor exception, to the diesel fuel oi 1 surveillance program approved by the staff for McGuire Nuclear Station',

Units 1 and 2.

The exception is that the licensee has specified that testing in accordance with ASTM 0-2276-78, Method A, or Annex A-2 would also be allowed.

The end result of testing in accordance with Method A or Annex A-2 is identical, and the staff considers these two test procedures to be interchangeable.

The licensee's exception is therefore acceptable.

With the above clarification, the licensee's proposal is identical to the McGuire program.

In the Safety Evaluation Report (SER) for the McGuire fuel oil surveillance program, the staff concluded that the proposed program would "result in a more conservative approach to fuel oil surveillance" and, because of the added conservatism, "should increase diesel gener'ator availability."

Based on the above, the staff fur'ther concluded that the McGuire program was acceptable.

Since the licensee's proposal for St. Lucie 2 is identical to the HcGuire Program, the staff concludes that it is also acceptable.

This fuel oil surveillance program is independent of plant-specific design and is generically applicable.

A copy of the McGuire SER is attached for reference.

(Note:

For the purpose of this TS surveillance, the terms "day tank" and "engine-mounted fuel tank" are interchangeable).

For purposes of, clarity, the staff has modified the licensee's proposed TS to reflect the current version of ASTH 0-2276, i.e., the 1983 revision rather than the 1978 revision.

The testing requirements of both versions are identi-cal.

Therefore, the licensee has agreed to use the 1983 version of ASTH 0-2276.

ENVIRONMENTAL CONSIDERATION This amendment involves a change in the installation or use of a facility.

component located within the restricted area as defined in 10 CFR Part 20 or a change to a surveillance requirement.

The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Commission has previously published a proposed finding that the amendment involves no significant hazards consideration and there has been no public cottment on such finding.

Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 551.22 (c)(9).

Pursuant to 10 CFR 51.22(b),

no environmental impact statement or'nvironmental assessment need be prepared in connection with the issuance of the amendment.

CON CLUS ION We have 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, and (2) such activities will

0 Q

I L

be conducted in compliance with the Commission's regulations, and the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public, Dated:

February 7, l989 Princi al Contributors:

E. Tomlsnson E. Tourigny Attachment YicGuire SER