ML20035H083
| ML20035H083 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 04/27/1993 |
| From: | Stimac S COMMONWEALTH EDISON CO. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19303F591 | List: |
| References | |
| GL-89-19, TAC-M75022, TAC-M75023, NUDOCS 9305030092 | |
| Download: ML20035H083 (19) | |
Text
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[ji / 1400 0 pus Place Ccmm:nw:alth Edison i
]
7 Downers Grcwe, tilinois 60515 April 27, 1993 I
Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation f
U.S.
Nuclear Regulatory Commission Washington, DC 20555 Attn:
Document Control Desk
Subject:
Zion Station Units 1 and 2 Application for Amendment to Facility Operating Licenses DPR-39 & DPR-48 Appendix A, Technical Specifications License Amendment Request No. 93-03 NRC TAC Numbers M75022 and M75023 NRC Dockot Nos. 50-295 and 50-304
References:
a)
HRC Generic Letter 89-19, dated September 20, 1989 b)
Letter from M.H.
Richter to USNRC, dated March 23, 1990 c)
Letter from S.F.
Stimac to USNRC, dated February 25, 1993 Dedr Dr. Murley:
Pursuant to 10CFR50.90 Commonwealth Edison Company (CECO) proposes to amend Appendix A, Technical Specifications, of Facility Operating Licenses DPR-39 and DPR-48.
The amendment request proposes revisions to Reactor Protection and Engineered Safeguards Technical Specifications and Limiting Safety System Settings to: 1) add Steam Generator Overfill Protection requirements and 2) modify the equations for the Overpower AT (OPDT) and Overtemperature AT (OTDT) protective functions.
The addition of Steam Generator Overfill Protection requirements fulfills CECO's commitments (References b) and c))
i related to Generic Letter 89-19 (Reference a)).
The modification of the OPDT and OTDT equations will correct inconsistencies between the current Technical Specification equations and the Eagle 21 Process Protection System and will relocate certain lag conpensators f rom the Technical Specifications.
The proposed changes are discussed in detail in the attachments to this letter.
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Dr. Murley April 27, 1993 l
This amendment request is subdivided as follows:
[
l '.
Attachment A provides a Description and Safety Analysis l
of the proposed changes.
2.
Attachment P describes Ceco's evaluation performed in accordance with 10 CFR 50.92(c), which confirms that no i
significant hazards consideration is involved.
j l
3.
Attachment C provides the Environmental Assessment.
'l 4.
Attachment D includes marked-up Technical Specification pages with the requested changes indicated.
Attachment l
D also includes typed copies of the revised Technical Specification pages.
i 5.
Attachment E provides supporting information in both proprietary and non-proprietary forms along with associated withholding documentation.
Specifically, Attachment E contains:
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1 1
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1.
One copy of " Zion NSSS Se'; point Evaluation, Protection i
l' System Channels, Eagle 21 Version Westinghouse Channels" l
Revision 2, dated March 1993 (Proprietary).
i 2.
One copy of " Zion NSSS Setpoint Evaluation, Protection System Channels, Eagle 21 Version Westinghouse Channels" l
Revision 2, dated March 1993 (Non-Proprietary).
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Also provided in Attachment E is a Westinghouse authorization letter, CAW-93-441, accompanying affidavit,_and L
Proprietary Information Notice.
As Item 1 contains-information l
proprietary to Westinghouse Electric Corporation, it is supported l
by an affidavit signed by Westinghouse, the owner of the j
information.
The affidavit sets forth the basis on which the.
information nay be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph 03) (4 ) of Section 2.790 of the Commission's regulations.
Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.790 of the Commission's regulations.
Correspondence with respect to the proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-93-441 and should be-addressed to N.J.
Liparulo, Manager of Huclear Safety &-
Regulatory Activities, Westinghouse Electric Corporation, P.O.
Box 355, Pittsburgh, Pennsylvania 15230-0355.
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Dr. Murley April 27, 1993 This proposed amendment has been reviewed and approved by both On-site and Off-site Review in accordance with Commonwealth Edison-procedures.
Commonwealth Edison is notifying the State of Illinois of our I
application for amendment by transmitting a copy of this letter and its attachments to the designated State office.
l Commonwealth Edison requests that this amendment be effective as of the date of its issuance, to be implemented within 30 days from the date of issuance.
To the best of my knowledge and belief, the statements contained herein are true and correct.
In some respects, these statements are not based on my personal knowledge but upon information received from other Commonwealth Edison and contractor i
employees.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
Please direct any questions you may have regarding this matter to this office.
l sespectfulb.,
E'.
sx Stephen F. Stimac Nuclear Licensing Administrator Attachments:
A) Description and Safety Analysis of the Proposed Changes B) Evaluation of Significant Hazards Consideration C) Environmental Assessment D) Marked-up Technical Specification Pages E) Supporting Technical Information cc:
A.
Bert Davis, Regional Administrator - RIII r
J.D.
Smith, Senior Resident Inspector - Zion C.Y.
Shiraki, Project Manager - NRR Office of Nuclear Facility Safety - IDNS County of b/N4b State of Signad be e me on this --[Wdy
" OFFICI AL SEAL' of_M M :19 h dM S ANDR A C. L AR A 1
NOTARY PUBLIO. STATE OF ILUNOIS ?
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P ATTACHMENT-A
.i ZION NUCLEAR GENERATING STATION l
LISCRIPTION AND SAFETY ANALYSIS OF THE PROPOSED TECHNICAL SPECIFICATION CHANGES FOR LICENSE AMENDMENT REQUEST NO. 93-03 i
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-t Part 1:
i Steam Generator Overfill Protection l
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Part 2:
l Technical Specification Equations Describing The Overpower i
Delta T (0PDT) and Overtemperature Delta T (OTDT) Functions l
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ZNLD/2562/1 j
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l LICENSE AMENDMENT REQUEST NO. 93-03 i
A.
DESCRIPTION OF THE PROPOSED CHANGES:
1)
Steam Generator Overf111 Protection l
An amendment to the Technical Specifications for the Zion Station, Units l
1 and 2, is being proposed in response to Generic Letter 89-19, " Safety l
Implications of Control Systems in LHR Nuclear Power Plants." The Generic Letter requires that the Steam Generator Overfill Protection System be included in plant procedures and Technical Specifications.
The proposed change includes the addition of Steam Generator Hi-H1 Level l-feedwater isolation signals to Tables 3.4-1 and 4.4-1 under the heading l
" Steam Generator Overfill Protection" along with corresponding addition to the Section 3.4 Technical Specification Bases.
The Table 3.4-1 additions include the following:
Number of channels of Steam Generator Hi-Hi Level measured:
Number of channels required to generate a Trip; Minimum number of channels required for Operability, Minimum degree of redundancy, Operator actions required if the LCO conditions cannot be met; and, Setpoint of the Steam Generator Hi-H1 Level trip.
The changes to Table 4.4-1 include the surveillance requirements for:
Channel Check once per Shift (S);
1 Channel Calibration once per 18 months (R); and, Channel Functional Test once per Quarter (Q).
l The change to the Bases includes the addition of the feedwater system isolation to the list of Engineered Safety Features (ESF) actuations.
Beyond the inclusion of these items into the Technical Specifications, there are no changes to the Plant. The instrumentation required for the Steam Generator Overfill Protection function is currently in place and in use and is being regularly tested.
This amendment simply formalizes the operability and testing requirements for the overfill protection system and prescribes the required actions if the steam generator overfill protection function is inoperable.
l ZNLD/2562/2 1
LICENSE AMENDMENT REQUEST NO. 93-03 2.
Equations Describing the Overpower Delta T (OPDT) and Overtemperature Delta T (OTDT) Functions.
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An amendment to the Technical Specifications for the Zion Station, Units 1 and 2, is required to revise equations that describe the calculation of Overtemperature Delta T (OTDT) and Overpower Delta T (0PDT) functions in the recently installed Eagle 21 Process Protection System.
These changes are needed for two reasons:
- a. The softwsre installed in the Eagle 21 Process Protection System is correct and in accordance with the safety analysis.
However, as a t
result of administrative error, the Technical Specification equations l
that describe the Eagle 21 calculations for OTDT and OPDT identify the time constants using the nomenclature used for the 7100 l
Protection System that the Eagle 21 System replaced.
These equations are not referred to in the day to day operation of the plant and correcting the equations is intended to avoid the potential for confusion during future interaction with the Eagle 21 System.
- b. The requirements for the lag compensators on measured AT and measured T are being relocated to plant procedures.
These lag avg compensators are currently used in the OTDT and OPDT calculations to compensate for the fast responding RTDs used in the RTD bypass manifolds at Zion.
The AT and T response time safety analyses i
includeassumptionsregardingthefesponsetimeofthesefunctions.
av Installation of fast responding Rosemount RTD's shortens the instrument response time and results in spurious turbine runback signals at elevated reactor power.
The lag compensation allows the j
response time to be adjusted to avoid spurious turbine runback j
signals.
Controlling the values assigned to the lag compensators by j
procedure will allow CECO to change the values as necessary to support plant operations within the assumptions for response times used in the safety analyses. Allowing CECO to adjust instrument response time within the limits of the safety analyses using procedural controls in accordance with 10CFR50.59 will relieve both the NRC and CECO of the administrative burden of a license amendment when changes are required.
l The equations that require revision are:
Specification 2.1.1.B.4a Overtemperature Delta T Note 1 This equation describes the Eagle 21 (pages 10a and 10b) calculation of OTDT.
Specification 2.1.1.B.Sa Overpower Delta T Notes 2 This equation describes the Eagle 21 (pages 10c and 10d) calculation of OPDT.
The specific changes to the equations in Note 1 and Note 2 are l
identified in Attachment D which contains the changes marked up directly on Technical Specification Pages 10a, 10b, 10c and 10d.
ZNLD/2562/3
LICENSE AMENDMENT REQUEST NO. 93-03 B.
CURRENT REQUIREMENTS:
1)
Steam Generator Overfill Protection Steam Generator Overfill Protection is provided by the Steam Generator Water Level - High High interlock, P-14.
The P-14 interlock is actuated when the level in any SG exceeds the high high setpoint, and performs l
the following functions:
trips the main turbine; trips the Main l
Feedwater (MFH) pumps; initiates feedwater isolation; and shuts the MFH regulating valves and the feedwater bypass regulating valves.
These functions prevent any further addition of water to the SGs and excessive cooldown of the primary system.
The main turbine is tripped to prevent carryover of excessive moisture to the turbine, which could damage the turbine.
There are no Technical Specification requirements currently in place for the Steam Generator Overfill Protection, or more specifically, the Steam Generator Hi-H1 Level Trip.
The accident analysis in UFSAR Section 15.1, Increase in Heat Removal by the Secondary System, discusses the Steam Generator Hi-Hi Level Trip but does not credit this function in the safety analysis.
Requirements for the inclusion of this instrumentation and the associated trip function in the Technical Specifications originated with Generic Letter 89-19, " Safety Implications of Control Systems in LWR Nuclear Power Plants," dated September 29, 1989.
2)
Equations Describing the Overpower Delta T (OPDT) and Overtemperature Delta T (OTDT) Functions.
The OTDT trip function is provided to ensure the design limit Departure from Nucleate Boiling Ratio (DNBR) is met.
The OPDT trip function ensures that protection is provided to ensure the integrity of the fuel under possible overpower conditions.
Currently, OTDT and OPDT are continuously calculated by the Eagle 21 System as described in Technical Specifications 2.1.1.B.4a Note 1 and 2.1.1.B.5a Note 2.
An administrative error exists in Note 1 and Note 2 in that time constants are identified by the Greek letter Tau but with subscripts associated with the 7100 Protection System instead of the subscripts associated with Eagle 21.
The Eagle 21 system uses software that employs the correct equations for calculating OTDT and OPDT.
Revising these equations to be consistent with the Eagle 21 software will prevent confusion but will not change the way the plant is currently being operated.
ZNLD/2562/4 1
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C.
REQUESTED REVISION:
1)
Steam Generator Overf111 Protection This amendment includes additions to Technical Specification Tables 3.4-1 and 4.4-1 as well as the Bases for Section 3.4.
The Table 3.4-1 i
addition will add the following Limiting Conditions for Operation under a new category heading, "VI. Steam Generator Overfill Protection."
Number of Channels:
3 per S/G l
l Number of Channels to Trip:
2 per S/G Minimum Operable Channels:
2 per S/G 4
Minimum Degree of Redundancy:
1 per S/G Operator Action if requirements Maintain Hot Shutdown cannot be met Setpoints:
70% Narrow Range Footnotes (+) and ( m ) associated with Table 3.4-1 column headings will also be applicable to the new section "VI. Steam Generator Overfill j
Protection."
The double plus sign footnote (u) used in the Table 3.4-1 has been modified deleting reference to errors being specified in the " Channel Accuracies, Overall Channel Accuracies, and Setpoint Tolerances for B I and C Reactor Protection and Control Systems", August 30, 1971, denoting that the channel tolerances are now controlled in the " Zion NSSS Setpoint Evaluation, Protection System Channels, Eagle 21 Version".
i This change deletes reference to the 1971 setpoint study no longer used on these channels since the completion of the Eagle 21 upgrades on both Units 1 and 2.
In addition, the Zion NSSS Setpoint Evaluation has been revised to reflect the addition of the Steam Generator Overf111 Protection Setpoint. As such, the reference to the setpoint document has been specified as the " Zion NSSS Setpoint Evaluation, Protection System Channels Eagle 21 Version", Revision 2, March, 1993. A copy of the March 1993 setpoint document is included in Attachment E.
The tolerances and inst _rument channel setpoint errors for the Steam Generator Overfill Protection channels included in the March 1993 document have been developed using channel accuracy methodology j
consistent with that used to develop the April 1992 setpoint study.
Previous NRC approval of the April 1992 setpoint study methodology is documented in the staff's Safety Evaluation Report related to Zion i
Station Technical Specification amendment Nos. 139/128, dated June 26, i
1992.
Control of these tolerances and instrument channel setpoint errors will be as before, in that any revision would require a Technical Specification amendment to change the document referenced in the table.
ZNLD/2562/5
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The proposed change will also add the following to Table 4.4-1.
These additions will also be under a new category heading, "VI. Steam Generator Overfill Protection."
Channel Check:
S I
Channel Calibration:
R Channel Functional Test:
0 Addition of the new category heading "VI. Steam Generator Overf111 Protection" will require that the Table 4.4-1 category "Permissives:" be moved to the next page which is currently identified as " deleted."
The definitions of the surveillance frequency notation (S,M,R, and N.A.)
have been deleted. This surveillance frequency notation is defined in existing Table 1.2 of the Technical Specifications. As such, the change is administrative in nature.
Finally, the Bases in Section 3.4 will be amended to include the f
feedwater system isolation for the Steam Generator Overfill as a function of the Engineered Safety Feature (ESF) Instrumentation System.
2)
Equations Describing the Overpower Delta T (OPDT) and Overtemperature Delta T (OTDT) Functions This change will correct nomenclature errors associated with subscripts to the Greek letter Tau that identify time constants used by the Eagle 21 System in the calculation of OPDT and OTDT.
l The values assigned to the lag compensators on measured AT and measured T
are being relocated from the Technical Specifications to plant prokedures. The 10CFR50.59 process which governs changes to plant av procedures will assure that values used for lag compensators will i
maintain instrument response time within the assumptions used in the l
safety analyses of AT and T functions.
avg Technical Specification Bases Section 2.1 has been updated to note that the OTDT and OPDT functions include lag compenstation on measured AT and measured T and that these lag constants have been accounted for av l
inthesafetyan$lysisandprovideallowanceforRTDresponse I
characteristics. These statements have been added to ensure that, with the lag constants relocated from Technical Specifications, configuration management is maintained.
l l
The specific changes to the equations in Note 1 and Note 2 are identified in Attachment D which contains the changes marked up directly on Technical Specifications pages 10a, 10b, 10c and 10d.
ZNLD/2562/6
r The double plus sign footnote (+o) used in Table 3.1-1 has been modified deleting reference to errors being specified in the " Channel Accuracies, Overall Channel Accuracies, and Setpoint Tolerances for H I and C Reactor Protection and Control Systems", August 30, 1971, denoting that the channel tolerances are now controlled in the " Zion NSSS Setpoint Evaluation, Protection System Channels, Eagle 21 Version".
This change deletes reference to the 1971 setpoint study no longer used on these channels since the completion of the Eagle 21 upgrades on both Units 1 and 2.
In addition, the Zion NSSS Setpoint Evaluation has been revised to reflect the changes in the equations for the OPD1 and OTDT reactor trip functions.
Therefore, the reference to the setpoint document has been specified as the " Zion NSSS Setpoint Evaluation, Protection System Channels, Eagle 21 Version, Revision 2, March, 1993".
For the Westinghouse source range and intermediate range neutron flux channels, Revision 1 of the setpoint evaluation applies since it specifies the established tolerances for these channels. As such, reference to Revision 1 of the Zion NSSS Setpoint Evaluation has been retained for these channels.
As it applies to the changes in the equations describing the OPDT and OTDT functions, the March 1993 setpoint document only reflects changes to the equations; there are no changes to the related tolerances and instrument channel accuracies. Changes included in the March 1993 setpoint document related to Steam Generator Overfill Protection are discussed in Section C.1 above. A copy of the March 1993 setpoint document is included in Attachment E.
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t LICENSE AMENDMENT REQUEST NO. 93-03 I
D.
IMPACT OF THE PROPOSED CHANGE:
1)
Steam Generator Overf111 Protection The Steam Generator Overfill Protection System already exists and is in use at the Zion Nuclear Station. The procedures for this system are in place and the surveillance requirements proposed by this change are already being conducted. The tolerances and instrument channel accuracies which are referenced for these channels have been developed utilizing the methodology previously approved for this type of application at Zion.
Therefore, there is no impact resulting from this change.
2)
Equations Describing The Overpower Delta T (OPDT) and Overtemperature Delta T (OTDT) Functions Correction of the nomenclature error is an administrative change only l
since the software installed in the Eagle 21 system and procedures correctly reflect the calculations used for the OTDT and OPDT functions.
l The requirements for lag compensators on measured AT and measured T
will be removed from the Technical Specifications and relocated to i
pitStprocedures.
Exis':ing procedures adequately address the I
requirements for these lag compensators.
These procedures are subject to the change control provision specified in the Administrative Controls Section of Technical Specifications.
The requirements for the OTDT and OPDT functions to be OPERABLE will remain in Technical Specifications.
Actions and Surveillance Requirements relative to these functions will also remain in Technical Specifications.
The relocation of these lag compensator requirements is an administrative matter which would allow future changes to be made without a license amendment.
This would relieve both the NRC, and CECO of an unnecessary administrative burden.
For configuration management purposes, documentation has been added to the related Technical Specification Bases describing the lag 1
compenstation. An evaluation in accordance with 10CFR50.59 will be performed for changes to these lag compensation requirements.
E.
SCHEDULE REQUIREMENTS:
l
- 1) Steam Generator Overfill Protection l
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- 2) Equations Describing the Overpower Delta T (OPDT) and l
Overtemperature Delta T (OTDT) Functions 1
It is requested that this amendment be effective as of the date of its issuance, to be implemented within 30 days from the date of issuance.
ZNLD/2562/8
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ATTACHMENT B 1
EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION FOR c
PROPOSED CHANGES TO APPENDIX A TECHNICAL SPECIFICATIONS.0F
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FACILITY OPERATING LICENSES
5 LICENSE AMENDMENT REQUEST NO. 93-03 I
ZNLD/2562/9
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E' 1
PART 1 STEAM GENERATOR OVERFILL PROTECTION i
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EVALUATION OF SIGNIFICANT HisZARDS CONSIDERATION t
Commonwealth Edison has evaluated this proposed amendment and determined that it involves no significant hazards considerations. According to 10CFR50.92(c), a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:
1.
Involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated;
)
2.
Create the possibility of a new or different kind of accident from any previously analyzed; or, 3.
Involve a significant reduction in a margin of safety.
i The following evaluation is provided for the three categories of the significant hazards consideration standards:
l.
Does the change involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated?
The inclusion of requirements in Technical Specifications for the Steam Generator Overfill Protection System is not assumed in the init1ation of l
any analyzed event.
This function is not credited in the mitigation of i
any analyzed accident. The addition of requirements for the Steam Generator Overfill Protection System helps ensure that continuous addition of cold feedwater and carryover of excessive moisture to the turbine, is prevented. As such, equipment protection is provided by this function.
In addition, the consequences of an event occurring with the proposed change are the same as the consequences of an event occurring with the existing requirements.
Therefore, this change does not involve a significant increase in the probability or consequences of a previously evaluated accident.
2.
Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
The proposed change does not necessitate a physical alteration of the plant (no new or different type of equipment will be installed) or changes in parameters governing normal plant operation. The proposed change will not impose any different requirements.
Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
Does this change involve a significant reduction in a margin of safety?
j The proposed change does not involve any reduction in a margin of safety.
The function, operation and testing of the installed Steam i
Generator Overf111 System has not changed from that described in the UFSAR.
In addition, the proposed change simply formalizes the. existing design, operating and testing requirements in Technical Specifications.
As such, the change does not involve a significant reduction in a margin of safety.
ZNLD/2562/11
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r PART 2 l
1 TECHNICAL SPECIFICATION EQUATIONS DESCRIBING l
THE OVERPOWER DELTA T AND 0VERTEMPERATURE DELTA T FUNCTIONS.
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ZNLD/2562/12
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l EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION Commonwealth Edison has evaluated this proposed amendment and determined that it involves no significant hazards considerations. According to 10CFR50.92(c), a proposed amendment to an operating license involves no i
significant hazards consideration if operation of the facility in accordance l
with the proposed amendment would not:
t i
1.
Involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated; 2.
Create the possibility of a new different kind of accident from any previously analyzed; or 3.
Involve a significent reduction in a margin of safety.
The following evaluation is provided for the three categories of the significant hazards consideration standards:
1.
Does the change involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated?
The proposed change will not result in any hardware changes.
The OPDT and OTDT trip functions are not assumed in the initiation of any analyzed events.
These functions are assumed in the mitigation of accident or transient events. The change to correct the nomenclature used to describe the time constants in the OPDT and OTDT equations is administrative in nature since the equations which are currently implemented in the Eagle-21 software are correct and the change has no physical effect on the plant.
The removal of the lag compensator requirements for measured AT and measured T from the Technical SpecificationsdoesnotimpactOPDTandOTDfOPERABILITYrequirements.
Technical Specifications will continue to require the OPDT and OTDT functions to be OPERABLE. Action statements and surveillance requirements for these functions will also remain in Technical Specifications.
The lag compensator requirements are aden9ately addressev in existing plant procedures controlled by 10CFR50.59 and are subject to the change control provisions specified in the Administrative Controls Section of the Technical Specifications.
Therefore, this change is administrative in nature. As such, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
The proposed changes do not necessitate a physical alteration of the plant (no new or different type of equipment will be installed) or changes in parameters governing the normal plant operation.
The proposed changes will not impose any different requirements and adequate control of the information will be maintained.
Thus, these changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
ZNLD/2562/13
3.
Does this change involve a significant reduction in a margin of safety?
The proposed changes will not reduce a margin of safety because they have no impact on any safety analysis assumption.
The Technical Specifications continue to require the OPDT and OTDT functions to be OPEPABLE consistent with the Zion Station licensing and analysis basis.
Since any future changes to the relocated lag compensators of the OPDT and OTDT functions in the plant procedure will be evaluated per the requirements of 10CFR50.59, no reduction (significant or insignificant) in a margin of safety will be allowed.
Therefore, this change does not involve a significant reduction in a margin of safety.
ZNLD/2562/14
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ATTACHMENT C ENVIRONMENTAL ASSESSMENT FOR j
i PROPOSED CHANGES TO APPEFJIX A TECHNICAL SPECIFICATIONS OF FACILITY OPERATING LICENSES DPR-39 AND DPR-48.
LICENSE AMENDMENT REQUEST NO. 93-03 4
PART 1:
Steam Generator Overfill Protection l
l Part 2:
Technical Specification Equations Describing the Overpower Delta T (OPDT) and Overtemperature Delta T (OTDT) Functions i
ZNLD/2S62/15 i
6 ENVIRONMENTAL ASSESSMENT The changes proposed by this License Amendment Request have been evaluated against the criteria for and identification of licensing and regulatory actions requiring environmental assessment in accordance with 10CFR51.21.
It has been determined that the proposed changes meet the criteria for categorical exclusion as provided for under 10CFR51.22(c)(9). The following is a discussion of how the proposed changes meet the criteria for categorical exclusion:
Although the proposed changes involve changes to Limiting Safety System Settings, Limiting Conditions for Operation, Surveillance Requirements and associated Bases for various safety systems i
(1)
The proposed changes involve no significant hazards consideration as evaluated in Attachment B of this License Amendment Request; (ii) There is no significant increase in the amounts, and no significant change in the types, of any effluents that may be released off-site since the proposed changes do not affect the generation of any radioactive effluents nor do they affect any of-the permitted release paths; and i
(iii) There is no significant increase in individual or cumulative occupational radiation exposure associated with this proposed change.
9 Accordingly, the proposed change meets the eligibility criteria for l
categorical exclusion set forth in 10CFR51.22(c)(9).
Based on the aforementioned and pursuant to 10CFR51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment incorporating the proposed changes.
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ZNLD/2562/16
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