ML20072Q950
| ML20072Q950 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/31/1994 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20072Q953 | List: |
| References | |
| NUDOCS 9409120304 | |
| Download: ML20072Q950 (23) | |
Text
_ - _ _ _ _
Ststion Suppsrt Ospartmsnt 10 CFR 50.90
._y-PECO ENERGY ecco '"e'av coma "v Nuclear Group Headquanes 965 chesterbrook Boulevard Wayne, PA 190876691 August 31,1994 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:
Umerick Generating Station, Units 1 and 2 Technical Specifications Change Request Nos.
94-32-0, 94-36-0, 94 40-0, 94-42-0, 94-44-0 and 9445-0 Gentlemen:
PECO Energy Company is submitting Technical Specifications (TS) Change Request Nos.
94-32-0,94-36-0,94-40-0,94-424,94-44-0 and 9445-0 in accordance with 10 CFR 50.90, requesting amendments to the TS (i.e., Appendix A) of Operating License Nos. NPF-39 and NPF-SS for Limerick Generating Station, Units 1 and 2, respectively. The proposed TS Changes, which are consistent with the Improved Standard Technical Specifications (NUREG-1433),
involve the following:
94-32 0
' Relocation of Tutbine Overspeed Protection System Requirements' 94-36-0
' Relocation of Primary Containment Conductor Protection Devices Requirements" 94-40 4
'Feedwater/ Main Turbine Trip System Actuation Instrumentation Requirements
- 94-42-0
' Permit Operability of Low Pressure Coolant injection While Aligned to Shutdown Cooling" 94-44-0
' Remove Temperature Requirement for Operational Condition 5' 94-45-0
' Reduce Frequency of Altemate Decay Heat Demonstration
- Information supporting these TS Change Requests is contained in Attachment 1 to this letter, and the proposed replacement pages for the LGS, Units 1 and 2, TS are contained in. This information is being subm!tted under affirmation, and the required affidavit is enclosed.
We request that, if approved, the amendments to the LGS, Units 1 and 2, TS be issued prior to January 28,1995, and become effective immediately upon issuance.
O7d ql 9409120304 940831 tg PDR ADOCK 05000352
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P PDR
August 31,1994 j
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If you have any questions, please do not hesitate to contact us.
Very truly yours, j
dC.
,p, G. A. Hunger, Jr.,
Director - Licensing Attachtnents Enclosure ec:
T. T. Martin, Administrator, Region I, USNRC (w/ attachments, enclosure) i N. S. Perry, USNRC Senior Resident Inspector, LGS (w/ attachments, enclosure)
R. R. Janati, Director, PA Bureau of Radiation Protection, (w/ attachments, endosure) i i
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COMMONWEALTH OF PENNSYLVANIA l
1 SS.
COUNTY OF CHESTER i
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W. H. Smith, Ill, being first duly swom, deposes and says:
l That he is Vice President of PECO Energy Company, the Appilcant herein; that he has read the r
l following Technical Specifications Change Request Nos. 94-32 4, 94-36-0, 94-40 4, 94-42-0, 94-l 444, and 94-454 for Limerick Generating Station, Units 1 and 2, invoMng Relocation of Turbine Overspeed Protection System Requirements, Relocation of Primary Containment Conductor Protection Device Requirements, Feedwater/ Main Turbine Trip System Actuation Instrumentation l
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Requirements, Permit Operability of Low Pressure Coolant injection While Aligned to Shutdown Cooling, Remove Temperature Requirement for Operational Condition 5, and Reduce Frequency of Alternate Decay Heat Demonstration, respectively, and knows the contents thereof; and that l
l the statements and matters set forth therein are true and correct to the best of his knowledge, i
l Information, and belief.
Y
/
V Vice President l
Subscribed and n to i
l before me this day of 1994.
tw.
NotmalSeal
/y N
Eka A Santon,tbtary Psic Notary Public rregnn Tw..Chesta County MyCcmmis90n EoresJuly 10.1995
ATTACHMENT 1 UMERICK GENERATING STATION UNITS 1 AND 2 l
Docket Nos.
50-352 50-353 License Nos.
NPF-39 NPF-85 Section 1:
Technical Specifications Change Request No. 94-32-0
' Relocation of Turbine Overspeed Protection System Requirements" Section 2:
Technical Specifications Change Request No.94-360
' Relocation of Primary Containment Conductor Protection Device Requirements' Section 3:
Technical Specifications Change Request No. 94-40-0
'Feedwater/ Main Turbine Trip System Actuation Instrumentation Requirements
- Section 4:
Technical Specifications Change Request No. 94-42-0 l
" Permit Operability of Low Pressure Coolant injection While Aligned to Shutdown Cooling' I
l Section 5:
Technical Specifications Change Request No. 94-44-0
' Remove Temperature Requirement for Operational Condition 5' Section 6:
Technical Specifications Change Request No. 94-45-0
' Reduce Frequency of Alternate Decay Host Demonstration' Supporting information for Changes - 19 pages l
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SECTION 1:
- RELOCATION OF TURBINE OVERSPEED PROTECTION SYSTEM REQUIREMENTS' (TSCR 94-32-0)
PECO Energy Company, Ucensee under Facility Operating License Nos. NPF-39 and NPF-85 for Umerick Generating Station, Units 1 and 2, respectively, requests that the Technical Specifications (TS) contained in Appendix A to the Operating Licenses be anwnded as proposed herein, to relocate the requirements of TS 3/4.3.8 ' Turbine Overspeed Protection System." This proposed TS change is consistent with criteria delineated in the improved Standard TS (i.e.,
NUREG-1433, " Standard Trchnical Specifications, General Electric Plants BWR/4," dated September 28,1992). The proposed changes to the TS are indicated by a vertical bar in the margin of TS pages x,3/4 3-110, and Bases page B 3/4 3-7 for Units 1 and 2. The TS pages showing the proposed change are contained in Attachment 2.
4 We request that, if approved, the TS change proposed herein by issued by January 28,1995, i
and become effective immediately upon issuance of the amendment.
i This TS Change Request provides a discussion and description of the proposed TS change, a safety assessment of the proposed TS change, information supporting a finding of No Significant Hazards Consideration, and information Supporting an Environmental Assessment.
Discussion and Descriotion of the Proposed Chanae
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i This TS Change Request will relocate the requirements of TS Section 3/4.3.8 " Turbine Ove speed Protection System' to the Updated Final Safety Analysis Report (UFSAR) and other plant procedures. The method of performing surveillance requirements will be adequately described in plant procedures. The proposed change will allow future administrative control of changes of these requirements without processing a license amendment.
Safety Assessme,n.!!
l This change will relocate the TS requirements to the UFSAR and other PECO controlled r
documents. All future changes to the UFSAR and these controlled documents are subject to the 1
change control process in the Administrative Controls Section of the LGS TS Section 6.0 including the provisions of 10 CFR 50.59.
The LGS ' Turbine Overspeed Protection System" protects the Turbine Generator against overspeed due to failure of the speed control system. The Turbine Generator is not a safety related system, and the Turbine Overspeed Protection System is not used for, nor capable of, detecting an abnormal degradation of a reactor coolant pressure boundary, monitoring a process variable that is an initial condition of a DBA, or being part to the success path that functions or actuates to mitigate a DBA, Based on the above criteria the loss of the Turbine Overspeed Protection System would be a non-significant risk contributor to core damage frequency and offsite releases. The proposed change is consistent with the BWR improved Standard Technical Specifications (NUREG-1433).
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Information Sucoortina a Findina of No Slanificant Hazards Consideration We have concluded that the proposed change to the Limerick Generating Station (LGS), Unit 1 and Unit 2 Technical Specifications (TS), which will relocate requirements from TS to other PECO controtted documents, does 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 crocosed TS chanae does not involve a slanificant increase in the j
orobability or consecuences of an accident oreviousiv e/aluated.
The proposed change relocates requirements from the TS, to licensee controlled documents. The licensee controlled documents containing the relocated requirements will be maintained using the provisions of 10 CFR 50.59 and are j
subject to the change control process in the Administrative Controls Section 6.0 of the TS. Since changes to licensee controlled documents will be evaluated i
per 10 CFR 50.59, no increase (significant or insignificant) in the probabHity or l
consequences of an accident previously evaluated wHi be allowed. Therefore, this change will not involve a significant increase in the probablity or consequences of an accidnt previously evaluated.
2.
The orooosed TS chanap_does not create the oossibility of a new or different kind of accident from any accident oreviousiv evaluated.
l This change relocates requirements to licensee controlled documents. This j
change w!!! not alter the plant configuration (no new or different type of equipment will be installed) or make changes in methods goveming normal i
plant operation. This change will not impose different requirements and adequate control of information will be maintained. This change wHI not alter assumptions made in the safety analysis and licensing basis. Therefore, this
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change will not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
The oronosed TS chance does not involve a sianificant reduction in a marain of safety.
l This change relocates requirements from the TS to licensee controlled documents. This change will not reduce a margin of safety since it has no l
Impact on any safety analysis assumptions. In addition, the requirements to be l
transferred from the TS to licensee controlled documents are the same as the existing Technical Specifications. Since any future changes to these licensee controlled documents will be evaluated per the requirements of 10 CFR 50.59, no reduction (significant or insignificant) in margin of safety wul be allowed.
Therefore, this change will not involve a significarst reduction in a margin of safety.
l The existing requirements for NRC review and approval of revisions, in accordance with 10 CFR 50.59, to these details and requirements proposed for relocation, does not have a specific margin of safety upon which to evaluate.
l However, since the proposed change is consistent with the BWR improved Standard Technical Specifications (NUREG-1433 approved by the NRC Staff) and the change controls for proposed relocated detals and requirements provide an equivalent level of regulatory authority, revising the TS to reflect the approved level of detaB and requirements ensures no reduction to the margin of safety.
Page 3 Informatlan Sunrvvtina an Environmental Aseaesment An Environmental Assessment is not required for the Technical Specifications change proposed by this Change Request because the requested change to the Limerick Generating Station, Units 1 and 2, TS conform to the criteria for " actions eligible for categorical exclusion,' as specified in l
10CFR51.22(c)(9). The requested change will have no impact on the environment. The l
proposed TS change does not involve a Significant Hazards Consideration as dh w in the preceding safety assessment section. The proposed change does not involve a significant change in the types or significant increase in the amounts of any edluent that may be released l
offsite. In addition, the proposed TS change does not involve a significant increase in individual or cumulative occupational radiation exposure.
Conclusion l
The Plant Operations Review Committee and the Nuclear Review Board have reviewed this proposed change to the Limerick Generating Station, Units 1 and 2, Technical Specifications, and have concluded that it does not involve an unreviewed safety question.
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,---n Page 4 SECTION 2:
' RELOCATION OF PRIMARY CONTAINMENT CONDUCTOR PROTECTION I
DEVICE REQUIREMENTS * (TSCR 94-36 0)
PECO Energy Company, licensee under Faculty Operating License Nos. NPF-39 and NPF-85 for Umerick Generating Station (LGS), Units 1 and 2, requests that the Technical Specifications (TS) contained in Appendix A to the Operating Licenses be amended, as proposed herein, to relocate the requirements of TS 3/4.8.4.1 ' Primary Containment Penetration Conductor Overcurrent Protective Devices." This proposed TS change is consistent with criteria delineated in the improved Standard TS (i.e., NUREG-1433, " Standard Technical Specifications, General Electric Plants, BWR/4," dated September 28,1992). The proposed change to the TS are indicated by a vertical bar in the margin of TS pages xv. 3/4 8-21, and Bases page B 3/4 8-3 for Units 1 and 2.
The TS pages, showing the proposed change is contained in Attachment 2.
We request that, if approved, the TS change proposed herein be issued by January 28,1995, and become effective immediately upon issuance of the amendment.
This TS Change Request provides a discussion and deecription of the proposed TS change, a safety assessment of the proposed TS change, information supporting a finding of No Significant I
Hazards Consideration, and information supporting an Environmental Assessment Discussion and Descriotion of the Prooosed Chanae This TS Change Request will relocate the requirements of TS Section 3/4.8.4.1 " Primary Containment Penetration Overcurrent Protective Device,' to the Updated Final Safety A".alysis Report (UFSAR) and plant procedures. The manner of performing surveHiance requirernents is j
currently described in plant procedures. The proposed change wHl allow future administrative control of changes of these requirements without processing a license amendment.
i Safety Assessme.n.t n
The change will relocate the TS requirements to the UFSAR and other PECO controlled documents. All future changes to the UFSAR and these controlled documents are subject to the change control process in the Administrative Controls Section of the LGS TS Section 6.0 including the provisions of 10 CFR 50.59. The proposed change is consistent with the BWR improved Standard Technical Specifications (NUREG-1433).
The LGS ' Primary Containment Penetration Conductor Overcurrent Protective Devices" TS Section protects penetrations and penetration conductors by either de-energizing circuits not required during reactor operation or demonstrating the OPERABluTY of primary and backup overcurrent protection circuit lareakers through periodic surveHlance. The overcurrent protective devices are not used for, nor capable of detecting a significant abnormal degradation of the reactor coolant pressure boundary. The devices are not process variables or do not monitor a l
process variable that is an initial condition of a DBA or Transient analysis that either assumes the l
fauure of or presents a challenge to the integrity of a fission product barrier. The devices are not part of the primary success path that functions or actuates to mitigate a DBA or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
The devices are non-significant risk contributors to core damage frequency and offsite release.
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Information Suocortina a Findina of No Sianificant Hazards Consideration We have concluded that the proposed change to the Limerick Generating Station (LGS), Unit 1 and Unit 2, Technical Specifications (TS), which wHI relocate requirements from TS to other PECO controlled documents, does 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 orooosed TS chance does not involve a slanificant increase in the orobabRity or
.ppnsecuences of an accident oreviousiv evaluated.
This proposed change relocates requirements from the TS to licensee controlled 4
documents. The licensee controlled documents containing the relocated requirements wUI be maintained using the provisions of 10 CFR 50.59 and are subject to the change control process in the Administrative Controls Section 6.0 of the TS. Since changes to these licensee controlled documents will be evaluated per 10 CFR 50.59, no increase (significant or insignificant) in the probability or consequences of an accident previously evaluated will be allowed. Therefore, this change wBl not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
The orocosed TS chanae does not create the oossibility of a new or different kind of accident from any accident oreviousiv evaluated.
This change relocates requirements to licensee controlled documents. This change will not alter the plant configuration (no new or different type of equipment will be installed) or make changes in methods governing plant operation. This change will not impose different requirements and adequate control of information will be maintained. This change will not alter assumptions made in the safety analysis and licensing basis.
Therefore, this change will not create the possibHity of a new or different kind of accident from any accident previously evaluated.
[
3.
The crocosed TS chanae does not involve a slanificant reduction in a maroin of safety.
This change relocates requirements from the TS to licensee controlled documents. This change will not reduce a margin of safety since it has no impact on any safety analysis assumptions. In addition, the requirements to be transferred from the TS to the licensee controlled documents are the same as the existing TS. Since any future changes to these licensee controlled documents will be evaluated per the requiremer;ts of 10 CFR 50.59, no reduction (significant or insignificant) in margin of safety will be allowed.
Therefore, this change will not involve a significant reduction in a margin of safety.
The existing requirements for NRC review and approval of revisions, in accordance with 10 CFR 50.59, to these details and requ'rements proposed for relocation, does not have a specific margin of safety upon which to evaluate. However, since the proposed change is consistent with the BWR Improved Standard TS (NUREG-1433 approved by the NRC Staff) and the change controls for proposed relocated details and requirements provide an equivalent level of regulatory authority, revising the TS to reflect the approved level of detail and requirements ensures no reduction to the margin of safety.
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information Succodino an Environmental Assessment An Environmental Assessment is not required for the Technical Specifications change proposed by this Change Request because the requested change to the Limerick Generating Station, Units l
1 and 2, TS conforms to the criteria for " actions eligible for categorical exclusion," as specified in 10CFR51.22(c)(9). The requested change will have no impact on the environment. The proposed TS changt does not involve a Significant Hazards Consideration as discussed in the preceding safety asrA asment section. The proposed change does not involve a significant change in the types or significant increase in the amounts of any effluent that may be released offsite. In addition, the proposed TS change does not involve a significant increase in individual or cumulative occupational radiation exposure.
Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed this proposed change to the Umerick Generating Station, Units 1 and 2, Technical Spec'fications, and have concluded that it does not involve an unreviewed safety question.
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SECTION 3:
"FEEDWATER/ MAIN TURBINE TRIP SYSTEM ACTUATION INSTRUMENTATION REQUIREMENTS" (TSCR 94-40 0)
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PECO Energy Company, Licensee under Fac8ky Operating License Nos. NPF-39 and NPF-85 for..
j Limerick Generating Station, Units 1 and 2 respectively, requests that the Technical Specifications (TS) contained in Appendix A to the Operating Licenses be amended as proposed j
herein, to permit the operab8ky requirement for the Feedwater/ Main Turbine Trip System i
Actuation Instrumentation to be Operational Condition (OPCON) 1.p._25% Rated Thermal Power 2
(RTP).
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This proposed TS change is consistent with criteria delineated in the improved Standard TS (i.e.,
- Standard Technical Specifications, General Electric Plants, BWR/4,* dated September 28,1992). The proposed changes to the TS are indicated by a vertical bar in the i
margin of TS pages 3/4 3-113 and 3/4 3-115 for Units 1 and 2. The TS pages showing the proposed change are contained in Attachment 2.
j We request that, if approved, the TS change proposed herein be issued by January 28,1995, j-and become effective immediately upon issuance of the amendment.
1 This TS Change Request provides a discussion and deas; peon of the proposed TS change, a i
safety annaaement of the proposed TS change, infomation supporting a finding of No Significant Hazards Consideration, and information supporting an Environmental Assessment
.Qigussion and Descriotion of the Prooosed Chanaes l
The feedwater/ main turbine trip system actuation instrumentation, reactor vessel water level-high level 8, is provided to initiate action of the feedwater/ main turbine trip system in the event i
of faBure of the feedwater controller under maximum demand. Operabuky requirements for this j
instrumentation require that k is operable in OPCON 1. The proposed T.S. change would permit the Level 8, Main / Reactor Feed Pump (RFP) Turbine trip logic operab8lty verification testing up
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to 25% Rated Thermal Power (RTP). Additionally, equipment problems previously identified that render the Level 8 Main /RFP Turbine trip logic inoperable would no longer be an OPCON a
Change restraint. Plant Startup procedures would be revised to ensure the testing is completed during power ascension to 25% RTP. The change of operability requirements in Technical Specifications makes this section consistent with NUREG-1433 (Improved Standard Technical l
Specification for General Electric Plants, BWR/4) Revision 0.
Safety Assessment j
The feedwater/ main turbine trip system actuation instrumentation, Reactor Vessel Water Level -
High Level 8, is provided to initiate action of the Main /RFP Turbine trip system in the event of j
failure of the feedwater controlier under maximum demand. This system is designed for -
protection of the Main Turbine and RFP Turbines from damage due to water carry-over. The Main Turbine and RFP Turbines do not serve a safety function and are considered Balance of Plant Equipmert Also, the bases for Average Planar Linear Heat Generation Rate (APLHGR) and Minimum Critical Power Ratio (MCPR), and the Core Operating Limits Report were reviewed and show that a sufficient margin to core safety limits exist below 25% RTP, so fuel integrity I
limits are not violated. This change is consistent with NUREG-1433 (Improved Standad Technical Specification for General Electric Plants, BWR/4) Revision O.
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trdormatinn Snruvutina a Findina of No Slanificant Harmeds Maration l
t We have concluded that the proposed change to the Limerick Generating Station (LGS), Units 1 i
and 2, Technical Specifications (TS) that revise TS Requirement TS 3/4.3.9 to change the operability requirement for the feedwater/ main turbine trip instrumentation, Reactor Vessel Water i
Level - High Level 8, from OPCON 1 to OPCON 12 25% RTP does not involve a Significant i
Hazards Consideration. In support of this determination, an evaluation of each of the three (3) standards set forth in 10CFR50.92 is provided below.
1.
The ornnnead Technical Soecificatinns (TS) chanas does not involve a slanificant j
incraana in the ornhahuitV or conSeouences of an accident orevinnalV -M**d 1
For the proposed TS change, in the event of a Reactor Vessel Water Level - High Level
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8 transient, operator action per existing plant procedures would terminate the event and prevent damage to the Main /RFP Turbine due to water carry over. The Main /RFP Turbine do not serve a safety function, also at <25% RTP a Level 8 transient event will l
not cause a reactor scram. An analysis of information in the bases for APLHGR and MCPR has shown that a sufficient margin to core safety limits exist, so fusi integrity j
levels are not violated. Therefore, the proposed TS change does not involve an increase j
in the probability or consequences of an accident previously evaluated.
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The orooosed TS chanae does not create the oossibility of a new or different kind of accident from any accident oreviousiv evaluated.
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Should the feedwater/ main turbine trip system, Reactor Vessel Water Level-High Level 8, not actuate in OPCON 1 at <25% RTP, operator action per existing plant startup procedures would protect the Main /RFP turbines. If operator action is not performed, damage to Balance of Plant, non-safety related equipment could occur. High Reactor Vessel Water Level is not a concern for reactor core safety at <25*, RTP. Therefore, the proposed TS change does not create the possibimy nr a w ::, different kind of j
accident from any accident previously evaluated.
i 3.
The orocosed TS chanae does not involve a sianificant reduction in a maroin of safety.
1 The proposed TS change, which revises the feedwater/ main turbine trip system j
actuation instrumentation, Reactor Vessel Water Level - High Level 8, operability requirements, does not affect the TS bases. The trips are designed to protect Balance d Plant Equipment at all Rated Power Levels. The Reactor Vessel Water Level - High Level 8 trips also protects fuel integrity at >25% RTP. Therefore, the proposed TS j
change to the operability requirements for the feedwater/ main turbine trip system actuation instrumentation does not involve a reduction in a margin of safety.
l Information Sunoortina an Environmental Assessment i
An Environmental Assessment is not required for the Technical Specifications change proposed j
by this Change Request because the requested change to the Limerick Generating Station, Units 1 and 2, TS conform to the criteria for " actions eligible for categorical exclusion," as specified in i
1 10CFR51.22(c)(9). The requested change will have no impact on the environment. The l
proposed TS change does not involve a Signifoant Hazards Consideration as discussed in the j
preceding safety assessment section. The proposed change does not involve a significant change in the types or significant increase in the amounts of any effluent that may be released 4
i offsite. In addition, the proposed TS change does not involve a significant increase in individual
]
or cumulative occupational radiation exposure.
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Conclusion The Plant Operations Review Commktee and the Nuclear Review Board have reviewed this proposed change to the Limerick Generating Station, Unks 1 and 2. Technical SpecWications, and have concluded that k does not involve an unreviewed safety question.
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I Page 10 SECTION 4:
' PERMIT OPERABluTY OF LOW PRESSURE COOLANT INJECTION WHILE ALIGNED TO SHUTDOWN COOUNG' (TSCR 94-42-0)
PECO Energy Company, licensee under Facuity Operating Ucense Nos. NPF-39 and NPF 85 for Umerick Generating Station (LGS), Units 1 and 2, requests that the Technical Specifications (TS) contained in Appendix A to the Operating License be amended, as proposed herein, to permit the operabuity of one Low Pressure Coolant injection (LPCI) subsystem of Residual Heat Removal (RHR) while the subsystem is aligned and operating in the Shutdown Cooling Mode during Operational Conditions (OPCONs) 4 and 5.
j This proposed TS change is consistent with criteria delineated in the Irnproved Standard TS (i.e.,
NUREG-1433, " Standard Technical Specifications, Otn ral Electric Plarus, BWR/4," dated September 28,1992). The proposed change to TS c indicated by a vertical bar in the margin of TS pages 3/4 54 and 3/4 5-7 for Units 1 and 2. ine TS pages showing the proposed changes are contained in Attachment 2.
We request that, if approved, the TS change proposed herein be issued by January 28,1995, and become effective immediately upon issuance of the amendment.
This TS Change Request provides a discussion and description of the proposed TS change, a safety assessment of the proposed TS change, information supporting a finding of No Significant Hazards Consideration, and information supporting an Environmental Assessment.
Discussion and Descriotion of the Prooosed Chanaes This TS Change Request would add a note stating, "One LPCI subsystem may be considered OPE!MBLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable." This change is consistent with NUREG - 1433
' Standard Technical Specifications."
LGS T3 Surveillance Requirement 3.5.2.b. and Surveillance Requirement 4.5.2.1 will be changed to add the note describing the LPCI operability.
Safety Assessment This proposed change is administrative in nature, in that there will be no physical changos made to plant equipment nor the method of their operation that would result in an unanalyzed condition. The change will increase the time required to obtain rated LPCI conditions due to the manual alignment of the subsystem; however, the reactor operator has sufficient time during OPCONs 4 and 5 to perform the manual LPCI alignment, from the Main Control Room, since the reactor decay heat loads and temperatures are significantly reduced from those parameters analyzed for OPCON 1. An integrated system response time is an ECCS operabRity requirement, which is currently 40 seconds for LPCI. This le based on OPCON 1 Design Basis Accident (DBA) Loss of Coolant Accident (LOCA) requirements. Additionally, the LGS Updated Final Safety Analysis Report (UFSAR) Section 6.3 states based on the conditions of OPCON 1, two loops of Core Spray and one loop of LPCI are the minimum required low pressure ECCS.
When the unit is in OPCON 4 or 5, cold shutdown has already been obtained, eliminating the high temperatures of OPCON 1. The cooler reactor inventory eliminates the loss of coolant potential from depressurization and the inventory flashing to steam. Therefore, whue in OPCONs 4 and 5, the remaining methods of inventory loss are bou off and draindown, which are also reduced. Sound engineering judgment indicates there is sufficient time to perform the manual realignment.
Page 11 in addition to the OPCON 1 LOCA analysis, shutdown cooling operations have been an initiator of many industry events where primary coolant inventory was lost. The consequences of this accident are decreased since the loop of RHR must be realigned for LPCI to mitigate the event, and the realignment, in itself, will terminate the drain down event. The proposed change is consistent with the BWR Standard Technical Specifications (NUREG-1433).
Information Suncortina a Findina of No Slanificant Hazards Consideration We have concluded that the proposed change to the Limerick Generating Station (LGS), Unit 1 and Unit 2, Technical Specifications (TS), which will permit the operability of one Low Pressure Coolant injection (LPCI) subsystem of Residual Heat Removal (RHR), while aligned to decay heat removal during OPCONs 4 and 5, does 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 orocosed Technical Soecifications chanae does not involve a slanificant increase in the orobability or consecuences of an accident oreviously evaluated.
The LPCI mode of RHR is an accident mitigator, not an initiator. Currently, the LPCI mode of RHR is an automatic Emergency Core Cooling System (ECCS) function during OPCONs 4 and 5. However, shatdown cooling has been an accident initiator in many industry events. Reliance on this loop of RHR for LPCI does not increase the probability of an accident in shutdown cooling, but the alignment for LPCI will, in itself, terminate the draindown event by ex' ting the shutdown cooling mode. This proposed change will permit the operabHity of one LPCI subsystem whue the components of that subsystem are aligned and operating in the Shutdown Cooling mode of RHR, orovided all other components of that subsystem are operable and can be manually realigned from the Main Control Room, if required. The required number of operable Emergency Core Cooling Systems (ECCS) remains unchanged, thus maintaining the TS required subsystem redundency (TS Section 3.5.2 requires two operable ECCS subsystems with exception for Reactor level). With this change, the required number of LPCI subsystems are capable of performing their function of limiting and or mitigat!ng the consequences of an accident, by allowing the manual alignment of one LPCI subsystem, during OPCONs 4 and 5. This allowance is justified since the change only applies to OPCONs 4 and 5, when reactor temperature, and associated heat loads are sufficiently low to provide the operator sufficient time to perform the manual realignment, from the Main Control Room, of the RHR pump suction valves and restart of the pump following LPCI injection conditions. Similar allowances for LPCI are currently permitted during OPCON 3, since the decay heat loads are significantly reduced compared to OPCON 1, which is the mode of operation under which ECCS capability is analyzed (Section 6.3 of the LGS Updated Final Safety Analysis Report (UFSAR)). The change will not increase the probabuity of occurrence or consequences of a malfunction of equipment since there will be no physical changes made to plant equipment nor the method of their operation that would result in an unanalyzed condition. PECO Energy evaluated the need for manual realignment of the pump minimum flow path since operating in Shutdown Cooling typically results in the isolation of the pump minimum flow path to prevent inadvertent dralning of the reactor vessel. The associated pump is still operable since this change is limited to OPCONs 4 and 5, when reactor pressure is sufficiently low to allow immediate injection to the reactor vessel without a minimum flow path. In situations, whue in OPCON 4, where reactor pressure may not be sufficiently low to allow injection, the RHR system will not be aligned for Shutdown Cooling, since the reactor vessel pressure will be greater than the RHR ' cut-in" permissive pressure. In addition, Administrative Controls are currently in place to realign RHR to the LPCI mode for planned pressure increases. Finally, this change is consistent with NUREG - 1433
I I
(
Page 12 1
" Standard Technical Specifications." Therefore, these changes wul not involve a significant increase in the probabilty or consequences of an accident previously evaluated.
2.
The si.- mad TS ciwnae does not crmra the r"Ov of a new or different idnd of accident from any accident oreviously evaluated.
The LPCI mode of RHR is an accident mitigator, not an initiator. This change wEl not reduce the number d required ECCS during OPCONs 4 and 5. This change wil permit j
the operabBky of one LPCI subsystem while the components of that subsystem are aligned and operating in the Shutdown Cooling mode of RHR. The change does not i
alter current methods of plant operation nor does the change make a physical change to plant equipment resulting in an unanalyzed malfunction of equipment Therefore, this change wlN not create the possibRity of a new or different kind of accident from any accidant previously evaluated.
3.
The ornrwad TS chance does not involve a alonht reduction in a margin of safety.
l The basis of TS Section 3.5.2 is to ensure sufficient ECCS capacity to maintain core cooling in OPCONs 4 and 5. This proposed change does not affect the required number of ECCS during OPCONs 4 and 5; therefore, adequate capsbuky through subsystem redundancy is maintained. The amount of time required to obtain rated LPCI conditions is increased due to the manual realignment, from the Main Control Room, of i
the suction valves and restart of the RHR pump following LPCI injection conditions. This change is in conformance with the current TS bases, since the operator has sufficient j
time to perform the rnanual realignment, during OPCONs 4 and 5, ensudng sufficient ECCS capability to maintain core coverage. In addklon, NUREG - 1433 BASES states, j
in part, "One LPCI subsystem may be aligned for decay heat removal and considered OPERABLE for the ECCS function, if it can be manually realigned (remote or local) to
{
the LPCI mode and is not otherwise inoperable Because of low pressure and low.
temperature conditions in MODES 4 and 5, sufficient time wil be avalable to manually align and initiate LPCI subsystem operation to provide core cooling prior to postulated fuel uncover." Therefore this change will not involve a signdicant reduction in a margin of safety; j
information Supporting an Environmental Assessment An Environmental Assessment is not required for the TS change proposed by this Change Request because the requested change to the Limerick Generating Station, Units 1 and 2, TS conform to the criteria for ' actions eligible for categorical exclusion,' as specified in 10CFR51.22(c)(9). The requested change will have no impact on the environment. The proposed TS change does not involve a Significant Hazards Consideration as discussed in the preceding safety assessment section. The proposed change does not involve a significant change in the types or significant increase in the amounts of any ofRuent that may be released off site. In addition, the proposed TS change does not involve a significant increase in individual or cumulative occupational radiation exposure.
Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed this proposed change to the Limerick Generating Station, Units 1 and 2, TS, and have concluded that it does not involve an unreviewed safety question.
Page 13 SECTION 5:
" REMOVE TEMPERATURE REQUIREMENT FOR OPERATIONAL CONDITION 5" (TSCR 94-44-0)
PECO Energy Company, Ucensee under Facility Operating Ucense Nos. NPF-39 and NPF-85 for Umerick Generating Station, Units 1 and 2, respectively, requests that the Technical Specifications (TS) contained in Appendix A to the Operating Ucenses be amended as proposed herein, to revise TS Table 1.2 and TS Bases 3/4.9.11 to remove the average reactor coolant temperature requirement in Operational Condition (OPCON) 5, Refueling. This proposed TS change is consistent with criteria delineated in the improved Standard TS (i.e., NUREG-1433,
" Standard Technical Specifications, General Electric Plants, BWR/4," dated September 28,1992).
The proposed change to the TS is indicated by a vertical bar in the margin of TS page 1-10 and TS Bases page B 3/4 9-2 for Units 1 and 2. The TS pages and TS Bases pages showing the proposed change are contained in Attachment 2.
We request that, if approved, the TS change proposed herein be issued by January 28,1995, and become effective immediately upon issuance of the amendment.
This TS Change Request provides a discussion and description of the proposed TS change, a safety assessment of the proposed TS change, information supporting a finding of No Significant Hazards Consideration, and Information Supporting an Environmental Assessment.
Discussion and Descriotion of the Prooosed Chance 1
The proposed Technical Specifications (TS) Change Request involves the change of Umerick Generating Station Units 1 and 2, TS Table 1.2 and TS Bases 3/4.9.11 to remove the average reactor coolant temperature requirement in Operational Condition (OPCON) 5, Refueling.
The average reactor coolant temperature requirement in OPCON 5 is proposed to change from
. 140*F to 'N/A' in the definition of OPCON 5 shown in TS Table 1.2. This change is consistent with the requirements of the improved Standard Technical Specifications, NUREG-1433, issued September 28,1992. This change to the TS Table 1.2. " Operational Conditions", eliminates the confusion as to which OPCON is applicable if the reactor coolant temperature exceeds 140*F with the reactor pressure vessel head removed. Currently, a temperature of greater than 140*F implies that the Unit is no longer in OPCON 5, however, the Unit is clearly not in OPCON 4, Cold Shutdown. In conjunction with this change, TS Bases 3/4.9.11
- Residual Heat Removal and Coolant Circulation," wul be revised to eliminate the reference to the OPCON 5 temperature requirement of 140*F. LGS wiu maintain the reactor coolant temperature below 140*F in accordance with station procedures. Therefore, the potential to remove decay heat will be maintained and the 140*F temperature wHl remain in the bases for TS 3/4.9.11. A change to the 140*F temperature in the future would stul require Plant Operations Review Committee (PORC) approval of a Safety Evaluation and would only be performed on a case by case basis.
t The elimination of the temperature requirement in OPCON 5 was rev!ewed for potential effect on reactor coolant system materials. This proposed TS change does not result in system temperature and pressure changes not previously analyzed. There is no effect on the material fracture toughness analysis or reduction in the protection against non-ductHe faHure. The reactor coolant system temperature and pressure are still restricted per TS Section 3/4.4.6.
The potential increased temperature effects were also evaluated for adequate shutdown margin, and it was determined that the potential increase in temperature between 140*F and 200*F to stay below OPCON 4, would have a negligible, however conservative effect on shutdown margin.
Page 14 i
Based on the above discussion it is concluded that a temperature requirement of 140*F for OPCON 5, Refueling, is not required provided that all required TS actions and procedural controls are followed. Therefore, we propose that TS Table 1.2 and TS Bases 3/4.9.11 be changed to reflect the removal of temperature requirement in OPCON 5. Refueling. This proposed change is consistent with the requirements in the improved Standard Technical Specifications, NUREG-1433, issued September 28,1993.
Safety Assessment The proposed TS change is in accordance with the requirements of the imp oved Standard Technical Specifications, NUREG-1433, issued September 28,1992, and does not involve a physical change in the configuration or operation of any systems important to safety. The elimination of a temperature requirement from the definition of Operational Condition (OPCON) 5, Refueling, does not result in reactor coolant system temperature and pressure changes, or reactivity changes not previously arnlyzed. The reactor pressure vessel wHI stil be restricted to the temperature and pressure limits of TS Section 3/4.4.6 which includes heatup/cooldown rates and minimum boltup limits.
The actual coolant temperature of 140*F will be administratively controlled by station procedures, to maintain the capability to remove decay heat. The potential increase in temperature between 140*F and 200*F to stay below OPCON 4, Cold Shutdown, would have a negligible, however conservative effect on shutdown margin which will improve due to the change in moderator density.
The proposed TS change does not affect existing accident analyses or design assumptions, nor does it impact any safety limits of the plant.
Information Sucoortina a Findina of No Sionificant Hazards Consideration We have concluded that the proposed change to the Umerick Generating Station (LGS), Units 1 and 2, Technical Specifications (TS) which will remove the average reactor coolant temperature requirement in Operational Condition (OPCON 5) Refueling, does 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 orocosed Technical Soecifications (TS) chanae does not involve a sionificant increase in the orobabilltv or consecuences of an accident oreviousiv evaluated.
The proposed TS change does not involve a physical change in the configuration of any systems important to safety. The elimination of a temperature requirement from the definition of OPCON 5 was reviewed for potential effect on reactor coolant system materials and for potential effect on reactMty. This TS change does not result in system temperature and pressure change or reactivity changes not previously analyzed. The reactor pressure j
vessel will still be restricted to the temperature and pressure limits of TS Section 3/4.4.6 which includes heatup/cooldown rates and minimum boltup limits. The j
reactor pressure vessel temperature and pressure limits wHI stHI ensure proper protection of the reactor coolant system materials. Therefore, this TS change does not increase the probability or consequences of an accident previously evaluated.
)
l Page 15 l
l 2.
The oronosed TS chanae does not create the ocasibilty of a new or different kind of accident from any accident oreviousiv evaluated.
The proposed TS change does not involve any physical changes in plant configuration, and reactor coolant system temperature and pressure are stBI restricted per TS Section 3/4.4.6. The decrease in moderator density corresponding to the potential change in temperature (i.e., above 140*F and below 200*F) would have a negligible, however conservative effect on shutdown margin. Therefore this TS change does not create the possiblity of a new or different kind of accident from any accident previously evaluated.
l 3.
The orocosed TS chanae does not involve a sianificant reduction in a marain of l
safety.
This proposed TS change does not change the reactor coolant system material restrictions as defined in TS Section 3/4.4.6. Therefore, the reactor pressure vessel will still be maintained under the current temperature and pressure restrictions as well as the current boltup limits.
The decrease in moderator density corresponding to the potential temperature j
change from 140*F to 200*F is insignificant and would afford approximately the l
same modemtor effect. Therefore, shutdown margin could only be improved (although marginally) at these evaluated temperatures. The actual coolant temperature will be administratively controlled to provide for personnel safety.
Therefore, this change will not involve a reduction in a margin of safety.
l l
Information Sucoortina an Environmental Assessment i
An Environmental Assessment is not required for the change proposed by this TS Change Request because the requested change to the LGS, Units 1 and 2, TS conform to the criteria for
" actions eligible for categorical exclusion," as specified in 10 CFR 51.22(c)(9). The requested l
change will have no impact on the environment. The proposed change does not involve a Significant Hazards Consideration as discussed in the preceding section. The proposed change does not involve a significant change in the types or significant increase in the amounts of any effluents that may be released offsite. In addition, the proposed change does not involve a significant increase in individual or cumulative occupational radiation exposure.
Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed this proposed change to the LGS, Units 1 and 2 TS and have concluded that it does not involve an l
unreviewed safety question, and will not endanger the health and safety of the public.
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Attachm3nt 1 Page 16 SECTION 6:
' REDUCE FREQUENCY OF ALTERNATE DECAY HEAT DEMONSTRATION" gTSCR 94-45-0)
PECO Energy Company, Licensee under Facility Operating License Nos. NPF 39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, respectively, requests that the Technical Specifications (TS) contained in Appendix A to the Operating Licenses be amended as proposed l
herein to modify TS Sections 3.4.9.1, 3.4.9.2, 3.9.11.1, 3.9.11.2, and the associated Bases Sections 3/4.4.9 and 3/4.4.11, to parmit the use of either an ' analytical approach" (i.e.,
)
calculation) or " demonstration" to ensure the operabliity of an attemate decay heat removal method, rather than the existing TS requirement which stipulates that operabuity of the altemate decay removal method be demonstrated. The proposed changes to the TS are indicated by a vertical bar in the margin of affected TS pages. The TS pages showing the proposed changes are contained in Attachment 2.
l We request that, if approved, the TS change proposed herein be issued by January 28,1995, j
and become effective immediately upon issuance of the~ amendments.
l This TS Change Request provides a discussion and description of the proposed TS changes, a safety assessment of the proposed TS change, information support!ng a finding of No Significant Hazards Consideration, and information supporting an Environmental Assessment.
Discussion and Descriotion of the ProDosed Chance l
l Currently, the Limerick Generating Station (LGS), Units 1 and 2, Technical Specifications (TS)
I Sections 3.4.9.1,3.4.9.2,3.9.11.1, and 3.9.11.2 require that operability of at least one (1) alternate decay heat removal method be " demonstrated" if the specified number of Residual Heat i
j Removal (RHR) Shutdown Cooling mode loops are not OPERABLE. This proposed TS change involves revising TS Sections 3.4.9.1,3.4.9.2,3.9.11.1,3.9.11.2, and the associated Bases Sections 3/4.4.9 and 3/4.9.11, to allow for the use of either an " analytical approach" (i.e.,
calculation) or " demonstration" as the means for ensuring operabilty of at least one (1) attemate decay heat removal method, rather than just ' demonstration" which is currently the case.
l Specifically, this proposed TS change involves revising ACTION 'a' in TS Sections 3.4.9.1, 3.4.9.2,3.9.11.1, and 3.9.11.2 by modifying the phrase, ".. demonstrate the operability of at least one alternate method....' to read, ".. verify the availability of at least one attemate method...," as it l
relates to the operability of an alternate decay heat removal method. This TS change also j
involves revising the associated Bases Sections 3/4.4.9 and 3/4.9.11 to clarify the intent of l
statement, "... verify the availability...,' to imply that the operability of an alternate decay heat l
removal method can be determined using either an ' analytical method" (i.e., calculation) or by l
" demonstration." In addition, this proposed TS change is consistent with criteria delineated in l
the improved Standard TS (i.e., NUREG-1433, " Standard Technical Specifications, General l
Electric Plants, BWR/4," dated September 28,1992).
l Safety Assessment Shutdown Cooling is a mode of operation of the Residual Heat Removal (RHR) system, and is designed to remove decay and sensible heat loads from the primary coolant system following a
)
reactor shutdown. The Shutdown Cooling mode of operation of the RHR system has the capability to remove these heat loads in order to facilitate refueling or maintenance activities, or for maintaining the reactor in a HOT SHUTDOWN condition. There are two (2) separate Shutdown Cooling loops, which are manually controlled by Operations personnel from the Main Control Room (MCR). Each loop concists of two (2) RHR pumps, and one (1) RHR heat l
exchanger which is cooled by the Residual Heat Removal Service Water (RHRSW) system.
l Although both loops are usually employed to support reactor shutdown operations, the reactor primary coolant temperature can be lowered to 212 F in less than 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> with only one (1) l Page 17 loop in operation.
This proposed TS Change Request involves revising the Umerick Generating Station (LGS),
Units 1 and 2, Technical Specifications (TS) to modify Sections 3.4.9.1,3.4.9.2,3.9.11.1,3.9.11.2, and the associated Bases Section 3/4.4.9 and 3/4.9.11, to permit the use of either an ' analytical approach" (i.e., calculation) or " demonstration" as the means for ensuring operabilty of at least one (1) attemate decay heat removal method, rather than ' demonstrating" the operabilty, which is currently required. These TS sections pertain to Shutdown Cooling operation requirements during HOT SHUTDOWN, COLD SHUTDOWN, and Refueling Operations at the plant.
Specifically, this proposed TS wBI revise ACTION 'a' in TS Sections 3.4.9.1,3.4.9.2,3.9.11.1, and 3.9.11.2 by modifying the phrase, ".. demonstrate the operabuity of at least one attemate method...," to read, "... verify the avaBabaity of at least one attemate method...," as it relates to operabliity of an alternate decay heat removal method. The associated Bases Sections 3/4.4.9 and 3/4.9.11 will also be revised to clarify the intent of statement, "... verify the avalablity...," to imply that the operabiitty of an alternate decay heat removal method can be determined either by " calculation" (which includes a review of component and system avaBability to verify that an alternate decay heat removal metirod is available) or by " demonstration."
This proposed TS change is consistent with criteria delineated in the improved Standard TS (i.e.,
NUREG-1433, " Standard Technical Specifications, General Electric Plants, BWR/4,* dated September 28,1992). This proposed TS change will allow either " calculation" or " demonstration" to determine the operabulty of an attemate decay heat removal method. This proposed TS change will not affect the capability, availability, or operation of any decay heat removal systems / methods. The operation of the Residual Heat Removal (RHR) and Residual Heat Removal Service Water (RHRSW) systems will not be impacted by this proposed TS change.
Information Sucoortina a Findino of No Slanificant Hazards Consideration We have concluded that the proposed change to the Limerick Generating Station (LGS), Units 1 i
and 2. Technical Specifications (TS) that revise TS Sections 3.4.9.1,3.4.9.2,3.9.11.1,3.9.11.2 and the associated Bases Sections 3/4.4/9 and 3/4.9.11, to permit the use of either an j
" analytical approach" (i.e., calculation) or "demonstratiorf as the means for ensuring operability of at least one (1) alternate decay heat removal method, does 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 orocosed Technical Soecifications (TS) chanae does not involve a slanificant increase in the orobability or consgouences of an accident oreviousiv evaluated.
The proposed TS change does not involve any physical changes to plant systems or equipment. This proposed TS change wHI allow the use of either an
' analytical approach * (i.e., calculatk>n) or " demonstration" to ensure the operability of an altemate decay heat removal method. This proposed TS change does not involve any physical changes to plant systems or components, nor does it affect the capability, availability, or operability of any decay heat removal systems / methods (e.g., Shutdown Cooling). The Shutdown Cooling mode of operation of the Residual Heat Removal (RHR) system, and Residual Heat Removal Service Water (RHRSW) system, are not impacted by this proposed TS change, and will continue to function as designed to remove decay heat loads from the reactor primary coolant system. The RHRSW system and various modes of operation of the RHR system, e g., Low Pressure Coolant injection (LPCI) are not accident initiators, since these systems function to mitigate the consequences of an accident. This proposed TS change is 4
Page 18 consistent wkh the criteria delineated in the improved Standard TS (i.e., NUREG-1433, " Standard Technical Specifications, General Electric Plants, BWR/4," dated September 28,1992).
Therefore, the prW TS change does not involve an increase in the probabilky or consequences of an accident previously evaluated.
2.
The oroposed TS change does not cresta the posalbuky of a new or dNierent idnd d accident from any accident oroviously evalustad.
This prnpnand TS change does not involve any physical changes to plant l
systems or equipment. The proposed TS change wtl allow the use of a
" calculation" or " demonstration
- as the means for determining the operabilty of an altemate decay heat removal method. The proposed TS change does not '
l Involve any physical changes to plant systems or equipment This proposed TS change wil not affect the operation of the Shutdown Cooling mode of the RHR sy%sm. This mode of operation will continue to function as designed to remove decay heat loads from the reactor primary coolant system. This proposed TS l
change wil not' impact the operation of the other modes of operation of the RHR system (e.g., LPCI), nor wel it affect the operation of the RHRSW system These systems will continue to function as designed, which is to mitigate the consequences of an accident. This proposed TS change wlN not introduce the potential for equipment malfunctions or faRures. This proposed TS change is consistent with the criteria delineated in the improved Standard TS (i.e., NUREG-1433).
Therefore, the proposed TS change does not create the possib8ky of a new or different kind of accident from any previously evaluated.
3.
.The oronosed TS chanoe daae not involve a slanificant radelan in a marain of safety.
The proposed change to the TS does not involve any physical changes to plant systems or equipment This proposed TS change does not make any physical l
modifications to plant systems or equipment, and is consistent with the crkeria delineated in the improved Standard TS (i.e., NUREG-1433). The proposed TS i
l change wHl not impact any mode of operation of the RHR system or the RHRSW j
system.
1 This proposed TS change involves revising TS ACTION statements, and associated supporting Bases sections, to allow for the uee of a ' calculation" or
' demonstration" to ensure the operabRky of an altemate decay heat removal method. The bases for the TS sections affected by this proposed change indicate that sufficiert heat removal capabilky, system redundancy, and coolant circulation wBI be avalable to facultate decay heat removal and mbdng to assure accurate temperature indication. This proposed TS change does not affect the function or avaHabRity of any decay heat removal system or method l
Therefore, the proposed TS change does not involve a reduction in a margin of safety.
l
Page 19 information Suocorting an Environmental Assessment i
An Environmental Assessment is not required for the change proposed by this Change Request because the requested change to the LGS, Units 1 and 2 TS conforms to the crteria for
" actions eligible for categorical exclusion," as specified in 10 CFR 51.22(c)(9). The rarywM change wRI have no impact on the environment. The proposed change does not involve a significant hazards consideration as discussed in the preceding section. The proposed change does not Irwolve a significant change in the types or si nificant increase in the amounts of any 0
l effluent that may be released offsite. In addition, the proposed change does not involve a I
significant increase in individual or cumulative occupational radiation exposure j
i l
Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed the proposed change to the LGS, Units 1 and 2, TS and have concluded that it does not involve an unreviewed safety question, and wel not endanger the health and safety of the public k
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