ML20087G904
| ML20087G904 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/10/1995 |
| From: | Stetz J CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20087G907 | List: |
| References | |
| NUDOCS 9504180040 | |
| Download: ML20087G904 (13) | |
Text
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-e 300 m Awenus Jolm P. $1st Toledo, OH 436524001 '
Vice President . Nuclear
- 419-249-2300 Do+ Bene Docket Number 50-346 License Number NPF-3 Serial Number 2286
' April 10,1995 United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C. 20555 Subj ec t : Proposed Modification u the Davis-Besse Nuclear Power Station 1 1
(DBNPS) Operating License NPF-3, Appendix A Technical Specifica- 'J tions to Revise Technical Specifications 3/4.7.1.2 - Auxiliary Feedvater System, 3/4.7.1.3 - Condensate Storage Tanks, and 3/4.7.1.7 - Motor Driven Feedvater Pump System Gentlemen:
Enclosed is an application for an amendment to the DBNPS Unit Number 1 ;
Operating License Number NPF-3, Appendix A, Technical Specifications. The s
proposed changes involve Technical Specifications (TS) 3/4.7.1.2, "Auxil- i lary Feedvater System," 3/4.7.1.3, " Condensate Storage Tanks," and 3/4.7.1.7, " Motor Driven Feedvater Pump System." '
An administrative change is proposed to Auxiliary Feedvater System Limiting Condition for Operation (LCO) 3.7.1.2 Action "a" to provide additional clarity. A change to Surveillance Requiremcat 4.7.1.2.1.a is proposed that removes the specific parameters of 1070 psid and 800 psia and removes specific reference to the pressure indicators aed for the measurement.
Bases changes are proposed that 1) clarify the seguirements of Surveillance '
Requirement 4.7.1.2.1.e which require that both the lov and the low-lov Auxiliary Feedvater Pump Suction Pressure Interlocks be tested in order to satisfy the Surveillance Requirements, and 2) explains the reason for the )
l single arterisked note of Surveillance Requirement 4.7.1.2.1.a and clari- :
Iles the 9perability requirements when Scal manual valves are realigned l for Surveillance Requirement testing. )
l Changes are proposed to revise TS 3/4.7.1.3, " Condensate Storage Tanks."
These proposed changes are submitted as a line item improvement to clarify and modify the LCO to more closely conform with NUREG-1430, " Improved Standard Technical Specifications for B&W Plants."
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Docht Numb:;r 50-346 Liccnsa Nu bar NPF-3 Serial Neyber 2286 Page 2 Changes are proposed to revise TS 3/4.7.1.7, "Hotor Driven Feedwater System," ond its associated Bases. This change is a consolidation of the present requirements contained in Surveillance Requirement 4.7.1.7.a and 4.7.1.7.c. It includes a Bases revision that explains the reason for the double asterisked note of Surveillance Requirement 4.7.1.7.c and clarifies the operability requirements when the local manual valves are realigned for testing purposes.
Toledo Edison requests that the NRC apptove and issue these changes by October 11, 1995.
Should you have any questions or require additional information, please contact Mr. Villiam T. O'Connor, Manager - Regulatory Affairs, at (419) 249-2366.
Very truly yours, FVK/laj Yf cc: L. L. Gundrum, DB-1 NRC/NRR Project Manager J. B. Martin, Regional Administrator, NRC Region III S. Starek, DB-1 NRC Senior Resident Inspector J. R. Villiams, Chief of Staff, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)
Utility Radiological Safety Board
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-. ,,*. Docht Number 50-346
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APPLICATION FOR AMENCHENT i
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. FACILITY OPERATING LICENSE NPF-3l l
- DAVIS-BESSE NUCLEARLPOWER STATION- j UNIT NUMBER 1 j l
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/ Attached are requested changes to the Davis-Besse Nuclear Power Station, 'I Unit Number 1. Facility Operating License Number NPF-3. Also included is the Safety Assessment'and Significant Hazards Consideration. i
.i The proposed' changes (submitted under cover letter Serial Number 2286) {
concerns ,
Appendix A, Technical Specification Section 3/4.7.1.2 -' Auxiliary Feedwater
- System, and its-associated Bases. l i
Appendix A, Technical Specification Section 3/4.7.1.3 - Condensate Storage ;
- Tanks. - .
t Appendix A, Technical Specification Section 3/4.7.1.7 - Motor Driven Feedwater Pump System, and its associated Bases. ,
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I By: , , _
J. P. Ste O fed Presidght - Nuclear. ;
3 Sworn and subscribed before me this 10th day of April,1995. ,
Y1uitn)Y.
Notary PuVlic, State of Chio
~'BAA EVEl.VN L DRESS Notary Puth. Stsee of Ohio ;
My comemesion Eswas 7/28/90 ;
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'Dockat Nurber 50-346
'Lic:nsa Nunb:r NPF-3 S3ric1 Nu1ber 2286 Enclosure n
-page 2 ~
The following information is provided to support issuance of the requested changes to the Davis-Besse Nuclear Power Station, Unit Number J Operating
-License Number NPF-3, Appendix A,-Technical Specifications. The changes involve Technical Specifications 3/4.7.1.2 - Auxiliary,Feedvater System, and its associated Bases,'3/4.7.1.3 - Condensate Storage Tanks, and' 3/4.7.1.7 - Motor Driven Feedvater Pump System, and its associated Bases.
A. Time Required to Implement: This change'is to be implemented within 90 days after the NRC issuance of the License' Amendment.
B. Reason for Change (License Amendment Request Number 94-0011):
This application proposes changes to the TS regarding the requirements for operation of the Auxiliary Feedvater System and its Bases, the Condensate Storage Tanks, and the Motor Driven Feedvater Pump System-and its Bases.
'An administrative change is proposed to Auxiliary Feedvater System Limiting Condition _for Operation (LCO) 3.7.1.2 Action "a" to provide additional clarity. A change to Surveillance Requirement 4.7.1.2.1.a is proposed that removes the specific parameters of 1070 psid and 800 psia and removes specific reference to the pressure indicators used for the measurement. Bases changes are proposed that 1) clarify the requirements of Surveillance Requirement 4.7.1.2.1.e which require that both the low and the low-lov Auxiliary Feedvater Pump Suction Pressure Interlocks be tested in order to satisfy the Surveillance Requirements,_
and 2) explains the reason for the single asterisked note of Survell-lance Requirement 4.7.1.2.1.a and clarifies the operability require--
ments when local manual valves are realigned for Surveillance Require-ment testing. -
Changes are proposed to revise TS 3/4.7.1.3, " Condensate Storage Tanks." These proposed changes are submitted as a line item improve-ment to clarify and modify the LCO to more closely conform with NUREG-1430, " Improved Standard Technical Specifications for B&W Plants." '
Changes are proposed to revise TS 3/4.7.1.7, " Motor Driven Feedvater System," and its associated Bases. This change is a consolidation of the present requirements contained in Surveillance Requirement 4.7.1.7.a and 4.7.1.7.c. It includes a Bases revision that explains the reason for the double asterished note of Surveillance Requirement 4.7.1.7.c and clarifies the operability requirements when the local manual valves are realigned for testing purposes.
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, . Attachment.1z SAFETY ASSESSMENT AND SIGNIFICANT HAZARDS CONSIDERATION FOR l
LICENSE AMENDMENT REQUEST 94-0011 .
(19 pages follow). ,
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1 LAR 94-0011 Psge 1 SAFETY ASSESSMENT AND SIGNIFICANT HAZARDS CONSIDERATION FOR LICENSE AMENDMENT REQUEST NUMBER 94-0011 TITLE Proposed Modification to the Davis-Besse Nuclear Power Station (DBNPS)
Operating License NPF-3, Appendix A Technical Specifications to Revise Technical Specification (TS) 3/4.7.1.2 - Auxiliary Feedvater System, TS 3/4.7.1.3 - Condensate Storage Tanks, and TS 3/4.7.1.7 - Motor Driven Feedvater Pump System.
DESCRIPTION
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The purpose of this licensing amendment request is to modify Davis-Besse Nuclear Power Station (DBNPS) Operating License NPF-3, Appendix A TS 3/4.7.1.2 - Auxiliary Feedvater System (AFV) and its associated Bases, TS 3/4.7.1.3 - Condensate Storage Tanks, and TS 3/4.7.1.7 - Motor Driven Feedvater System and its associated Bases.
Auxiliary Feedvater System Limiting Condition for Operation (LCO) 3.7.1.2 Action a'(page 3/4 7-4) is revised to add the phrase "or both" after the word "either," and to add "(s)" after the word " generator," as shown on the accompanying marked up page. This change is an administrative change to i provide additional clarity that an auxiliary feedvater train must be capable of providing feedvater to both steam generators to be considered operable, and does not change the intended meaning of Action a.
Surveillance Requirement 4.7.1.2.1.a on TS page 3/4 7-4 is proposed for revision to state:
"a. At least once per 92 days on a STAGGERED TEST BASIS bys*
- 1. Verifying the differential pressure of each steam turbine i driven pump is greater than or equal to the required differen-tial pressure at the specified recirculation flow rate. The i provisions of Specification 4.0.4 are not applicable for entry l into MODE 3." i This change removes the specific parameters of 1070 psid and 800 psia !
presently contained within the Surveillance Requirement. It also removes i specific reference to the pressure indicators used for the measurement.
Completed modifications in the operation of the Auxiliary Feedvater Pumps require that the 1070 psid value be increased in crder to demonstrate ;
Auxiliary Feedvater System operability. However, NUREG-1430, " Improved l Standard Technical Specifications for B&V Plants" no longer contains !
specific parameters and instrumentation for this Surveillance Requirement.
Therefore, this line item improvement is proposed to more clorely adopt the ;
general wording of NUREG-1430, " Improved Standard Technical Specifications !
for B&V Plants" by deleting the specific values and the instrumentation l used. The revised wording is in general conformance with the vording and l intent of NUREG-1430, but has been modified to utilize the DBNPS specific
LAR 94-0011 Phge 2
- terminology and test method. Test proce6 pres at the DBNPS have been revised to incorporate the increased pressure differential value.
A change to Bases Section 3/4.7.1.2, " Auxiliary Feedvater System," (page B3/4 7-lb) is proposed that states:
The Condensate Storage Tanks are the non-safety-related primary source of the water for the Auxiliary Feedvater System. When the auxiliary feedvater pumps are needed and either the condensate Storage Tanks are not available or have been emptied by the Auxiliary Feedvater System, a safety-related transfer system transfers the suction from the Con-densate Storage Tanks to the Service Vater System. The Service Water System is the safety-related secondary source of the water and must be available for the associated Auxiliary Feedvater System train to be OPERAPLE. The transfer is initiated upon detection of a lov suction pressure at the suction of the auxiliary feedvater pumps by suction pressure interlock switches. These pressure switches, upon sensing lov suction pressure, vill automatically transfer the suction of the auxiliary feedvater pumps to the Service Vater System. On a sustained low-lov suction pressure, additional auxiliary feed pump suction pressure interlock switches will operate to close the steam supply valves to protect the turbine driven auxiliary feedvater pumps from cavitation. The steam supply valves vill re-open automatically upon restaration of suction pressure to the pumps. Both the lov and the low-low Auxiliary Feed Pump Suction Pressure Interlocks are required to be OPERABLE for OPERABILITY of the associated auxiliary feedvater train."
This change provides the basis for Surveillance Requirement 4.7.1.2.1.e.
This surveillance requires testing of both the lov and the low-lov auxil-iary feedvater pump s,uction pressure interlocks.
Another change to Bases Section 3/4.7.1.2, " Auxiliary Feedvater System," js proposed that states:
Each train of auxiliary feedvater must be capable of providing feedvater flow to each steam generator in order to be OPERABLE.
However, the design of the system does not provide for feeding both steam generators simultaneously from one train.
This addition to the Bases provides additional clarification for the changes proposed in LCO 3.7.1.2. Each train of auxiliary feedvater must be capable of providing flow to either steam generator at all times but the design of the system is to provide full flow to enly one steam generator from one train of auxiliary feedvater at any one time.
Another change to Bases Section 3/4.7.1.2, " Auxiliary Feedvater System," is proposed that states:
"When conducting tests of an auxiliary feedvater train in MODES 1, 2, or 3 which require local manual realignment of valves that make the train inoperable, a dedicated individual shall be stationed at the
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i LAR 94s0011 P5ge 3 '
valves, in communication vith the control room, able to restore the valves to normal system OPERABLE status. However, it is not required to have this dedicated individual stationed if the other train of the Auxiliary Feedvater System is OPERABLE and the Motor Driven Feedvater Pump System is OPERABLE pursuant to Technical Specification 3/4.7.1.7 because two sources of auxiliary feedvater to the steam generators are OPERABLE. In either situation, the Auxiliary Feedvater System train with the local manual realigned valves is inoperable and the Limiting Condition for Operation ACTION must be followed."
This Bases change provides the reason for the single asterisked note of Surveillance Requirement 4.7.1.2.1.a and clarifies the operability require-ments when the local manual valves are realigned for Surveillance Require-ment testing purposes.
The proposed changes revise LCO 3.7.1.3 (page 3/4 7-6) as follows:
Change Action b. Replace " Demonstrate" with " Verify by administrative means." Add " verify once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter" after " auxiliary feedvater system." Replace "next" with "following" as shown below:
"b. Verify by administrative means the OPERABILITY of the 1ervice water system as a backup supply to the auxiliary feedvater system, verify once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter, and restore the condensate storage tanks to OPERABLE status within 7 days, or be in HOT SHUTD0VN vithin the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."
Surveillance Requirement 4.7.1.3.2 is then proposed for deletion because the intent of its requirements have been included in Action b as discussed above.
These proposed changes are submitted as line it'em improvements to clarify and modify the TS to more closely conform with the guidance of NUREG-1430,
" Improved Standard Technical Specifications for B&W Plants." NUREG-1430 does not contain this surveillance requirement in its TS 3/4.7.6, "Conden-sate Storage Tank (CST)", nor is it contained in TS 3/4.7.8, " Service Water System (SUS)."
The proposed changes also revise TS 3/4.7.1.7 (page 3/4 7-12a) as follows:
Delete Surveillance Requirement 4.7.1.7.a. concerning the Motor Driven Feedvater Pump and replace with the word " deleted." Add the following requirement to Surveillance Requirement 4.7.1.7.c (page 3/4 7-12b) :
"2. Verifying the Motor Driven Feedvater Pump starts from the Control Room."
This change is a consolidation of the present requirements contained in Surveillance Requirement 4.7.1.7.a and 4.7.1.7.c and does not change the intended requirements of the surveillance.
A change is proposed to Bases Section 3/4.7.1.7, " Motor Driven Feedvater Pump System," (page B3/4 7-3) that states:
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.LAR 94,0011' Phge 4 *
"When conducting tests of the Motor Driven Feedvater Pump System.in.
HODE-loat greater than 40% RATED THERMAL POWER which requires local ;
manual realignment of valves which make the system inoperable, a dedi- H cated individual shall be stationed at the realigned train's valves, in communication with the control room, able to restore the valves to nor- ,
mal system-OPERABLE status. However, it is not required to have.this dedicated individual stationed if both trains of'the Auxiliary Feed-water System are OPERABLE pursuant to Technical Specification 3/4.7.1.2
- because two sources of auxiliary feedvater to the steam generators are OPERABLE. In either situation, the Motor Driven Feedvater Pump-System with the local manual realigned valves is inoperable and the Limiting condition for Operation ACTION must be followed."
-This Bases change provides the reason for the double asterisked note of Surveillance Requirement 4.7.1.7.c and clarifies the operability require- j ments when the local manual valves are realigned for testing purposes.-
1 SYSTEMS, COMPONENTS, AND ACTIVITIES AFFECTED:
Auxiliary Feedvater System Motor Driven Feedvater System Service Vater System FUNCTIONS OF THE AFFECTED SYSTEMS, COMPONENTS, AND ACTIVITIES:
The Auxiliary Feedvater System is described in the DBNPS Updated Safety Analysis Report (USAR) Section 9.2.7, " Auxiliary Feedvater System." The Auxiliary Feedvater System is designed to provide feedvater to the steam .
generators when main feedvater is not available. The Auxiliary Feedvater System is also designed to mitigate feedvater line and steam line breaks as described in USAR Sections 15.2.8, " Loss of Normal Feedvater," and 15.4.4,
" Steam Line Rupture." The Condensate Storage Tank as described in USAR Section 9.2.6, provides the water supply to the Auxiliary Feedvater System.
There are two 250,000 gallon non-seismic Category I designed tanks.
The function of the non-safety related Motor Driven Feedvater Pump System i is to cool the Reactor Coolant System down from the normal' operating !
conditions in the event of the total loss of main feedvater and auxiliary )
feedvater pumps. The Motor Driven Feedvater Pump is described in USAR i Section 9.2.8, "Hotor Driven Feedvater Pump."' I l
In the context of this license amendment request, ~ the Service Water System I serves as the seismic Category I backup water supply to the Auxiliary Feedvater System when the Condensate Storage Tanks supply is not available. i USAR Section 9.2.1 describes the Service Vater System. l EFFECTS ON SAFETY:
The proposed changes to the TS 3/4.7.1.2 Action a are acceptable because the revised Action a is a rewording of the current Action a in order to provide additional clarity and does not change the intent of the require- H ment. The change was made to specifically clarify the condition when auxiliary feedvater is inoperable to both steam generators. Revording the Action statement for additional clarity has no adverse effect on safety.
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LAR 94-0011 Page 5
- The proposed change to Surveillance Requirement 4.7.1.2.1.a removes the specific parameter of a developed differential pressure of 1070 psid while on recirculation flow and the specific parameter of the secondary steam supply pressure greater than 800 psia. Additionally the reference to specific instrumentation used to perform the test has been removed.
These proposed changes to Surveillance Requirement 4.7.1.2.1.a are line item improvements that adopt the general wording and intent of NUREG-1430,
" Improved Standard Technical Specifications for B&W Plants," but have been modified to utilize DBNPS specific terminology. The pumps vill continue to be tested in accordance with the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI. In addition, changes vill be subject to the requirements of 10CFR Section 50.59. Therefore, the proposed changes to Surveillance Requirement 4.7.1.2.1.a have no adverse effect on safety.
The proposed changes are modified by the currently existing note indicating that the provisions of Specification 4.0.4 are not applicable for entry into MODE 3. This is required because there is insufficient steam pressure to perform the test prior to entry into MODE 3.
Removing the references to specific pressure values and specific plant instrumentation is consistent with NUREG-1430 and has no adverse effect on safety because the purpose of the existing Surveillance Requirement will continue to be met.
The first proposed change to Bases B3/4.7.1.2, " Auxiliary Feedvater System," provides the reason for Surveillance Requirement 4.7.1.2.1.e and states that both the lov and the low-low Auxiliary Feed Pump Suction Pressure Interlocks must be tested in order to satisfy the Surveillance Requirement. This Bases change, along with the explanation that the Service Vater System must be available for the associated Auxiliary Feedvater System train to be operable, provides additional clarification and does not change the Surveillance Requirement. Therefore, this change has no adverse effect on safety.
The second proposed c!.ange to Bases B3/4.7.1.2, " Auxiliary Feedvater System," is to specify clearly that each train auxiliary feedvater must maintain the capability to supply either stcam generator at all times but the design of the system is to provide full flov to only one steam generator from one train of auxiliary feedvater at any one time. This Bases clarification does not change the way the Auxiliary Feedvater System is operated and, therefore, has no adverse affect on safety.
The third proposed change to Bases B3/4.7.1.2, " Auxiliary Feedvater System," is to provide the reason for the single asterisk note of Surveil-lance Requirement 4.7.1.2.1. When an auxiliary feedvater train is taken out of service for testing, a dedicated individual does not need to be l stationed at the local manual realicaed valves if there is one train of the Auxiliary Feedvater System and the Motor Driven Feedvater Pump System operable because two sources of auxiliary feedvater to the steam generators are operable. If the Motor Driven Feedvater Pump System is inoperable, 1
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leaving on1 ..e auxiljary feedvater train operable, then it is required that a dedicated individual be stationed at the valves able to quickly restore the system. In either situation, the Auxiliary Feedvater System train with the local manual realigned valves is inoperable and the LCO Action must be followed. This Bases change provides additional explanation and does not change the Surveillance Requirement. Therefore, this change has no adverse effect on safety.
The proposed change to LCO 3.7.1.3 Action b is a line item improvement to clarify the intended requirement and closely adopt the guidance of NUREG-1430. This proposed change is made in conjunction with the proposed deletion of Surveillance Requirement 4.7.1.3.2. Existing SR 4.7.1.3.2 '
requires demonstrating the operability of the Service Water System and includes verification that the service water loop Auxiliary Feedvater System isolation valves are either open or operable. The new ACTION b requires verifying by administrative means the operability of the Service Water System, where operability of the Service Water System includes the operability of the service water loop Auxiliary Feedvater System isolation valves. Including requirements to verify the operability of the Service Vater System in the Action statement of the LCO is appropriate because '
these actions are only taken if the Condensate Storage Tanks become inoperable. The Service Vater System is required to be continuously operable by LCO 3/4.7.4.1, " Service Vater System," in Modes 1, 2, 3 and 4.
The purpose of performing Action b of LCO 3.7.1.3 serves to. ensure that when the Condensate Storage Tanks are inoperable the Service Vater System, upon which the Auxiliary Feedvater System then depends, remains operable.
Thetefore, this change has no adverse effect on safety. 1 The proposed change to TS 3/4.7.1.7 vill remove SR 4.7.1.7.a which is ;
i currently redundant with SR 4.7.1.7.c, and relocate the requirement to verify that the Motor Driven Feedvater Pump starts from the Control, Room from 4.7.1.7.a to SR 4.7.1.7.c. Surveillance Requirement 4.7.1.7.c vill be l renumbered accordingly, as shown in the attached marked up copy. Verifica- i tion of the proper operation of the Motor Driven Feedvater Pump in accord- l ance with existing SR 4.7.1.7.d, encompasses the purpose for the " indica-tion of flow" stipulated in SR 4.7.1.7.a which is being removed. These changes are administrative and serve to remove the redundant portions of the Surveillance Requirement and renumber SR 4.7.1.7.c as shown. There-fore. this change retains the intended requirements for performing surveil-lances on the Motor Driven Feedvater Pump System and has no adverse effect on safety.
The proposed change to Bases B3/4.7.1.7, " Motor Driven Feedvater System,"
is to provide the reason for the double asterisked note of Surveillance Requirement 4.7.1.7.c. When the Motor Driven Feedvater System is taken out of service for testing, a dedicated individual does not need to be stationeo at the local manual realigned valves if both Auxiliary Feedvater System trains are operable because two sources of auxiliary feedvater to the steam generators are operable. If one of the trains of Auxiliary Feedvater System is inoperable, leaving only one auxiliary feedvater train operable, then it is required that a dedicated individual be stationed at i
the valves able to quickly restore the system. In either situation, the Motor Driven Feedvater Pump System train with the local manual realigned
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- 1 valves is inoperable and the LCO Action must be followed. This Bases i change provides additional explanation and does not change the Surveillance i Requirement. Therefore, this change has no adverse effect on safety. I SIGNIFICANT HAZARDS CONSIDERATION: ;
The Nuclear Regulatory Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazard exists due to a proposed ,
amendment to an Operating License for a facility. A proposed amendment involves no significant hazards consideration if operation of the facility in accordance with the proposed changes vouldt (1) Not involve a signiff-cant increase in the probability or consequences of an accident previously evaluated; (2) Not create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Not involve a significant reduction in a margin of safety. Toledo Edison has reviewed ,
the proposed changes and determined that a significant hazards considera- '
tion does not exist because operation of the Davis-Besse Nuclear Power Station, Unit Number 1, in accordance with these changes would:
i Not involve a significant increase in the probability of an accident I la.
previously evaluated because no change is being made to any accident initiator. No previous analyzed accident scenario is changed, and initiating conditions and assumptions remain as previously analyzed.
The proposed changes are clarifications and the incorporations of the guidance provided by NUREG-1430. Therefore, it can be concluded that the proposed changes do not involve a significant increase in the l probability of an accident previously evaluated.
lb. Not involve a significant increase in the consequences of an accident previously evaluated because the proposed changes do not affect accident conditions or assumptions used in evaluating the radiological consequences of an accident. The proposed changes do not alter the source term, containment isolation or allovable radiological relea.1s.
- 2. Not create the possibility of a new or different kind of accident from any accident previously evaluated because the proposed changes do not change the way the plant is operated and, no new or different failure modes have been defined for any plant system or component important to i safety, nor has any limiting single failure been identified as a result of the proposed changes. No new or different types of failures l or accident initiatoes are introduced by the proposed changes. !
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- 3. Not involve a significant reduction in a margin of safety because the proposed changes are clarifications and the incorporations of the l guidance provided by NUREG-1430, and continue to ensure the availabil- l ity and capability of the Auxiliary Feedvater System, Service Water l System and the Motor Driven Feedvater Pump System when called upon to perform their functions. The proposed changes vill not adversely '!
impact any safety analysis assumptions.
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. CONCLUSIONS: 1 On the basis of-the above, Toledo Edison has determined that the License Amend- !
ment Request does not involve a significant hazards consideration. As this l License Amendment Request concerns a proposed change to the Technical Specifica- ;
tions that must be reviewed by the Nuclear Regulatory Commission, this License Amendment Request does not constitute an unreviewed safety question. :
ATTACHMENT: ,
Attached are the proposed marked-up changes to the Operating License..
REFERENCES:
- 1. Technical Specifications 3/4.7.1.2 - Auxiliary Feedvater System, )
3/4.7.3 - Condensate Storage Tanks,'and 3/4.7.1.7 -' Motor Driven )
Feedwater Pump System and associated Bases. i
- 2. NUREG-1430, Revision 0, Improved Standard Technical Specifications for B&W Plants.
- 3. USAR.Section 9.2.1,-Service Water System. .
- 4. USAR Section 9.2.6, Condensate Storage Facilities. ;
- 5. USAR Section 9.2.7, Auxiliary Feedwater System.
By USAR Section 15.4.4, Steam Line Rupture.
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