ML20101S028

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Proposed Tech Specs Clarifying Action Statements for Cold Leg Injection Accumulators & Upper Head Injection (Uhi) Sys & Uhi Surveillance Requirements
ML20101S028
Person / Time
Site: McGuire, Mcguire  
Issue date: 01/30/1985
From:
DUKE POWER CO.
To:
Shared Package
ML20101S012 List:
References
TAC-56473, TAC-56474, TAC-56476, TAC-56477, TAC-56873, TAC-56874, NUDOCS 8502050194
Download: ML20101S028 (10)


Text

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7 Attachment I Page 1 of 4 3/4.5 EMERGENCY CORE COOLING SYSTEMS 3/4'.5.1 ACCUMULATORS COLD LEG INJECTION a

LIMITING CONDITION FOR OPERATION

'3.5.1.1 Each cold' leg injection accumulator shall be OPERABLE with:

The isolation valve open, a.

4 b.

A' contained borated water volume of between 8022 and 8256 gallons A boron concentration of between 1900 and 2100 ppm, c.

d.

A' nitrogen cover pressure of between 430 and 484 psig, and e.

A water level and pressure channel OPERABLE.

- APPLICABILITY: MODES 1, 2, and 3*.

ACTION:

With one accumulator inoperable, except as a result of a closed a.

isolation valve, restore the inoperable accumulator to OPERABLE status within I hour or be in at least HOT STANDBY within the next 6_ hours and reduce pressurizer pressure to less than 1000 psig within the1following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

b.

With one accumulator inoperable due to the isolation valve being

- closed, either immediately open the isolation valve or be in at least HOT' STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce pressurizer pressure to less than 1000 psig within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

-SURVEILLANCE REQUIREMENTS 4.5.1.1.1 Each cold leg injection accumulator shall be demonstrated OPERABLE:

~

a.

At'least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by:

1) Verifying the contained borated water volume and nitrogen cover-pressure in the tanks, and 2)- Verifying that each cold leg injection accu;sulator

-isolation valve-is open.

  • Pressurizer pressure above 1000 psig.

8502050194 850130

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PDR McGUIRE-- UNITS 1 and 2 3/4'5-1 Amendment-No. 32 (Unit 1)

Amendment No. 13 (Unit 2) e w-,r c._---..,-.1-

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Attechment I

p. 2 of 4

' Justification and Safety Analysis The proposed changes of the Technical Specifications are concerned with ACTION

-requirements associated with Technical Specification 3.5.1.1.

The current Technical Specification ACTION requirement (a) requires that in the event'a cold leg accumulator becomes' inoperable for reasons other than a closed isolation valve and cannot be restored to operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, the reactor be placed 'in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the.following_6 hours.

The~ proposed Technical Specification differs from the cdrrent specification in that reducing the pressurizer pressure below 1000 psig (within the following

6. hours) will be required rather than placing the reactor in HOT SHUTDOWN (within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />).
The proposed change to ACTION (a) does not involve a reduction in the margin of if

. safety at McGuire Nuclear Station. In the event of a planned reduction in reactor coolant system pressure, it is standard procedure at McGuire to isolate the

' cold. leg accumulators below 1000 psig in order to prevent inadvertent. injection of the accumulator contents into the RCS. Therefore, the cold leg injection accumulators serve no_ safety function below 1000 psig, t

The. Limiting Condition for Operation.is applicable for Mode 3 (HOT STANDBY).only above 1000. psig.by the current Specification 3.5.1.1, thus the accumulators are not required to be OPERABLE when pressteizer pressure is below-1000 psig; therefore the accumulators are not.necessary to mitigate the consequences of any anticipated event'that may occur with the reactor in this state.

Another proposed change concerns the' ACTION (b) required-by the Specification-

3.5.1.1.'

The proposed changes would place the reactor in HOT STANDBY in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce the pressurizer pressure below 1000 psig within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> in case an isolation valve is found closed and cannot be immediately opened.

~

The current' specifications require power reduction to HOT STANDBY within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and HOT SHUTDOWN within the -following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in event of a closed (and inoperable).

cold leg accumulator isolation valve.

'As previously discussed, the change to procede below 1000 psig rather than.to

~ HOT SHUTDOWN does not involve a reduction'in the safety margin at McGuire. :The cchange.to allow 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to reach HOT STANDBY and the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to. reduce pressurizer pressure.below 1000 psig in the case of a closed and inoperable isolation. valve does not pose a safety risk. Presently, the' Specification allows 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> to reach HOT STANDBY if an accumulator is inoperable for any reason other u

! than a closed ~(and ' inoperable) cold --leg accumulator isolation valve;- thus _ the additiona15 hours has been determined to pose no additional risks. The change twill make ACTION (a). and (b) consistent.

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The proposed. changes reflect the revisions currently being considered in the-

) Standard Technical Specifications Revision V for the Westinghouse PWRs.

J 4

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Attachment I

p. 3 of 4 It should also be noted that proposed changes have previously been submitted for.the Limiting Conditions for operation, 3.5.1.lb and 3.5.1.1d.

These proposed changes were submitted with the McGuire Unit 2/ Cycle 2 reload submittal'which was transmitted by Mr. H. B. Tucker's letter of November 16, 1984. The changes proposed in the reload submittal would establish the same limits'for borated water volume and nitrogen cover pressure in the accumulators for both units. The changes proposed in the reload submittal are expected to.

be approved prior to this proposal, and each proposal does not impact upon

.the other.

O 4

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e Attachment I

p. 4 of 4

' Analysis of Significant Hazards Consideration

- Pursuant to the requirements of 10CFR50.91, this analysis provides a determination that the proposed modification of the Technical Specification -3.5.1.1 does not, involve a significant hazards consideration, as defined by 10CFR50.92.

The proposed. changes concern the Cold Leg Injection Accumulator System. There

_are two main changes involved in the Specification 3.5.1.1:

1)

A proposed change to permit 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to place the reactor in HOT STANDBY instead of the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> currently allowed

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in event of inoperability of the Cold Leg Injection Accumulator System due to a closed and inoperable isolation valve'.

. 2) ~ A proposed change to low' r the pressurizer pressure below e

1000 psig. within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> instead of placing the reactor in HOT SHUTDOWN within.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The first change does not involve any significant hazards consideration, as the situation is allowed.for similar circumstances. The difference (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to be

'in HOT STANDBY rather than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) is due to an error in Revision IV of the Standard Technical Specifications, and is presently being incorporated into' Revision:V of the Westinghouse Standard Technical Specifications. Since 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />

-are also permitted to place the reactor in HOT STANDBY if the Cold Leg Injection System is inoperable due.-to reasons other than closed inoperable isolation valves, the.inoperability of Cold Leg Injection Accumulators for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is already considered'to pose negligible ~ adverse safety consequences. Thus the proposed

-change is no less conservative than other portions of the Specification 3.5.l'.1 ACTION statement.

The second change' requires that pressurizer pressure be' lowered below 1000 psig

- within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> instead of placing the reactor in HOT SHUTDOWN as currently.

-required.. Since McGuire procedures require that--the Cold' Leg Injection Accumulators The_ isolated below 1000 psig reactor coolant system pressure to prevent _ inadvertent i

injection,.the accumulators serve no_ safety function below.1000 psig, and thus the 4

inoperability or.. failure of the Cold' Leg Injection Accumulators below 1000 psig thas no safety implications. There:is~ no possibility of any new accident mechanisms or consequences ' arising due' to the proposed changes.

Thel proposed-amendments would not

1)i Invo?ve~a significant increase in the probability or con-sequences of an. accident previously evaluated; or

-2)

Create _.the possibility of a-new or'different kind of

-accident from.any accident previously evaluated;_or

3)-l Involve a'significant reduction in~a margin of safety.

Based upon the-preceding analysis, Duke Power Company concludes that the-proposed-s

. amendments-do not involve-a significant hazards consideration.

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Attachm:nt 11 page 1 of 3 EMERGENCY CORE COOLING SYSTEMS

~ UPPER HEAD INJECTION LIMITING CONDITION FOR OPERATION 3.5.1.2 Each Upper Head Injection Accumulator System shall be OPERABLE with:

a.

The isolation valves open, b.

The water-filled accumulator containing a minimum of 1850 cubic feet of borated water having a' concentration of between 1900 and 2100 ppm of boron, and c.

The nitrogen bearing accumulator pressurized to between 1206 and 1264 psig.

APPLICABILITY: MODES 1, 2, and 3*.

ACTION:

a.

With the Upper Head Injection Accumulator System inoperable, except as a result of a closed isolation valve (s), restore the Upper Head Injection Accumulator System to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce pressurizer pressure to less than 1900 psig within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

b.

With the Upper Head Injection Accumulator System inoperable due to the isolation valve (s) being closed, either immediately open the isolation valve (s) or be in at.least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce pressurizer pressure to less than 1900 psig within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.5.1.2. Each Upper Head Injection Accumulator System shall be demonstrated OPERABLE:

a.

At least once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />s-by:

1) Verifying the contained borated water volume and nitrogen

. pressure in the accumulators, and

2) Verifying that each accumulator isolation valve is open.
  • Pressurizer Pressure above 1900 psig.

McGUIRE - UNITS 1 and 2 3/4 5-3

rr Attachment II

p. 2 of 3

~ Justification'and Safety Analysis s

The propose'd: changes oflthe Technical Specifications are concerned with the

ACTION requirements associated with Specification 3.5.1.2.

The current LTechnical Specification 3.5.1.2 ACTION (a) requires that in i

event-of 'an inoperable' Upper Head Injection System (UHI) except as a result of closed: isolation valve (s) the UHI is to be. restored to operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or'the' reactor is-to be placed in at least HOT STANDBY within the next 6' hours and HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The proposed

Technical; Specification differs from the current speci,fication in that it

-.-requires 1that the pressurizer pressure be reduced below 1900 psig within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.instead of the requirement to place the reactor in HOT SHUTDOWN within

-6. hours.. The proposed change is no less conservative than the current Specification.

1The. Limiting Conditions for Operation currently contained in Technical Specification l3.5.1.2 apply to': mode 3 (HOT STANDBY) only above 1900 psig. Previous safety

! analyses have shown that the. Upper Head Injection System serves no safety function

<when RCS pressure is below 1900 psig. Therefore, this change to the " ACTION" rstatement will have.no adverse impact on safety. Also, as presently written, if r

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Lthe UH1' system becomes inoperable and cannot be restored within the given time frameitm is possible to get out of the Applicability of the Specification (Mode 3 above 1900.psig) prior to completing the " Action" (reaching Mode 4,

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' : HOT. SHUTDOWN) 'sta'tement. This proposed change would eliminate this inconsistency.

?Another. proposed change concerns Technical Specification 3.5.l'.2 ACTION (b).

The current ACTION '(b) requires -that if the UHI System is inoperable.due-to

-closed: valve (s),~-either immediately open the valves.or be in HOT STANDBY within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and be in HOT SHUTDOWN within next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.L The proposed Technical

Specifications seek to. modify these requirements. _The requirement to place E

' the' reactor: in HOT STANDBY within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is changed by allowing 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to place the reactor,in HOT STANDBY mode. 'In the~ case of inoperability of-the UHI syste's, due to something other than closed inoperable isolation valv'es. Technical JSpecification 3.5.1.2' ACTION (a)calso' permits 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to attain to HOT STANDBY status. The " ACTION". requirements-of parts (a) and (b)'are presently different c only..as :the ; result of an ' error: of finconsistency in Revision -IV of the Standard

< Technical Specifications for Westinghouse PWRs,Jon which McGuire's Technical l Specifications <are based. :(This error isLbeing corrected in Revision V of'the Westinghouse Standard Technical: Specifications.) The requirement to put the y

reactor.in HOT STANDBY.'due to'an inoperable UHI, system needs to be consistent

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for all causes. The' proposed: change is no less conservative than the existing y

Spe'cification and would make the>" ACTION" statements consistent for an-

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inoperable UHI system

[

The proposed.changesJare a result of a utility wide' review of the Technical-

' Specification : 3.5.1. 2.-

The proposed changes have been incorporated in-the draft'

Revision..V of !the;Stiandard; Technical Specifications for?the Westinghouse-PWRs. =
Thelproposedchanges'donot'haveany.adversesafetyimplications.

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lThe-proposed' changes are contingent-upon approval of.the change submitted with the' McGuire Unit 2/ Cycle 2: reload submittal-as transmitted by Mr. H. B. Tucker's

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1etter of Novemberi16. 1984.
;The change to the specification proposed in the 1

reload submittal ~would disallow power operation with the UHI system inoperable, /

Lwhich is more: conservative than the present specification, which allows power soperation up;to 46%'of-rated thermal power with the UHI system. inoperable, thus T

fthe proposal inithe reload submittal should be approved prior to this proposal;

being. approved.

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i Attachment II

p. 3 of 3 Analysis of Significant Hazards Consideration Pursuant to the requirements of 10CFR50.91, this analysis provides a determination that the proposed modification of the Technical Specification 3.5.1.2 does not involve a significant hazards consideration, as defined by 10CFR50.92.

The proposed changes concern the Upper Head Injection System. There are two proposed changes in Specification 3.5.1.2 requiring significant hazards evaluation:

1) A proposed change to allow 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to place the reactor in HOT STANDBY instead of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> currently allowed in the event of inoperability of the UHI system due to a closed, inoperable isolation valve.
2) A proposed change to lower the pressurizer pressure below 1900 psig within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> instead of placing the reactor in HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

-The proposed change to allow 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to place the reactor in HOT STANDBY instead of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> as in ACTION (b), is reasonable and maintains conservatism, as in ACTION (a) of Specification 3.5.1.2.

The potential addition of 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of power operation with UHI inoperable does not present a significant risk to plant safety as permitted under ACTION (a) of the Specification. The reason for the present difference is an error in Revision IV of the Westinghouse Standard Technical Specifications on which McGuire's Technical Specifications are based. This is being corrected in Revision V of the Westinghouse Standard Technical Specifications.

The second change permits reducing the pressurizer pressure to below 1900 psig in Mode 3 instead of proceeding to HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

It is recognized in the current specification 3.5.1.2 that UHI system operability is not necessary below 1900 psig in mode 3.

Therefore the proposed change does not have any adverse implications for plant safety.

The proposed changes are in the process of being incorporated into Revision V of the Standard Technical Specifications for the Westinghouse PWRs.

The proposed amendments would not:

1) Involve a signi?icant increase in the probability or consequences of an accident previously evaluated; or
2) Create the possibility of a new or different kind of accident--from any accident previously evaluated; or
3) Involve a significant reduction in a margin of safety.

Based upon the preceding analysis, Duke Power Company concludes thac the proposed amendments.do not involve a significant hazard consideration.

E-Attachment III page 1 of 3 EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) b.

At least once per 31 days and within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after each solution volume increase of greater than or equal to 1% of tank volume by

. verifying the boron concentration of the solution in the water-filled accumulator; At least once per 18 months by:

c.

1) Verifying that each accumulator isolation valve closes automatically when an actual or simulated water level signal of 76.25 i 3.3. inches above the bottom inside edge of the water-filled accumulator exists.

If actual water level is used, then the accumulator shall be at atmospheric pressure.

2.

Verifying that the total dissolved nitrogen and air in the water-filled accumulator is less than 80 scf per 1800 cubic feet of. water (equivalent to 5 x 10-5 pounds nitrogen per pounds water).

d.

At least once per 5 years by replacing the membrane installed

.between.the water-filled and nitrogen bearing accumulators.

McGUIRE - UNITS 1 and 2 3/4 5-4 Amendment No.

4 (Unit 2)

Amendment No. 23 (Unit 1)-~

W-4 Attachment'III 4

p. 2 of 3 m

u

' Justification and Safety Analysis s

The propose'd changes.co the McGuire's Technical Specifications concern y

" b?

the ' surveillance _ requirements for the Upper Head Injection (UHI) System.

The_ current specification 4.5.1.2.c requires clarification regarding theLmethods employed to verify its compliance.

TheEcurrent Technical Specification 4.5.1.2.c requires that, at least onceLevery 18 months verify.that each accumulator isolation valve closes Lautomatically.when the water level-is 76.25 3.3 inches above the bottom

~inside edge'of the water fill d accumulator with atmospheric pressure e

lin -the ; accumulator.

In its_present form Specification 4.5.1.2.c could Ebe;interpeted to mean that the actual tank water level is to be reduced

'to the1setpoint,in order to verify that each accumulator isolation valve

~

closes.,.However such an interpretation is not practical and is not consistent
with testing performed on other systems where an instrument reaching a

.setpoint_ actuates a. device. Further discussion of this matter may be found

<.in Mr. Hi B. Tucker's letter of December 20, 1984' to Mr. J. P. O'Reilly

. (Region II Administrator) which is primarily concerned with the subject

- ' ' ~. "

. Specification.

At >.fcGuire tlue normal practice is to conduct the tests requir d by specification

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e

,4.5.1.2.c as'a channel calibration. The entire loop from the level transmitter J

fco the valve actuation is tested. Testing by sequential, overlapping or-total

' channel' steps is allowed. The'use of actual process system fluid level is.

Enot, required. For these types of ~ instrumentation loops, it is not reasonable

.or-practical to' manipulate the entire process' system so as to achieve the

required actuation setpoint.' Instead, test signals are used to perform the
operationalutest. 'Such signals are placed as close to the sensor as possible.

The testais considered-successful-if the' channel responds with the required range and accuracy to known values of input signals'.

This type of testing

using simulated signalsLis also-employed for other safety related systems including pressurizer _ water level (high), steam generator water level (low)
aad:many others Since the1 current methods employed.by the McGuire Nuclear-Station _to verify _'

f testing required by the-Specification"4.5.1.2.c are considered highly reliable-and used: industry _ wide, it is the intent-of Duke Power Company to revise-12 l the specification 4.5~ 1.2.c to clarify that use of an actual or ' simulated -

' water level signal ~in testing is acceptable. The-proposed change supplies-

' a needed ~ clarification and'does :not have any ' adverse safety implication.

Anotherl proposed 1 change concerns Specification 4.5.1.2.d.-- This change

~

requires-that the membrane installed-in the UHI accumulators be replaced.

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every 5 years ~and the removed membrane.be tested to verify that it bursts :

fat a differential' pressure of 40!10 psi._ The 'requirementito test the removed membrane'is being' deleted in Revision V of the' Standard Technical Specifications, for Westinghouse PWRs..This membrane is usually replaced more often than-s

once every_5 years and testing the' removed membrane does not.have any 29

-significant safety' implication.as it.is a post-service, destructive test.

Duke Power Company proposes ~tol delete the requirement to test the removed

. membrane ~from McGuire's Technical ~ Specifications.

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Attachm:nt III a

p. 3 of 3 Analysis'of Significant Hazards Consideration p

Pursuant to the requirements of 10CFR50.91, this analysis provide

' determination that the proposed modifications of the Technical Spec sa do not. involve a significant hazards consideration cations

, as defined by 10CFR50.92.

clarification for Specification 4.5.1.2.c.The proposed chang e

The proposed change contains Another change involves. deletion of the requiremen in the UHI tank to a rupture test af ter it has been removed fr embrane

' Specifications for the Westinghouse PWRs.This requirement om service.

cal of this component does not affect plant operation or performance of UH components. in any manner, thus this requirement is not needed.

The proposed amendments would not:

~

1)

Involve a'significant increase in the probability or consequences of an accident previously evaluated; or 2)

Create the pcssibility of a new or different kind of accident from any accident previously evaluated; or 3)

Involve a significant reduction in a margin of safety.

Based upon.the preceding analysis, Duke Power Company concludes that the proposed amendments do not involve a significant hazard considerati on.

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