ML20128D349

Proposed Tech Specs,Deleting Initial & Subsequent Daily Testing of Diesel Generator When Core Spray Subsystem,Lpci or Containment Cooling Modes of RHR Found Inoperable

ML20128D349
Person / Time
Site:	Quad Cities
Issue date:	06/28/1985
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20128D330	List: ML20128D326 ML20128D349
References
0284K, 284K, NUDOCS 8507050091
Download: ML20128D349 (14)

Text

{{#Wiki_filter:. ATTACHENT 1 PROPOSED REVISION TO DPR-29 Revised Pages: 3.5/4.5-2 3.5/4.5-3 3.5/4.5-4 3.5/4.5-11 3.9/4.9-3 0284K. 8507050091 850628 PDR ADOCK 05000254 P PDR ,

10/00028/ QUAD-CITIES DPR-29

e. Core spray header Ap instrtmentation check once/ day calibrate once/3 months test once/3 months

f. tagic systenn Each functional refueling test outage

2. Frta and after the date that one of the 2. When it is determined that one core core spray subsystens is made or found spray subsystem is i rable, the to be Inoperdle for any reason, operable core spray system and the continued reactor operation is LPCI mode of the M systen shall be permissible only during the succeeding demonstrated to be operable 7 days unless such subsystem is sooner innediately. The operable core spray made operable provided snat durine such subsystem shall be demonstrated to be 7 days all active components of tlie operdle daily thereafter.

other core spray subsystem and the LPCI mode of the e system and the diesel generators required for operation of such components if no external source of power were available shall be operable.

3. The LPCI mode of the M system shall be 3. LPCI mode of the M systen testing operdle whenever irradiated fuel is in shall be as specified in Specifications the reactor vessel and prior to reactor 4.5.A.1.a. b, c, d, and f except that startup from a cold condition. three M pungs shall de1Iver at least 14500 yn against a system head corresponding to a reactor vessel

pressure of 20 psig.

4. From and after the date that one of the 4. When is is detennined that one of the M pumps is made or found to be M peps is incperable, the remaining inoperable for any reason continued active conponents of the LPCI mode of reactor operation is permissible only - the M, containment cooling mode of the during the succeeding 30 days unless M and both core spray subsystems such pump is sooner made operdle, shall be demonstrated to be operable provided that during such 30 da the lamediately and the operable M peps remaining active conponents of he LPCI daily thereafter mode of the M, contalrunent cooling mode of the H, all active components of both core spray subsystems, and the diesel generators required for operation of such components it no external source of power were available shall be operable.

5. From and after that date that the LPCI 5. When it is detennined that the LPCI mode mode of the M system is made or found of the M system is inoperable, both to be inoperable for any reason, core spray subsystems and the 3.5/4.5-2 MIENDIIENT 26

ID/00028/ QUAD-CITIES DPR-29 continued reactor operation is contairment cooling mode of the lum permissible only during the succeeding 7 shall be demonstrated to be operable days unless it is sooner made operable, inmediately and daily thereafter. provided that during such 7 days all active conponents of both core spray subsystems, the containment cooling mode

    ,            of the IDR (including two 15R pumps),

and the diesel generators required for operation of such components if no external source of power were available shall be operable. l l

6. If the requirements of Specification -{

3.5.A cannot be met an order 1 shutdown 1 ofthereactorshallbeinitiaed,and  ! the reactor shall be in the cold I shutdown condition within 24 hours.

8. Contaltnent Cooling Mode of the IGR System B. Containment Cooling Mode of the 15R systen 1.e Both loops of the contaltaent cooling Surveillance of the containment cooling mode mode of the ItR s tem as defined in of the 15R system shall be perfonned as the bases for ifica, tion 3.5.B shall follows:

be operable whenever irradiated fuel is in the reector vessel and prior to 1. IBR service water sabsystem testing: reactor startap from a cold condition. 1.b Frun the effective date of this amendment until July 1,1982, the "A" a. Pump and valve once/3 loop of the containment cooling mode of operability months the 15R system for each reactor may share the Unit 2 "A" and "B" 15R service b. Flow rate test- After pwp water peps using cross tie line each IGR maintenance 1/2-10124-16"-0. Consequently the service water and every 3 requirements of Specifications,3.5.8.2 3xmp shall months and 3.5.8.3 will inpose the deliver at corresponding surveillance testing of least 3500 gpm equ puent associated with both reactors against a pressure if he shared IUR service water pwp or of 198 psig punps, or the cross tie line, are made or found to be inoperable. c. A logic system Each functional refueling test. octage.

2. Fran and after the date that one of the 2. When it is determined that one lum lum service water peps is made or found service water pwp is inoperable, the to be inoperable for any reason, remaining conponents of that loop and continued reactor operation is the other contaltnent cooling loop of permissible only during the succeeding the IDE systen shall be demonstrated to 30 days unless such pop is sooner mode be operable innediately and daily operaDIe, provided that during such 30 thereafter.

days all other active conponents of the containment cooling mode of the f5R ._ system are operable. 3.5/4.5-3 MIENDIIEIU 78

10/00028/ QUAD-CITIES DPR-29

3. From and after the date that one loop of 3. When one loop of the contaltnent cooling the conta.rnent cooling mode of the IHL ~ mode of the IHt system becomes system is made or found to be inoperable iroperable, the operable loop shall be for any reason, continued reactor demonstrated to be operable imediately, operation is permissible only & ring the and daily thereafter.

succeeding 7 days unless such subsystm is sooner made operable, provided that all active components of the other loop of the contalement cooling mode of the IHL systs, both core spray sabsystems, and both diesel rators required for operation of components if no external source of power were available, shall be operable.

4. Contaltnent cooling spray loops m 4. During each 5-year period, an air test required to be operable when the m ctor shall be performed on the drywell spray water temperature is greater tlwn headers and nozzles and a water spray 212*F and prior to reactor startw test perfonned on the torus spray header from a cold condition. Continued aq$ nozzles.

reactor operation is permitted provided that a maxim m of one dr may be inoperable for 30>well days when spray the loop reactor water temperature is greater than 2120F.

5. If the requirements of 3.5.8 cannot be an orderly shutdown shall be met,iated, init and the reactor shall be in a cold shutdown condition within 24 hours.

C. HPCI Subsystem C. HPCI Subsystem Surveillance of WCI subsystem shall be perfonned as follows:

1. The'HPCI subsystem shall be operable 1. HPCI subsystem testing shall be as whenever the reactor pressure is greater specified in Specification 4.5.A.1.a.b, irradiated fuel is in the c, and d except that the HPCI purp t

than 90vesse reactor psig,l, and prior to reactor shalldeliveratleast5000gpmagainst startup from a cold condition. a system head corresponding to a reactor vessel pressure of 1150 psig to 150 psig, and a logic system furectional test shall be performed during each refueling outage.

2. From and after the date that the WCI 2. When it is determined that the HPCI subsystem is made or found to be subsystem is inoperable, the LPCI mode inoperable for any reason continued of the IHL system, both core spray reactor operation is perm,issible only subsystens, the automatic pressure

              & ring the succeeding 1 days unless such                           relief subsystem, and the RCIC system subsystem is sooner made operable.                                thall be demonstrated to be 3.5/4.5-4
                                                                                      ---n ---- . .  ,, -   a , w,.--. .

2ADM00248 QUAD-CITIES DPR-29 3.5 LIMITING CONDITION FOR OPERATION BASES A. Core Spray and LPCI Mode of the RHR System This specification assures that adequate emergency cooling capability is available whenever irradiated fuel is in h reactor vessel. Based on the loss-of-coolant analytical methods described in General Electric Topical Report NE00-20566 and N specific analysis in Reference I, core cooling systems provide sufficient cooling to the core to dissipefe the energy associated with the loss-of-coolant accident, to limit calculated fuel cladding tenperature to less h n 2200*F, to assure that core geometry remains intact, to limit cladding metal-water reaction to less than 15 and to limit h calculated local metal-water reaction to less than 175. The limiting conditions of operation in Specifications 3.5.A.I through 3.5.A.6 specify the conbinations of operable subsystems to assure the availability of the mininnan cooling systems noted above. No single failure of ECCS equipment occurring during a loss-of-coolant accident under Nse limiting conditions of operation will result in inadequate cooling of h reactor core. Core spray distribution has been shown, in full-scale tests of systems similar in design to h t of Quad-Cities I and 2, to exceed h minimum requirements by at least 255. In addition, cooling effectiveness has been demonstrated at less than half h rated flow in simulated fuel assenbiles with heater rods to duplicate h decay heat characteristics of Irradiated fuel. The accident analysis is additional conservative in that no credit is taken for spray cooling of W reactor core before h Internal pressure has fallen to 90 Psig. The LPCI mode of h RHR system is designed to provide emergency cooling to N core by flooding the in event of a loss-of-coolant accident. This system functions in con 61 nation with h core spray system to prevent excessive fuel cladding temperature. The LPCI mode of h RHR system in con 6Ination with h core spray subsystem provides adequate cooling for break areas of approximately 0.2ft aup to and including 4.18 ft athe latter being the double-ended recirculation line break with the equalizer line between the recirculation loops closed without assistance from W high-pressure emergency core cooling subsystems. The allowable repair times are established so that the average risk rate for repair would be no greater than the basic risk rate. The method and concept are described in Reference 3. Using the results developed in this reference, W repair period is found to be less than half W test interval. This assumes that the core spray subsystems and LPCI constitute a one-out-of-two system; however, the combined ef fect of h two systems to limit excessive cladding temperature must also be considered. The test interval specified in Specification 4.5 was 3 months. Therefore, an allowable repair period which maintains j h basic risk considering single failures should be less than 30 days, and this ( specifications is within this period. For multiple failures, a shorter Interval is specified; to improve the assurance h t h remaining systems will function, a daily test is called for. Although it is recognized that the information given in Reference I provides a quantitative method to estimate allowable repair times, the lack of operating data to support W analytical approach prevents complete acceptance of this method at this time, h refore, W times stated in h specific items were established with due regard to judgment. Should one core spray subsystem become Inoperable, the remaining core spray subsystem and the entire LPCI mode of W RHR system are available should the need for core cooling arise. To assure that the remaining core spray and the LPCI mode of the RHR system are available, they are demonstrated to be operable innediately. This demonstration includes a manual initiation of the ptsups and associated valves. Based on judgnents of W reliability of the remaining systems, i.e., the core spray and LPCI, a 7-day repair period was obtained. i l AMENDMENT 61 3.5/4.5-11

10/00028/ quad-CITIES orn-29 unless an additional line is sooner placed in service, providing both the Unit and Unit 1/2 emergency diesel generators are operable.

2. From and after the date the incoming power is not available from any line, continued reactor operation is permissible providing both the Unit and Unit 1/2 emergency diesel generators are operating, all core and containment cooling systems are operable, reactor power level is reduced to 405 of rated, and the NRC is notified within 24 hours of the situation, the precautions to be taken during this period and the plans for prompt restoration of incoming power.

3. From and after the date that one of the two 125/250-volt battery systems is made or found to be inoperable for any reason, continued reactor operation is permissible only during the succeeding 3 days unless such battery system is sooner made operable.

D. Diesel Fuel D. Diesel Fuel 1here shall be a minlaun of 10 000 gallons Once a month the quantity of diesel of diesel fuel sgply on site for each fuel available shall be logged. diesel generator. Once a month a sample of diesel fuel shall be checked for quality. E. Diesel-Generator Operability E. Diesel-Generator Operability

1. Whenever the reactor is in the 1. When it is detenmined that

! Startup/ Hot Stan 6 y or Run mode and the either the unit or shared unit or shared diesel generators and/or diesel Jenerator is inoperable their respective associated buses are all low-pressure core cooling , made or found to be inoperable for any systems and all loops of the reason except as specified in containment cooling mode of the Specification 3.9E.2below continued Ms tem associated with the M tN fig that111ofthelow-pressurecore rwb E ed ton ope inmediately and daily e cooling and all loops of the contaltnent thereafter. cooling mode of the M system associated with the operable diesel 2. During each refueling outage, a generator shall be operable,and two simulated loss of off-site offsite lines are avallalbe. If this powerinconjunctionwithan requirement cannot be met, an orderly ECCS initiation signal test shutdown shall be initiated and the shall be performed on the 4160 volt emergency bus by: f l 3.9/4.9-3 MIENDMENT 77 l r . -- _ _ _ _ . - __ _ _ _ _ _ _ . _ _ _ _ _ _ . - _ __ _ _ _ _ _

ATTACHENT 2 PROPOSED REVISION TO DPR-30 Revised Pages: 3.5/4.5-2 3.5/4.5-3 3.5/4.5-4 3.5/4.5-11 3.9/4.9-3 i l i 0284K

                                                     . - . _ . .              = _ -

ID/00028/ QUAD-CITIES DPR-30 ,

e. Core spray header ap instruentation i check Once/ day i calibrate once/3 months

  -                                                                                      test              once/3              1 months              l F. Logic system      Each functional        twfueling test               outage

2. Fran and after the datt that one qf the 2. When it is determined that one core core spray subsystems is made or round spray subsystem is t rable the to be lnoperable for any reason. -

operable core spray system and the continued reector operation is LPCI mode of the M system shall be geraissible only kring the succeeding demonstrated to be operable I days unless such subsystem is sooner inmediately. The operable core spray made operable provided that during such subsystem shall be demonstrated to be 7 days all active conponents of the operable daily thereafter. other core spray subsystem and the LPCI mode of the IHL system and the diesel generators required for operation of such components if no external source of power were available shall be operable.

3. The LPCI mode of the M system shall be 3. LPCI mode of the M system testing operable whenever irradiated fuel is in shall be as s

the reactor vessel and prior to reactor 4.5.A.1.a. b,pecified in Specifications c, d, and f except that i startup from a cold condition. three M pumps shall deliver at least 14500 gam against a system head corresponding to a reactor vessel pressure of 20 psig.

4. From and after the date that one of the 4. When is is determined that one of the M peps is made or found to be M pups is inoperable. The remaining inoperable for any reason continued active conponents of the LPCI mode of reactor operatia is perm,issible only the M contalrunent cooling mode of the during the suct. -11ng 30 days unless M and both core spray subsystems shall such pop is soom.. made operable, be demonstrated to be operable provided that & rin ssuch 30 days the innediately and the operable M peps remaining active cc % nents of the LPCI daily thereafter.

l mode of the M, contalrunent cooling I mode of the M, all active components l of both core spray subsystems, and the l diesel generators required for operation I of such conponents it no external source of power were available shall be operable.

5. From and after that date that the LPCI 5. When it is determined that the LPCI node node of the M system is made or found of the M system is inoperable, both to be inoperable for any reason, core spray subsystems and the t

I r l 3.5/4.5-2 A!!ENDIII'ITf 27 l l l . .- _ - _ _ _ _ - - . -

1D/00028/ QUMM:111ES DPR-30 continued reector operation is contalrunent cooling mode of the M permissible only during the succeeding 7 shall be demonstrated to be operable days unless it is sooner made operable, inmediately and daily thereafter. provided that during such 7 days all active components of both core spray subsystems, the contaltunent cooling mode

.              of the M (including two M ms),

and the diesel generators required for operation of such components if no external source of power were available shall be operable.

6. If the requirements of Specification 3.5.A ca'wtot be met an orderly shutdown ofthereactorshalIbeinitiated,and the reactor shall be in the cold shutdown condition within 24 hours.

8. Containment Cooling Mode of the M System 8. Containment Cooling Mode of the M system 1.a Both loops of the contaltunent cooling Surveillance of the containment cooling mode mode of the M s tem as defined in of the M system shall be performed as the bases for ifica, tion 3.5.8, shall follows:

be operable whenever irradiated fuel is in the reactor vessel and prior to 1. M service water subsystem testing: reactor startup frem a cold condition. 1.b From the effective date of this amendment until July 1,1982 the "A" a. Pup and valve Once/3 1 the contaltunent cooIIng mode of operability months t M system for each reactor may share the Unit 2 "A" and "S" M service b. Flow rate test- After pump water pays using cross tie line each M maintenance 1/2-10124-16"-0. Con tly, the service water and every 3 irements of ifi tir.cs 3.5.8.2 pe g shall months 3.5.8.3 will the deliver at corresponding surveillance testing of least 3500 gpm equ puent associated with both reactors against a pressure if ne shared M service water pop or of 198 psig pays, or the cross tie line, are made or found to be inoperable, c. A logic system Each functional test. refueling outage.

2. From and after the date that one of the 2. When it is determined that one M M service water pups is made or found service water pwp is inoperable, the to be inoperable for any reason, remaining ccuponents of that loop and continued reactor operation is the other contaltunent cooling loop of permissible only during the succeeding the M systen shall in demonstrated to 30 days unless such pop is sooner mode be operable inmediately and daily operable, provided that during such 30 thereafter.

days all other active conponents of the containment cooling mode of the M system are operable. . t 3.5/4.5-3 AMENDMDri' 72

o 10/00328/ QUAD-CITIES OPR-30

3. From and after the date that one loop of 3. When one loop of the containment cooling the containment cooling mode of the M mode of the M system becomes system is made or found to be inoperable inoperable, the operable loop shall be for any reason, continued reactor demonstrated to be operable immediately operation is permissible only during the and daily thereafter.

Succeeding 7 days unless such subsysten

  .         is sooner made operable, provided that all active caponents of the other loop of the containment cooling mode of the M system both core spray subsystems, andbothdIesel           rators required for operation of          components if no external source of power were available, shall be operable.

During the time 1978 through period April frun April 30, 1978 while17, the 2A Contalrenent Cooling toop of the M System is made inoperable for heat continued reactor exchanger ation is repair,issible per:m beyond the 7-day limitation, unless such loop is sooner made operable, provided that during the time the 7-day limit is exceeded, a visual inspection is performed daily to assure that proper valve alignment and system inte maintained in the "B" M loop.grity is

4. Contaltenent cooling spray loops are 4. an air test required to be operable when the reactor During shall beeach 5-yearon performed period,drywell the spray water temperature is greater than headers and nozzles and a water spray 212'F and prior to reactor startup test perfonned on the torus spray header from a cold condition. Continued and nozzles.

reactor operation is permitted provided that a maxismsn of one drywell spray loop may be inoperable for 30 days when the reactor water tecperature is greater than 212 T.

5. If the requirements of 3.5.8 cannot be an orderly shutdown shall be met int (lated,andthereactorshallbeina cold shutdown condition within 24 hours.

l l-l 3.5/4.5-4 M!EJDMENT 45

  . 2ADM00248 QUAD-CITIES DPR-30 3.5 LIMITING CONDITIONS FOR OPERATION BASES A. Core Spray and LPCI Mode of h RHR System This specification assures that adequate emergency cooling capability is available.

Based on the loss-of-coolant analyses included in References I and 2 and in accordance with 10 CFR 50.46 and Appendix K, core cooling systems provide sufficient cooling to the core to dissipate the energy associated with h loss-of-coolant accident, to limit h calculated peak cladding temperature to less than 2200"F, to assure that core geometry remains intact to limit the corewide cladding metal-water reaction to less than 15 and to limit W calculated local metal-water reaction to less than 175. The alloweble repair times are established so that h average risk rate for repair would be no greater than W basic risk rate. The method and concept are described in Reference

3. Using the results developed in %Is reference, h repair period is found to be less W n half the test interval. This a ssumes ht the core spray subsystems and LPCI constitute a one-out-of-two system; however, the con 61ned ef fect of the two systems to limit excessive cladding temperature must also be considered. The test interval specified in Specification 4.5 wa s 3 months. Therefore, an allowable repair period which maintains h basic risk considering single failures should be less than 30 days, end this specification is within this period. For multiple failures, a shorter Interval is specified; to Igrove W assurance that the remaining systems will function, a daily test i

is called for. Although it is recognized ht h information given in Reference 3 provides a quantitative method to estimate allowable repair times, the lack of operating data to support h analytical approach prevents coglete acceptance of this method at this time. Therefore, h times stated in h specific items were established with due regard to judgment. Should one core spray subsystem become innperable, the remaining core spray subsystem and the entire L"Cl mode of the RHR system are available should h need for core cooling arise. To assure that the remaining core spray and the LPCI mode of h RHR system are available, Wy are demonstrated to be operable innediately. This demonstration includes a manual initiation of the pumps and associated valves. Based on judgments of h reliability of h remaining systems, i.e., the core spray and LPCI, a 7-day repair period was obtained. I Should h loss of one RHR pump occur, a nearly full complement of core and containment cooling equipment is avalleblo. Three RHR pugs in conjunction with the core spray subsystem will perform W core coolirg function. Because of the availability of the majority of the core cooling equipment, which will be demonstrated to be operable, a 30wiey repair period is justified. If the LPCI mode of the RHR system is not available, at least two RHR pug s must be avaiIable to futfiII the containment cooling functlon. The 7-Jsy repair period is set on this basis. B. RHR Service Water The containment cooling mode of N RHR system is provided to remove heat energy from N containment in the event of a loss-of-coolant accident. For h flow specified, h containment long-term pressure is limited to less than 8 psig and is therefore more than ample to provide h required heat removal capability (reference SAR Section 5.2.3.2). N Containment Cooling mode of the RHR5 System consists of two loops. Each loop consists of I Heat Exchanger, 2 RHR Pugs, and h associated valves, piping, electrical equipnent, and instrumentation. The "B" loop on each unit contains 2 RHR Service Water Pumps. During h period from November 24, 1981, to July 1, 1982, the "A" loop on each unit may I utilize the "A" and "B" RHR Service Water Pisaps from Unit 2 via a cross-tie line. After July 1,1982, each "A" loop will contain 2 RHR Service Water Pimps. Either set of

• equipment is capable of performing the containment cooling function. Loss of one RHR service water pug does not seriously Jeopardize W contairment coolirg capability,, as any one of the remaining three pumps can satisfy the cooling requirements. Since inere is some redundancy left, a 30-day repair period is adequate. Loss of one loop of h containment cooling mode of the RHR system leaves one remaining system to perform W containment cooling function. The operable system is demonstrated to be operable each day when the above condition occurs.

l AlIEliDIIEliT 72 3.5/4.5-1l

10/00028/ quad 4:111ES DPR-30 unless an additional line is sooner placed in service, providing both the Unit and Unit 1/2 emergency diesel generators are operable.

2. From and after the date the incaming

  .             power is not available from any line, continued reactor operation is pemissible providing both the Unit and unit 1/? emergency diesel generators are operating, all core and containment cooling systems are operable reactor power level is reduced to 40I, of rated, and the IstC is notified within 24 hours of the situation, the precautions to be taken during this period and the plans for prompt restoration of incoming power.

3. From and after the date that one of the two 125/250-volt battery systems is made or found to be inoperable for any reason continued reactor operation is permiss,ible only during the succeeding 3 days unless such battery system is sooner made operable.

D. Diesel Fuel D. Diesel Fuel Ther9 thall be a minlaun of 10 000 gallons Once a month the quantity of diesel of diesel fuel sgply on site for each fuel available shall be logged. diesel generator. Once a month a sample of diesel fuel shall be checked for quality. E. Diesel-Generator Operability E. Diesel-Generator Operability

1. Whenes?r the reactor is in the 1. When it is detennined that Startupri5t Staney or Run mode and the either the unit or shared unit or shared diesel generators and/or diesel generator is inoperable, their respective associated buses are all low-pressure core cooling made or found to be inoperable for any systems and all loops of the reason except as specified in containment cooling mode of Specification 3.9.E.2below continued the M s tem associated with Erfn# gt EN that all of the low-pressure core og y b N1ftE $*ratEtYbe operable lamediately and daily cooling and all loops of the contairment thereafter.

cooling mode of the M system essociated with the operable diesel 2. During each refueling outage, a generator shall be operable,and two simulated loss of off-site offsite lines are availalbe. If this powerinconjunctionwithan requirement cannot be met, an orderly ECCS initiation signal test shutdown shall be initiated and the shall be performed on the 4160 valt emergency bus by: 3.9/4.9-3 AMENDMENT 71

ATTACHENT 3 EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION Description of Amendment Request Section 3.5 was amended to delete the requirement for both initial and subsequent daily operability testing of the diesel generators when ECCS equipment o: a diesel generator is inoperable. Basis for Proposed No Significant Hazards Consideration Determination The NRC Staff in Generic Letter 84-15 indicated that requirements for testing diesel generators when ECCS equipment is inoperable results in excessive testing and increased degradation of the diesel engines. The Staff encouraged that licensees request these testing requirements be deleted. The amendments submitted for Quad Cities Units 1 and 2 delete the testing requirements when the Core Spray System or LPCI or Containment Cooling Mooes of RHR System are inoperable. This amendment complies with the Staff's position. Furthermore, Commonwealth Edison has extended the guidance in Generic Letter 84-15 to also apply when a diesel generator is found to be inoprable i.e. We have deleted the initial and subsequent daily testing of the operable diesel generator. The Commission has provided standards for determining whether a significant hazards consideration exists [10 CFR 50.92(c)]. A proposed amendment involves no significant hazards consideration if operation of the facility in accordance with the change would not: (1) Involve a significant increase in the probability consequences of an accident previously evaluated: or (2) Create the possibility of a new or different kind of accioent from any accident prev!,;cpsly evaluated: or (3) Involve a significant reduction in a margin of safety. With regards to the first standard, the proposed change eliminates unnecessary diesel generator testing which could only contribute to accelerated wear, in turn, may degrade diesel generator reliability and availability. Therefore, the change does not involve a significant increase in the probability or consequences of an accident previously analyzed..

L As for the second standard, the change would not create the possibility of a new or different kind of accident from any previously evaluated as no physical change will be required at the facility - only a reduction in the frequency of testing. Finally, the proposed change would not involve a significant reduction in a margin of safety because demonstration of d.'esel generator operability will be maintained and yet with the elimination of unnecessary testing the overall performance of the diesel generator would be maintained if not improved. Therefore, since the application for amendment involves a proposed change that meets the standards provided in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists, Commonwealth Edison has made a proposed determination that the application involves no significant hazards consideration. I 0284K h _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _}}