Text

Proposed Tech Specs,Revising TS 3/4.7.5, Ultimate Heat Sink & Associated Bases to Support SG Replacement & Incorporate Recent UHS Design Evaluations
	ML20148B615
Person / Time
Site:	Byron
Issue date:	05/06/1997
From:	; COMMONWEALTH EDISON CO.
To:	;
Shared Package
ML20148B612	List: ML20148B607; ML20148B615;
References
	NUDOCS 9705130177
	Download: ML20148B615 (9)
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ATTACIIMENT B MARKED UP PAGES FOR PROPOSED CIIANGES TO APPENDIX A,TECIINICAL SPECIFICATIONS, OF FACILITY OPERATING LICENSES NPF-37 and NPF-66 BYRON NUCLEAR POWER STATION UNITS I and 2 Revised Pares 3/4 7-13 3/4 7-14 3/4 7-14a 3/4 7-15 B 3/4 7-3 B3/4 7-4 i

9705130177 970506 I

PDR ADOCK 05000454 P

PDR

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PLANT SYSTEMS 3 /4.7.5 ULTIMATE HEAT SINK LIMITING CONDITIONS FOR OPERATION The ultimate heat sink (UHS) shall be OPERABLE with:

f.

3.7.5 A water leve1 Aeach of the UHS cooling tower basins of at least

,2 D

A total of '6 fans OPERABLE (high speed),

b.

Two 0PERABLE essentia'i service water makeup pumps, c.

3 An essential service water pump discharge temperature of 1;;; th:r.

d.

I'i'i R.fi.f..,f 2...*3..$[' _fE_$*I^r#r"Y E l

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6 Two OPERABLE UHS cooling tower basin level switches, e.

y The National Weather Service (NWS) does not forecast the Rock River f.

level to exceed 702.0 feet MSL, Rock River water level greater than 670.6 feet MSL, and g.

The National Weather Service (NWS) has not issued a tornado watch h.

that includes the Byron Site Area.

S APPLICABILITY: MODES 1, 2, 3, and 4 ACTION:

c7o L

With a water level of less than fiHi-in either UHS cooling tower a.

basin, restore the water level to at least in ea:h UHS cooling tower basin within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months or be in HOT STANDBY within the neict 6 -- --

hours and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

With only'5 fans OPERABLE, within I hour verify the 5 OPERABLE fans

(

b.

7 are capable of being powered by their respective emergency diesel Restore at least 6 fans to OPERABLE status within "7

pnerators.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and (SLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

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AMENDNENTNO.[

BYRON - USS 1 & 2 3/4 7-13 9

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INSERT A 1) 5 80 F; or 2) 5 90 F, with 6 OPERABLE fans running in high speed; or 3)

$ 96 F, with > 6 OPERABLE fans running in high speed.

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LIMITING CONDITION FOR OPERATION (Continued)

. ACTION (Continued) c.

With one essential service water makeup pump inoperable, within p

l 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months either:

1)

Restore the inoperable essential service water makeup pump to OPERABLE status, or -

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2)

V3rify that the same train deep well pump is OPERABLE with both s

'T UHS cooline tower basin levels i%fk Continue to verify both 907o basin levels are t'425 every two hours and restore the (g) inoperable essential service water makeup pump to OPERABLE i

status within *7 days.

(*This can be extended to 14 days for h'

Essential Service Water Makeup pump inspection and extended maintenance during the time when at least one unit is in MODE 5

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or6.) The provisions of Specification.3.0.4 are not i

applicable.

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3)

Otherwise be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and 5

t in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

/

d.

With the essential service water pump discharge water temperature not i

meeting the above requirement, be in at least NOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

c' e.

1)

With one UHS cooling tower basin switch inoperable:

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,M a)

Restore the level switch to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months

( Oaf or verify both basin levels are 2425-within the next hour 10 and every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thereafter. The provisions of Specification 3.0.4 are not applicable.

[-

b)

Otherwise be in at least HOT STANDBY within the next

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j 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

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2)

With both UHS cooling tower basin level switches inoperable:

a)

Restore one level switch to OPERABLE status within I hour

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A and follow the provisions of 3.7.5.e.1 above, or verify qg g both basin levels are 2%ft-within the next hour and every e

t 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thereafter.

The provisions of Specification 3.0.4 are not applicable.

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A

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b)

Otherwise be in at least HOT STANDBY within the next

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6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

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3)

With any UHS cooling tower basin level switch inoperable for more than 30 days, prepare and submit a special report

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to the Commission pursuant to Specification 6.9.2 within the next 10 days outlining the cause of the inoperability

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and the plans for restoring the switch (es) to OPERABLE

)

status.

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f.

With Rock River water level forecasted by NWS to exceed 702.0 feet

^ " " "

MSL:

BYRON - UNITS 1 & 2 3/4 7-14 AMENDMENT N0.

PLANT SYSTEMS r

LIMITING CQiiDITION FOR OPERATION (Continued)'

ACT10N (Continued) 1)

Within one hour verify that both deep well s are OPERABLE with both UHS cooling tower basin levels 2 and at least once every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thereafter, verify both basin levels are 2425..

The provisions of Specification 3.0.4 are not applicable.

gcg With one deep well pump inoperable restore both deep well oumps 2) to OPERABLE status with both basin levels 21tMbefore the Rock River level exceeds 702 feet MSL or within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , whichever comes first and follow provisions of ACTION f.1).

Othentise be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months an$

3) i SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

i f

With Rock River water level at or below 670.6 feet MSL within one g.

hour verify Rock River level and flow, and:

i If Rock River level > 664.7 feet MSL and flow 2 700 cfs verify 1)

Rock River level > 664.7 feet MSL and flow 2 700 cfs every i

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter. The provisions of Specification 3.0.4 are not applicable.

If Rock River level s 664.7 feet MSL or flow < 700 cfs, within l

2) one hour:

a)

Verify that both deep well pumps.are OPERABLE with both UHS cooling tower basin levels 2 M and at least once every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thereafter, verify both basin levels are 2125.

l The provisior.s of Specification 3.0.4 are not applicable.

O,]o b)

With one deep well pump inoperable, within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restor both deep well pumps to OPERABLE status with both basin levels 2 Set-and follow provisions of ACTION g.2)a).

c)

Otherwise be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and at least COLD SHUTDOWN within the subsequent i

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

h)

With a tornado watch issued by NWS that includes Byron site area:

1)

Within one hour verify that both deep well pumps are OPERABLE with both UHS cooling tower basin levels 2 42Fand at least 1

once every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thereafter, verify,oth basin levels 2 The provisions of Specification 3.0.4 are not applicable.

40%

With one deep well pump inoperable, within 30 minutes take 2) action to restore both Aeep well oumos to OPERABLE status with both basin levels 21ff and at least once every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thereafter, verify both basin levels 1-Sek <

3)

Otherwise be in H0T STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

l BYRON - UNII5 1 & 2 3/4 7-14a AMENDMENT NO.

PLANT SYSTEMS h

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. SURVEILLANCE RE001REMENTS 4.7.5 The UHS shall be determined OPERABLE at least once per:

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months by verifying the water level in each U S cooling tower l

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a.

basin to be greater than or equal to Jef, g

b.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months by verifying the essential service water pump discharge l

water temperature is within its limit, i

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months by verifying that the Rock River water level is within its c.

limits, 2.

i d.

31 days by starting from the control room each UHS cooling tower fan that is required to be OPERABLE and not already in high speed -

t operation and operating each of those fans in high speed for at least

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15 minutes, e.

31 days by 1)

Verifying that the fuel supply for each diesel powered essential service water makeup pump is at least 36% of the fuel supply tank volume, 2)

Starting the diesel from ambient conditions on.a low basin level G

test signal and operating the diesel powered pump for at least 30 minutes, 3)

Verifying that each valve (manual, power operated, or automatic) in the flow path is in its correct position, i

4)

Starting each deep well pump and operating it for at least 15 minutes and verifying that each valve (manual, power-operated, or automatic) in the flow path is in its correct

position, f.

92 days by verifying that a drain sample of diesel fuel from the fuel I

storage tank, obtained in accordance with ASTM D4057-1981, is within the acceptable limits specified in Table 1 of ASTM-D975-1977 when i

checked for viscosity, water, and sediment, 0

g.

18 months by performing a CHANNEL CALIBRATION on each of the UHS

/

cooling tower basin level switches, h.

18 months by subjecting each diesel that powers an essential service water makeup pump to an inspection in accordance with procedures prepared in conjunction with its manufacturer's recommendations for the class of service and by cycling each testable valve in the flow path through at least one complete cycle of full travel, g-1.

18 months by verifying each deep well pump will provide at least 550 gpa flow rate, and i

j. ' 18 months by visually inspecting and verifying no abnormal breakage

{

or degradation of the fill materials in the UHS cooling tower.

BYRON,,- UNITS 1 & 2 3/4 7-15 AMENDMENTNO.[

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u ELANT SYSTEMS BASES j

3/4.7.1.5 MAIN STEAM LINE ISOLATION VALVES The OPERABILITY of the main steam line isolation valves ensures that no more than one steam generator will blowdown in the event of a steam line rupture. This restriction is required to: (1) minimize the positive reactivity effects of the Reactor Coolant System cooldown associated with the blowdown, and (2) limit the pressure rise within containment in the event the 4

steam line rupture occurs within containment.- The OPERABILITY of the main steam isolation valves within the closure times of the Surveillance Requirements are consistent with the assumptions used in the safety analyses.

3/4.7.2 STEAM GENERATOR PRESSURE / TEMPERATURE LIMITATION The limitation on steam generator pressure and temperature ensures that the pressure-induced stresses in the steam generators do not exceed the

~

maximum allowable fracture toughness stress limits. The limitations of 70*F and 200 psig are based on a steam generator RT of 60*F and are sufficient er i

to prevent brittle fracture.

3/4.7.3 COMPONENT COOLING WATER SYSTEM The OPERABILITY of the Component Cooling Wattr System ensures-that sufficient cooling capacity is available for continued operation of safety-related equipment during normal and accident conditions. The redundant i

cooling capacity of this system, assuming a single failure, is consistent with the assumptions used in the safety analyses.

i 3/4.7.4 ESSENTIAL SERVICE WATER SYSTEM The OPERABILITY of the Essential Service Water System ensures that sufficient cooling :apacity is available for continued operation of safety-related equipment during normal and accident conditions. The redundant cooling capacity of this system, assuming a single failure, is consistent with the assumptions used in the accident conditions within acceptable limits.

Essential Service Water pump in the shut dowr unit ensures the availability of

[)

The OPERASILITY of the unit crosstie along with the availability of an sufficient redundant cooling capacity for ths,p;4tating unit.m

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3/4.7.5 ULTIMATE HEAT SINK hn kmpe m hy c.

A_A A The limitations on the ultimate heat in ensure 1) sufficient cooling capacity is available for continued operat on of safety related equipment i

during normal and accident conditions and 2) adequate inventory is available to provide a 30-day cooling water supply to safety related equipment. The limiting design basis event for the UHS s a loss of coolant accident coincident with a loss of offsite power on one unit, in conjunction with the yethee unit proceeding to an orderly shutdown an6 cop]d, rom maximum power.

pModeJ.as_sumingasingleactivefailure.

Inseft BYiON UNITS 1 1 2 B 3/4 7-3 AMENDMENTNO.[

PLANT SYSTEMS BASES ULTIMATE HEAT SINK (Continued)

X Insert The minimum UHS cooling tower basin water level ef 50% indisetud d.

. (673.75 fast et,;;; ".::: :: L;;;l) and the service water pump discharge temperature limits assure that adequate thermal capacity is available in the SX water inventary to absorb the initial accident heat input. Six ei sig t

ling t:= f:- are re-"f red te b :;;;44'.; ;.~T):_3X ceeling te.i ei beiin:51: :: th:t-of g fans-are-evetleble-after-a-singl: ::th:

temperature will remain less than 100*F.

h) gQ A-vei n f 2^^.000 cellens != ee 4 ceeliaa t E r b??ir. 1 :":.' b' supply-the-auxiliary f;;d.;;ter ;yst =. The4 basin inventory is -alee-available for transporting heat from safety related equipment during normal and accident conditions. Due to evaporation, blowdown, and auxiliary feedwater supply the bas.in inventory alone is not adequate for the required 30-day cooling water j

supply, there

-maheupssystems are provided to replenish the basin j

inventory.

n s.c < t d

(

Adequate inventory is maintained by the SX makeup system that uses the i

Rock River as a water source. The SX makeup system is designed to withstand all design basis natural phenomena events and combination of events except for seismic events during low Rock River flow or level (loss of SX makeup pump suction), tornado, and river flood. A backup makeup system uses the deep wells as a water source. The deep well system is designed for seismic, i

tornado, and river flood events.

)

i Each essential service water makeup pump is powered by a diesel engine 1

with a fuel supply adequate for approximately 3 days of operation.

s Achievement of the design basis 30-day operation is dependent upon successful i

implementation of plant procedures to replenish the fuel supply following

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design basis events.

The operability requirements for the basin level switches, Rock River 4

l 1evel limitations, and tornado watch limitations assure that the SX makeup i

system is available.to provide makeup water. The corresponding actions assure that the backup deep well system is available and increases the minimum cooling tower basin level to assure that adequate basin water inventory is j

available after a two hour delay to manually start the deep well pumps after C

an accident.

f l

3/4.7.6 CONTROL ROOM VENTILATION SYSTEM The OPERABILITY of the Control Room Ventilation System ensures that: (1) the ambient air temperature does not exceed the allowable temperature for continuous duty rating for the equipment and instrumentation cooled by this system, and (2) the control room will remain habitable for operations personnel during and following all credible accident conditions. Operation of the system with the heaters operating for at least 10 continuous hours in a 31-day. period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters.

The OPERABILITY of this system in conjunction with control room 1

BYRON - UNITS 1 & 2 8 3/4 7-4 ANENDMENT NO.

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INSERT B 1

The limiting design basis event for the UHS makeup is a two unit trip from full power, assuming a single active failure and loss of the normal auxiliary feedwater supply source.

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i INSERT C Depending on basin temperature, six or more fans are required to be available or i

running so that the required number of fans are available after a single active l

failure to assure basm I

t INSERT D SX basin temperature and SX pump discharge temperature are essentially the same since the piping from the tower basins to the pumps is underground and the temperature increase across the SX pump at accident flow rates is negligible.

Temperature is measured at the discharge of each SX pump.

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INSERT E j

The makeup systems are designed to provide adequate makeup for normal and accident conditions concurrent with the use of the essential service water system as i

the supply source for the auxiliary feedwater system, assuming a single active failure.

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t t

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1 ATTACIIMENT C EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATIONS FOR PROPOSED CIIANGES TO APPENDIX A, TECHNICAL SPECIFICATIONS, OF FACILITY OPERATING LICENSE NPF-37

)

Commonwealth Edison Company (Comed) has evaluated this proposed amendment and has determined that it involves no significant hazards considerations. According to Title 10, Code of Federal Regulations, Part 50, Section 92, Paragraph c ( 10 CFR 50.92 (c)), a proposed amendment to an operating license involves no significant hazards considerations if operation of the facility in accordance with the proposed amendment would not:

1. Involve a significant 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 margin of safety.

A.

INTRODUCTION Commonwealth Edison Company (Comed) proposes to amend Technical Specification (TS) 3/4.7.5, " Ultimate Heat Sink" and the associated Bases for Byron Nuclear Power Station, Units 1 and 2, to support steam generator replacement and to incorporate recent Ultimate Heat Sink (UHS) design evaluations. The proposed TS changes revise the following Limiting Conditions for Operation (LCOs) for the UHS: the minimum water level in each essential service water (SX) cooling tower basin, the maximum SX pump discharge temperature, and the number of fans supporting heat removal.

B.

NO SIGNIFICANT HAZARDS ANALYSIS

1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Technical Specification 3/4.7.5 establishes the operating requirements for the UHS. Operation of the UHS within its design basis ensures the following:

I

1) suflicient cooling capacity is available for continued operation of safety related equipment during normal and accident conditions and 2) adequate inventory is available to provide a 30-day cooling water supply to safety related equipment. Design analyses supporting the proposed TS changes provide full qualification of the UHS.

A loss of offsite power (LOOP) coincident with a loss of coolant accident (LOCA), designated a LOOP /LOCA, on one unit, in conjunction with the non-accident unit proceeding to an orderly shutdown and cooldown from maximum power using normal operating procedures, remains the limiting design basis event for the UHS basin temperature.

The proposed changes to the UHS LCO for basin temperature and the number of fans running do not, in themselves, factor into any initiating event for Updated Final Safety Analysis Report (UFSAR) Chapter 15 accidents and, consequently, do not increase the probability of occurrence for these previously evaluated accidents.

The UHS plays a vital role in mitigating the consequences of any accident or transient. The proposed changes will ensure that the minimum conditions necessary for the UHS to perform its design functions will always be met.

Engineering calculations demonstrate that the SX pump discharge design temperature limit of 100 F, which was assumed as an initial input for the accident analyses, is preserved. Consequently, the proposed changes to the i

number of cooling tower fans required to be running in high speed relative to j

the SX pump discharge temperature do not increase the consequences of any accident previously evaluated.

The two unit plant trip from full power with the loss of normal auxiliary feedwater (AF) supply source has been shown to be more limiting than the LOOP /LOCA scenario for UHS makeup and volume considerations.

The proposed changes to the UHS LCO for minimum basin water level do not, in themselves, factor into any initiating event for the UFSAR Chapter 15 accidents and, consequently, do not increase the probability of occurrence for these previously evaluated accidents.

The proposed changes to increase the minimum basin water levels ensure there is a suflicient volume ofwater in the UHS basin at all times. With these proposed changes, the UHS will perform its design function for the required 30 days, and the consequences of any accident presiously evaluated are not increased.

2

2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The supporting analyses for the revised TS 3/4.7.5 do not involve a new or different kind of accident from any accident previously evaluated. The proposed limits on SX basin minimum water level, maximum basin temperature, and the number of fans operating are within the design capabilities of the UHS, and ensure that the UHS will always be in a condition to perform its design function in the event of an accident or transient. New and revised analyses which support the requested TS changes ensure the full qualification of the UHS. The UHS will not be operated in a different manner such that the possibility of a new or different kind of accident would be I

created. Consequently, these changes do not create the possibility of a new or different kind of accident from those previously evaluated.

3. The proposed change does not involve a significant reduction in a margin of safety.

The proposed limits on SX basin minimum water level and maximum temperature are based on the results of new and revised design analyses which ensure that the margin of safety is not reduced. Required operator actions with appropriate times are incorporated into the analyses. The new limits on temperature and volume will ensure that, under the most limiting accident or transient scenario, cooling water from the basin will meet the accident analyses SX design temperature limit of 100 F and will ensure that adequate inventory is available to provide a 30-day cooling water supply to safety related equipment. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above evaluation, Comed has concluded that the proposed changes involve no significant hazards considerations. In addition, the proposed changes will not result in a change in the type or amount of any efIluents released offsite nor will the changes result in an increase in individual or cumulative occupational radiation exposure.

I 3

1

ATTACIIMENT D l

l ENVIRONMENT ASSESSMENT FOR PROPOSED CHANGES TO APPENDIX A,TECIINICAL SPECIFICATIONS, OF FACILITY OPERATING LICENSES NPF-37 & NPF-66 Commonwealth Edison Company (Comed) has evaluated this proposed hcense amendment request against the criteria for identification oflicensing and regulatory actions l

requiring environmental assessment in accordance with Title 10, Code of Federal Regulations. Part 51, Section 21 (10 CFR 51.71). Comed has determined that this proposed license amendment request meets the criteria for a categorical exclusion set forth in 10 CFR 51.22(c)(9). This determination is based upon the following:

1.

The proposed licensing action involves the issuance of an amendment to a license for a reactor pursuant to 10 CFR 50 which changes a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or which changes an inspection or a surveillance requirement. This proposed License Amendment Request will allow Comed to revise the minimum water level in each essential service water (SX) cooling tower basin, the maximum SX pump discharge temperature, and the number of fans supporting heat removal; 2.

this proposed License Amendment Request involves no significant hazards consideration as shown in Attachment C; 3.

there is no significant change in the types or significant increase in the amounts of any effluent that may be released offsite; and 4.

there is no significant increase in individual or cumulative occupational radiation exposure.

Therefore, pursuant to 10 CFR 51.22(b), neither an environmental impact statement nor an environmental assessment is necessary for this proposed License Amendment Request.

4 I

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ML20148B615

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