ML20196B410
| ML20196B410 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 11/25/1998 |
| From: | COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20196B400 | List: |
| References | |
| NUDOCS 9812010096 | |
| Download: ML20196B410 (23) | |
Text
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ATTACHMENT B l
. MARKED UP PAGES FOR '
PROPOSED CHANGES TO APPENDIX A TECHNICAL SPECIFICATIONS OF FACILITY OPERATING LICENSE NPF-72 AND NPF-77 1
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. IMPROVED TECHNICAL SPECIFICATIONS '
REVISED SECTIONS:
3.8.4 REQUIRED ACTIONS D, E, F ASSOCIATED BASES 3.8.9 REQUIRED ACTION C.2 ASSOCIATED BASES SURVEILLANCE REQUIREMENT SR 3.8.4.7 j i
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l 9812010096 981125 9 l PDR ADOCK 05000456:'
P PDR y Page1of1 Attachment B-Marked Up T/S Pages
DC Sources-Ooerating 3.8.4 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C. One DC electrical C.1 ---------NOTE--------
power division Only required when crosstied to opposite unit has an opposite-unit DC inoperable battery.
electrical power ---------------------
subsystem with an inoperable source. Verify opposite-unit Once per while opposite unit is DC bus load 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in MODE 5. 6. or s 100 amps for AT&T defueled. (s 200 amps for C&D).
AND C.2 Open at least one 7 days crosstie breaker between the crosstied divisions.
D. One DC electrical D.1 Open at least one 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> power division crosstie breaker crosstied to between the crosstied opposite-unit DC divisions. +
electrical power 6 subsystem when replacing Unit 2 AT&T E+
batteries while e(
c3 opposite unit is in ' CP MODE 1. 2. 3. or 4. [d (continued)
BRAIDWOOD - UNITS 1 & 2
DC Sources-Operating 3.8.4 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME E. One DC electrical E.1 Restore DC electrical 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> power subsystem inoperable for reasons power subsystem to OPERABLE status. l\.
Other than Condition 4-A. B. C. or D. DB AU c
E.2 ---------NOTE-------- e Only applicable when replacing Unit 2 AT&T y
batteries. m
%g Restore DC electrical 10 days E '
power subsystem to ?
OPERABLE status. 9 c
F. Required Action and Associated Completion F.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> l/ )
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Time not met. 6N2 l l
F.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> l SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY
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SR 3.8.4.1 Verify battery terminal voltage is 7 days 2130.5 V for AT&T (2127.6 V for C&D) on float charge.
(continued)
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BRAIDWOOD - UNITS 1 & 2
DC Sources -Operating 3.8.4 SURVEILLANCE REOUIREMENTS (continued)
VEILLANCE FREQUENCY SR 3.8.4.6 Verify each battery charger supplies a load 18 months equal to the manufacturer's rating for ,
= 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
- 3R 3.8.4.7 NOTES '
- 1. The modified performance discharge test in SR 3.8.4.8 may be performed in.
lieu of the service test in SR 3.8.4.7.
). 2. This Surveillance shall not be
. performed in MODE 1. 2. 3. or 4. 4 Verify battery capacity is adequate to . 18 months i supply, and maintain OPERABLE status, the required emergency loads for the design duty cycle whan subjected to a battery service test.
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BRAIDWOOD - UNITS 1 & 2 3.8.4 - 4 12/17/07 h visicr. C- .
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DC Sources-Operating
. 3.8.4 SURVEILLANCE REOUIREMENTS (cont 1nued) l 1'
' i SURVEILLANCE. FREQUENCY )
4 SR 3.8.4.8 NOTE This Surveilltnce shall not be performed in
- MODE 1, 2, 3, or 4. . ,
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Verify battery capacity is = 95% for AT&T 60 months -
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(= 80% for C&D) of the manufacturer's '
rating when subjected to a performance E
- discharge test or a' modified performance %
1 discharge test. 12 months when ! ~ !
adthonor
&ceg, I:en a4 RepL4cemes oF/eT{T 6 m.enes has reached 85%
of the expected {h'
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i life with. Cb i
, capacity < 100%
of ig f ;,
i manufacturer's Oc l rating ,
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24 months when l battery has i reached 85% of !
the expected i life with capacity = 100%
of manufacturer's rating l-k BRAIDWOOD - UNITS 1 & 2 3.8.4 - 5 '
Distribution Systems-Operating i 3.8.9 ;
i ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME l, A. One AC electrical A.1 Restore AC electrical 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> power distribution power distribution ;
subsystem inoperable. subsystem to JPERABLE AND l status.
- 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />.from discovery of .
failure to meet LC0 !
B. One AC instrument bus B.1 Restore AC instrument 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> !'
electrical power bus electrical power distribution subsystem distribution AND :
inoperable, subsystem to OPERABLE status. 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> from discovery of j failure to meet LCO C. One DC electrical C.1 Restore DC electrical- 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> power distribution power distribution subsystem inoperable. subsystem to OPERABLE AND status.
16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> from discovery of failure to meet LC0
% OR C-U C.2 ---------NOTE--------
g Only applicable when
% replacing Unit 2 AT&T batteries.
C, _____________________
Ww if gg Restore DC electrical power distribution 10 days subsystem to OPERABLE status.
BRAIDWOOD - UNITS 1 & 2
I B 3.8.4 l
INSERT D.1 Dl l Condition D is only applicable when replacing the Unit 2 AT&T batteries (i.e.,
l old batteries) with the C&D batteries (i.e., new batteries). In order to i replace the AT&T batteries, temporary batteries will be connected to the DC i bus after the old batteries are disconnected. The temporary batteries will be l connected to the DC bus through the same breaker used to connect the old l batteries. In order to prevent de-energizing the DC bus while connecting the l temporary batteries, the Unit 2 DC bus will be crosstied to Unit 1. Once the i existing charger and the temporary batteries are connected to the DC bus, at least one crosstie breaker will be opened. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time allows sufficient time to safely disconnect the old batteries and reconnect the temporary batteries and existing charger to the Unit 2 DC bus. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time also allows sufficient time to safely disconnect the temporary batteries and reconnect the new batteries and existing charger to the Unit 2 DC bus. This Completion Time is acceptable based on compensatory measures to open the DC crosstie breaker during adverse conditions.
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B 3.8.4 INSERT E.2
. Required Action E.2 is only applicable when replacing the Unit 2 AT&T batterles (i.e. old batteries) with the C&D batteries (i.e. . new batteries).
In order to replace the AT&T batteries, temporary batteries will be connected to the DC bus after the old batteries are disconnected. The temporary batteries will be the AT&T batteries previously removed on Unit 1. Therefore, the temporary batteries will fulfill the same safety related requirements as the old batteries, and the DC electrical power subsystem will be in accordance with current design basis. However, due to not being seismically mounted. the DC electrical power subsystem will be inoperable during the period when the temporary batteries are installed. The 10 day Completion Time allows sufficient time to safely perform the activities associated with replacing the AT&T batteries with the C&D batteries. The 10 day Completion Time is based on the redundant capabilities afforded by the OPERABLE DC electrical power subsystem and the low probability of an event occurring during this period.
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B 3.8.9 !
INSERT C.2_ !
Required Action C.2 is only applicable when replacing the Unit 2 AT&T batteries (1..e., old batteries) with the C&D batteries (i.e. , new batteries). l In order to replace.the AT&T batteries, temporary batteries will be connected ;
to the DC bus after. the old batteries are disconnected. The temporary ,
c batteries will be the AT&T batteries previously removed on Unit 1. Therefore. l the temporary batteries will fulfill the same safety related requirements as l the old batteries, and the DC electrical power subsystem will be in accordance l with current design basis. However due to not being seismically mounted. the i DC. electrical power subsystem will be inoperable during the period when the l temporary batteries.are installed. The 10 day Completion Time allows sufficient time to safely perform the activities associated with replacing the '
AT&T batteries with the C&D batteries. The 10 day Completion Time is based on the redundant capabilities' afforded by the OPERABLE DC electrical power !
subsystem and.the low probability of an event occurring _during this period. ;
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I DC Sources-Doeratino i B 3.8.A _ !
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EASES E!
ArTIONS ':cr.tinucC ,
GIA*o G.2- I$N9 hc.erYD.{ Condition E. $
to comple/ represents one division with a loss of ao111ty tely respond to an event, and a potentla,1 loss of
' ability for the DC divisi~on to remain energized ouring normal operation. It is. therefore. imperative that the operator's attention focus on stabilizing the unit.
minimizing the potential for complete loss of DC power to !
the affected division. The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> limit is consistent with l
the allowed time for an inoperable DC distribution system division. l i
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inoperable (e.g. ,quired DC electrical inoperable battery orpower subsystems one DC division is I crosstied to the opposite-unit DC division that does not have an inoperable battery charger), the remaining DC electrical power subsystem has the capacity to support a safe shutdown and to mitigate an accident condition. Since a subsequent worst case single failure would, however.
result in the complete loss of the remaining 125 VOC electrical power subsystems with attendant loss of ESF functions, continued power operation should not exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Time is based on Regulatory Guide 1.93 (Ref. 8) and reflects a reasonable time to assess '
unit status as a function of the inoperable DC electrica power subsystem and. if the DC electrical power sobsystem s not restored to OPERABLE status, to prepare to effect an
~ orderly and safe unit shutdown, CLSaT E,2j >F D i E
/1andY2 $
If the inoperable DC electrical power subsystem cannot be restored to OPERABLE status, or the crosstie breaker (s) cannot be opened, within the required Completion Time, the i unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable.
based on operating experience. to reach the required unit conditions from full power conditions in an orderly manner
[ and without challenging plant systems. The Completion Time
- to bring the unit to MODE A is consistent with the time l required in Regulatory Guide 1.93 (Ref. 8).
4 BRAIDWOOD - UNITS 1 & 2 B 3.8.4 -8 1
.- 1 Distribution Systems-Operating !
B 3.8.9 l
BASES i ACTIONS (continued) l The second Completion Time for Required Action C.1 i establishes a limit on the maximum time allowed for any '
combination of required distribution subsystems to be -
inoperable during any single contiguous occurrence of :
failing to meet the LCO, If Condition C is entered while. '
for instance an AC bus is inoperable and subsequently '
returned OPERABLE. the LCO may already have been not met for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This could lead to a total of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, '
since initial failure of the LCO. to restore the DC !
distribution system. At this time, an AC bus could again become inoperable, and DC distribution restored OPERABLE. l This could continue indefinitely.
This Completion Time allows for an exception to the normal
" time zero" for beginning the allowed outage time " clock." -L This will result in establishing the " time zero" at the time C -
the LCO was initially not met, instead of the time $ !
Condition C was entered. The 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> Completion Time is an C
- heri- C acceptable limitation on this potential to fail to meet the LCyndefinitely. 1 g. ;
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0,1 and 0.2 ff,Oc i If the inoperable distribution subsystem cannot be restored to OPERABLE status within the required Completion Time, the l
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unit must be brought to a MODE in which the LCO does not i apply. To achieve this status, the unit must be brought to ;
at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable. !
based on operating experience. to reach the recuired unit t conditions from full power conditions in an orcerly manner and without challenging plant systems. <
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i With two electrical power distribution subsystems inoperable that result in a loss of safety function., adequate core
! cooling, containment OPERABILITY and other vital functions '
l for DBA mitigation would be compromised, and immediate plant shutdown in accordance with LCO 3.0.3 is required.
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BRAIDWOOD - UNITS 1 & 2 -
B 3.8.9 - 9 1
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ATTACHMENT C EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION FOR PROPOSED CHANGES TO APPENDIX A TECHNICAL SPECIFICATIONS OF FACILITY OPERATING LICENSE NPFJ2 AND NPF-77 Comed has evaluated the proposed amendment and determined that it involves no significant hazards consideration. According to 10 CFR 50.92(c), a proposed amendment to an operation license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:
Involve a significant increase in the probability or consequences of an accident previously evaluated; or Create the possibility of a new or different kind of accident from any accident previously evaluated; or Involve a significant reduction in a margin of safety.
Comed proposes a one time change to Improved Technical Specification (ITS) 3.8.4, DC l
Sources-Operating and ITS 3.8.9 Distribution Systems-Operating. This change is j requested to support the replacement of the Unit 2125 volt DC ESF batteries and racks.
The proposed one time change will replace ITS 3.8.4 Required Action D with Required Actions necessary to support an on-line change out. One of the Required Actions will permit operation for 10 days in MODES 1-4 while one DC division is connected to the
' existing safety related battery charger and a temporary, previously qualified safety related, 1 but non-seismically mounted battery. This alignment will be used while the current !
battery is replaced and tested. An additional 8-hour Completion Time is being proposed to allow the bus to be crosstied during the disconnection of the current battery and the re-conriection of the charger and temporary battery. This Completion Time will also be entered during reconnection of the new battery (once installed) and removal of the temporary battery. The above evolution will be performed for each DC Division on Unit 1 2.
The proposed one time change to ITS 3.8.9 will add a Required Action C.2 which allow a Completion Time of 10 days for restoring DC electrical power distribution subsystem to OPERABLE status, which is also necessary to support the change out of batteries. l All required surveillances for the temporary and new batteries to demonstrate operability !
will be performed prior to connecting to the DC Bus.
The determination that the criteria set fonh in 10 CFR50.92 are met for this amendment request is indicated below:
Page 1 of 4 Attachment C-Significant Hazards Consideration 1
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Does the change involve a significant increase in the probabiihy or consequences of !
.an accident previously evaluated? l 1
During the replacement of the existing batteries, a temporary battery bank will !
provide the same function as the AT&T batteries being removed. Even though .
this temporary battery will not be seismically mounted, due to its location in the Turbine Building,it is the safety related AT&T battery which was previously qualified and used to perform this function on Unit 1.
While the temporary battery is being connected, the DC bus will be sr yplied by the existing crosstie with Unit 1. Similar crosstie conditions are allowe inder the present Improved Technical Specifications.
The DC system is normally supplied by the AC system through the ESF battery charger. The essential function of the DC system battery is to supply control power necessary to start and load the Diesel Generators. Once the Diesel Generators are on line, the DC system will be supplied via the battery charger.
However, the ESF batteries have been sized for one hour to provide additional assurance that the critical DC loads are available in the event of a loss of a battery charger.
During the 10 day Completion Time when the temporary battery and the ESF charger are supporting the bus, the ability of that DC Division to mitigate an event / accident is unchanged except for its ability to cope with a seismic event.
However, the probability of a seismic event concurrent with the 10 day Completion Time is extremely small. During a seismic event, one DC division may be compromised, however, the unit has adequate DC power available in the form of the other division to mitigate all Design Basis accidents. This loss of one DC division is bounded by the loss of an entire AC division, a condition which the i plant is currently evaluated to withstand. I During the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time to connect and disconnect the temporary battery, there is no adverse impact on Unit 1. The compensatory measures to l
manually open the crosstie will ensure the Unit 1 DC battery can supply its '
required loads for the entire one hour duty cycle. The Unit 2 DC bus, which is crosstied, will be de<nergized in the event of a Unit 2 accident based on the compensatory measures. This action would only be required if the associated Diesel Generator were to fail to re-energize its associated charger. This condition is consistent with the other crosstie scenarios currently permitted by the Technical Specifications. Thus, the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time is consistent with the two hour Completion Time with respect to the ability to safely shutdown the Unit. Only the duration of the Completion Time is different.
Based on the above, the overall design, function, and operation of the DC system and equipment has not been significantly modified by these changes. The proposed changes do not affect any accident initiators or precursors and do not alter the design assumptions for the systems cr components used to mitigate the consequences of an accident as analyzed in UFSAR Chapter 15. I Page 2 of 4 Attachment C-Significant Hazards Consideration
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Therefore, this proposed amendment does not involve a significant increase in the J
. probability or consequences of an accident previously evaluated.
Does the change create the possibility of a new or different kind of accident from any l accident previously evaluated? '
i During the replacement of the existing batteries, a temporary battery bank will !
provide the same function as the batteries being removed. Even though this !
temporary battery is not seismically .nounted, it is the safety related AT&T i battery which was previously qualified and utilized to perform this function on l Unit 1. Because this temporary battery is identical to the battery that is currently I installed, and will be connected and used in the same way, no new electrical or functional failure modes are created.
l The temporary battery will be located in the turbine building, which is non-seismic. The temporary battery will not be seismically mounted. Thus, a seismic failure of the batteries is possible. Since the temporary battery is located in the j turbine building the potential for battery failure to initiate an ccident is not '
present, and failure of the battery can not create a different response from any I previously postulated accident. ,
i Due to the location of the main generator in rehtionship to the temporary ;
batteries, a turbine blade failure would not hit the battery unless it penetrated the j turbine casing and ricocheted in the direction of the battery, which is an unlikely i scenario due to the orientation of the temporary battery. Likewise, an unmitigated l Outside Containment Steam Line Break of either unit would be internipted by the !
successful closure of all MSIVs thereby leaving the battery and the DC bus intact I and available. Also any affects of a postulated storm on the turbine building have been previously addressed and would not change as a result of the batteries being temporary located there.
While the temporary battery is being connected, the DC bus will be supplied by the existing crosstie with Unit 1. To prevent any occurrence on Unit 2 from adversely affecting Unit 1, this crosstie will be manually disconnected based on specific criteria that may be indicative of a Unit 2 accident (specifically a Unit 2 LOOP). Once the crosstie is opened, the Unit 2 bus will be de-energized and the other Unit 2 division will be required to mitigate the accident. This loss of one DC division is bounded by the loss of one division (AC or DC), a condition which the plant is currently evaluated to withstand.
The DC system and its equipment will continue to perform the same function and be operated in the same fashion. The proposed changes do not introduce any new accident initiators or precursors, or any new design assumptions for the systems or components used to mitigate the consequences of an accident. Therefore, the 4
possibility of a new or different kind of accident from any accident previously
- evaluated has not been created.
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I Page 3 of 4 Attachment C-Significant Hazards Consideration l
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Therefore, this proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Does the change involve a significant reduction in a margin of safety?
During the replacement of the existing batteries, a temporary safety related battery bank will perform the same function as the batteries being removed. Even though this temporary battery is not seismically mounted, it is the safety related battery which was previously qualified and used to performed this function on Unit I and is identical to the safety related battery that is currently installed. Therefore, it has the same capacity, margin and capability to fulfill the requirements of the Unit 2 DC bus as the existing qualified battery. The proposed replacement activity will not prevent the plant from responding to either a seismic event or design basis accident. In both cases, the design mitigation capability will be maintained. Due to the limited duration of the activity and the planned contingency actions, a significant reduction in the margin of safety will not result.
While the temporary battery is being connected, the DC bus will be supplied by the existing crosstie with Unit 1. This condition is currently allowed for a limited time by the Improved Technical Specifications.
The inherent design conservatism of the DC system and its equipment has not been altered. The DC system and its equipment will continue to be operated with the same degree of conservatism. Accordingly, there is no significant reduction in the margin of safety.
Therefore, based upon the above evaluation, Comed has concluded that these changes involve no significant hazards consideration.
Page 4 of 4 Attachment C-Significant Hazards Consideration
ATTACHMENT D I ENVIRONMENTAL ASSESSMENT FOR PROPOSED CHANGES TO APPENDIX A '
TECHNICAL SPECIFICATIONS OF FACILITY OPERATING LICENSES
I Comed has evaluated this proposed operating license amendment request against the criteria for identification oflicensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21. Comed has determined that this proposed I license amendment request meets the criteria for a categorical exclusion set forth in 1 10 CFR 51.22(c)(9) and as such, hu determined that no irreversible consequences exist in )
accordance with 10 CFR 50.92(b). This determination is bued on the fact that this change i
- is being proposed as an amendment to a license issued pursuant to 10 CFR 50 which ;
changes a requirement with respect to installation or use of a facility component located I within the restricted area, as defined in 10 CFR 20, or which changes an inspection or a surveillance requirement, and the amendment meets the following specific criteria:
(i) The amendment involves no significant hazards consideration.
As demonstrated in Attachment C, this proposed amendment does not involve any significant hazards consideration.
(ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.
The proposed change will not result in changes in the operation or configuration !
of the facility. There will be no change in the level of controls or methodology p used for processing of radioactive effluents or handling of solid radioactive waste, I
nor will the proposal result in any change in the normal radiation levels within the plant. Therefore, there will be no change in the types or significant increase in the amounts of any effluents released offsite resulting from this change.
(iii) There is no significant increase in individual or cumulative occupational radiation exposure.
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i Page 1 of 2 Attachment D-Environmental Assessment t
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- The proposed change will not result in changes in the operation or configuration
, of the facility which impsct ra<tation' exposure. There will be no change in the . i level of controls or methodc*ogy used for processing of radioactive effluents or -i handling of solid radioactiv waste, nor will the proposal result in any change in the normal radiation levels within the plant. Therefore, there will be no increase .
in individual or cumulative occupational radiation exposure resulting from this
-l change. '
. Therefore, based upon the above evaluation, Comed has concluded that no irreversible consequences exist with the proposed change.
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- i. Page 2 of 2 Attachment D-Environmental Assessment
E ATTACHMENT C 9
EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION FOR PROPOSED CHANGES TO APPENDIX A TECHNICAL SPECIFICATIONS OF FACILITY OPERATING LICENSE NPF-72 AND NPF-77 Comed has evaluated the proposed amendment and determined that it involves no significant hazards consideration. According to 10 CFR 50.92(c), a proposed amendment to an operation license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:
Involve a significant increase in the probability or consequences of an accident previously evaluated; or Create the possibility of a new or different kind of accident from any accident previously evaluated; or Involve a significant reduction in a margin of safety.
Comed proposes a one time change to Improved Technical Specification (ITS) 3.8.4, DC Sources-Operating and ITS 3.8.9 Distribution Systems-Operating. This change is requested to support the replacement of the Unit 2125 volt DC ESF batteries and racks.
The proposed one time change will replace ITS 3.8.4 Required Action D with Required Actions necessary to support an on-line change out. One of the Required Actions will permit operation for 10 days in MODES 1-4 while one DC division is connected to the existing safety related battery charger and a temporary, previously qualified safety related, but non-seismically mounted battery. This alignment will be used while the current battery is replaced and tested. An additional 8-hour Completion Time is being proposed to allow the bus to be crosstied during the disconnection of the current battery and the re-connection of the charger and temporary battery. This Completion Time will also be entered during reconnection of the new battery (once installed) and removal of the temporary battery. The above evolution will be performed for each DC Division on Unit 2.
The proposed one time change to ITS 3.8.9 will add a Required Action C.2 which allow a Completion Time of 10 days for restoring DC electrical power distribution subsystem to OPERABLE status, which is also necessary to support the change out of batteries.
All required surveillances for the temporary and new batteries to demonstrate operability j will be performed prior to connecting to the DC Bus.
The determination that the criteria set forth in 10 CFR50.92 are met for this amendment request is indicated below:
Page 1 of 4 Attachment C-l Significant Hazards Consideration
Does the change involve a significant increase in the probability or consequences of l an accident previously evaluated? I During the replacement of the existing batteries, a temporary battery bank will l provide the same function as the AT&T batteries being removed. Even though l this temporary battery will not be seismically mounted, due to its location in the Turbine Building, it is the safety related AT&T battery which was previously qualified and used to perform this function on Unit 1.
While the temporary battery is being connected, the DC bus will be supplied by the existing crosstie with Unit 1. Similar crosstie conditions are allowed under the present Improved Technical Specifications.
l The DC system is normally supplied by the AC system through the ESF battery charger. The essential function of the DC system battery is to supply control l power necessary to start and load the Diesel Generators. Once the Diesel Generators are on line, the DC system will be supplied via the battery charger.
However, the ESF batteries have been sized for one hour to provide additional assurance that the critical DC loads are available in the event of a loss of a battery charger. l During the 10 day Completion Time when the temporary battery and the ESF charger are supporting the bus, the ability of that DC Division to mitigate an event / accident is unchanged except for its ability to cope with a seismic event.
However, the probability of a seismic event concurrent with the 10 day Completion Time is extremely small. During a seismic event, one DC division i may be compromised, however, the unit has adequate DC power available in the 1 form of the other division to mitigate all Design Basis accidents. This loss of one DC division is bounded by the loss of an entire AC division, a condition which the plant is currently evaluated to withstand.
During the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time to connect and disconnect the temporary battery, there is no adverse impact on Unit 1. The compensatory measures to manually open the crosstie will ensure the Unit 1 DC battery can supply its required loads for the entire one hour duty cycle. The Unit 2 DC bus, which is crosstied, will be de-energized in the event of a Unit 2 accident based on the compensatory measures. This action would only be required if the associated Diesel Generator were to fail to re-energize its associated charger. This condition is consistent with the other crosstie scenarios currently permitted by the Technical Specifications. Thus, the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time is consistent with the two hour Completion Time with respect to the ability to safely shutdown the Unit. Only the duration of the Completion Time is different.
Based on the above, the overall design, function, and operation of the DC system ;
and equipment has not been significantly modified by these changes. The proposed changes do not affect any accident initiators or precursors and do not alter the design assumptions for the systems or components used to mitigate the consequences of an accident as analyzed in UFSAR Chapter 15.
Page 2 of 4 Attachment C-Significant Hazards Consideration
l Therefore, this proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
During the replacement of the existing batteries, a temporary battery bank will provide the same function as the batteries being removed. Even though this temporary battery is not seismically mounted, it is the safety related AT&T battery which was previously qualified and utilized to perform this function on Unit 1. Because this temporary battery is identical to the battery that is currently installed, and will be connected and used in the same way, no new electrical or functional failure modes are created.
The temporary battery will be located in the turbine building, which is non-seismic. The temporary battery will not be seismically mounted. Thus, a seismic failure of the batteries is possible. Since the temporary battery is located in the turbine building the potential for battery failure to initiate an accident is not present, and failure of the battery can not create a different response from any previously postulated accident.
Due to the location of the main generator :n relationship to the temporary batteries, a turbine blade failure would not hit the battery unless it penetrated the turbine casing and ricocheted in the direction of the battery, which is an unlikely scenario due to the orientation of the temporary battery. Likewise, an unmitigated Outside Containment Steam Line Break of either unit would be interrupted by the successful closure of all MSIVs thereby leaving the battery and the DC bus intact and available. Also any affects of a postulated storm on the turbine building have been previously addressed and would not change as a result of the batteries being temporary located there.
While the temporary battery is being connected, the DC bus will be supplied by the existing crosstie with Unit 1. To prevent any occurrence on Unit 2 from adversely affecting Unit 1, this crosstie will be manually disconnected based on specific criteria that may be indicative of a Unit 2 accident (specifically a Unit 2 LOOP). Once the crosstie is opened, the Unit 2 bus will be de-energized and the other Unit 2 division will be required to mitigate the accident. This loss of one DC division is bounded by the loss of one division (AC or DC), a condition which the plant is currently evaluated to withstand.
The DC system and its equipment will continue to perform the same function and be operated in the same fashion. The proposed changes do not introduce any new accident initiators or precursors, or any new design assumptions for the systems or components used to mitigate the consequences of an accident. Therefore, the l possibility of a new or different kind of accident from any accident previously evaluated has not been created.
Page 3 of 4 Attachment C-Significant Hazards Consideration
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l Therefore, this proposed amendment does not create the possibility of a new or !
different kind of accident from any accident previously evaluated. l Does the change involve a significant reduction in a margin of safety? i During the replacement of the existing batteries, a temporary safety related battery bank will perform the same function as the batteries being removed. Even though this temporary battery is not seismically mounted, it is the safety related battery which was previously qualified and used to performed this function on Unit 1 and ,
is identical to the safety related battery that is currently installed. Therefore, it has ;
the same capacity, margin and capability to fulfill the requirements of the Unit 2 DC bus as the existing qualified battery. The proposed replacement activity will .
not prevent the plant from responding to either a seismic event or design basis accident. In both cases, the design mitigation capability will be maintained. Due i to the limited duration of the activity and the planned contingency actions, a !
significant reduction in the margin of safety will not result. t While the temporary battery is being connected, the DC bus will be supplied by the existing crosstie with Unit 1. This condition is currently allowed for a limited time by the Improved Technical Specifications. l i
The inherent design conservatism of the DC system and its equipment has not l been altered. The DC system and its equipment will continue to be operated with the same degree of conservatism. Accordingly, there is no significant reduction in I the margin of safety.
Therefore, based upon the above evaluation, Comed has concluded that these changes involve no significant hazards consideration.
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4 ATTACHMENT D '
t ENVIRONMENTAL ASSESSMENT FOR PROPOSED CHANGES TO APPENDIX A TECHNICAL SPECIFICATIONS OF !
FACILITY OPERATING LICENSES ;
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Comed has evaluated this proposed operating license amendment request against the !
- criteria for identification of licensing and regulatory actions requiring environmental i assessment in accordance with 10 CFR 51.21. 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) and as such, has determined that no irreversible consequences exist in accordance with 10 CFR 50.92(b). This determination is based on the fact that_this change is being proposed as an amendment to a license issued pursuant to 10 CFR 50 which changes a requirement with respect to installation or use of a facility component located i within the restricted area, as defined in.10 CFR 20, or which changes an inspection or a surveillance requirement, and the amendment meets the following specific criteria:
(i) The amendment involves no significant hazards consideration.
As demonstrated in Attachment C, this proposed amendment does not involve any significant hazards consideration.
l (ii) _ There is no significant change in the types or significant increase in the ,
amounts of any effluents that may be released offsite.
l The proposed change will not result in changes in the operation or configuration of the facility. There will be no change in the level of controls or methodology ;
used for processing of radioactive effluents or handling of solid radioactive waste, i nor will the proposal result in any change in the normal radiation levels within the plant. Therefore, there will be no change in the types or significant increase in the amounts of any effluents released offsite resulting from this change.
l (iii) . There is no significant increase in individual or cumulative occupational radiation exposure.
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Page 1 of 2 Attachment D-Environmental Assessment
The proposed change will not result in changes in the operation or configuration
. of the facility which impact radiation exposure. There will be no change in the level of controls or methodology used for processing of radioactive effluents or handling of solid radioactive waste, nor will the proposal result in any change in the normal radiation levels within the plant. Therefore, there will be no increase
. in individual or cumulative occupational radiation exposure resulting from this >
change.
Therefore, based upon the above evaluation, Comed has concluded that no irreversible consequences exist with the proposed change.
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Page 2 of 2 Attachment D- i Environmental Assessment
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