ML20205M313
| ML20205M313 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/21/1988 |
| From: | DUQUESNE LIGHT CO. |
| To: | |
| Shared Package | |
| ML20205M300 | List: |
| References | |
| NUDOCS 8811030031 | |
| Download: ML20205M313 (18) | |
Text
, _.
f ATTACliMENT' A l
Revise the Beaver Valley Power
- Station, Unit No. 2 Technical Specifications as follows:
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i 8811030031 891024 i
PDR ALOCK 05000412 P
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3/4.3 INSTRUMENTATION 3,/4. 3.1 REACTOR TRIP SYSTEM INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.1.1 As a minimum, the reactor trip system instrumentation channels and interlocks of Table 3.3-1 shall be OPERABLE with RESPONSE TIliES as shown in Table 3.3-2.
A_PPLICABILITY:
As shown in Table 3.3-1.
ACTION:
As shown in Table 3.3-1 SURVEILLANCE RE001kEMENTS 4.3.1.1.1 Each reactor trip system instrumentation channel and interlock and automatic trip logic shall be demonstrated OPERABLE by the performance of the Reactor Trip System Instrumentation Surveillance Requirements
- during the M00ES }
and at the frequencies shown in Table 4.3-1.
i (t 4.3.1.1.2 The Icgic for the interlocks shal'3 be demonstrated OPERABLE during the at power CHANNEL FUNCTIONAL TEST of chanaels affected by interlock opera-tion.
The total interlock function shall tn demonstrated OPERABLE at least once per 18 months during CHANNEL CALIBRAT10N testing of each channel affected by interlock operation.
4.3.1.1.3 The REACTOR TRIP SYSTEM RESPONSE TIME of each reactor trip f ion shall be demonstrated to be within it", limit at least once per 18 month ach test shall include at least one logic train such that both logic trains are tested at least once per 36 months and one channel per function such that all channels are tested at least once every N times 18 months where N is the total number of redundant channels in a specific reactor trip function as shown in the "Total No. of Channels" column of Table 3.3-1.
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- For the automatic trip logic, the surveillance requirements shall be the application of vaaious simulated input combinations in conjunction with each possible interlock logic state and verification o" the required logic output incluoing, as a minimus, a continuity checs, of output devices.
BEAVER VALLEY - UNIT 2 3/4 3-1 fro pa seal Wordt
TABLE 4.3-1 (Continued)
TABLE NOTATION With the reactor trip system breakers closed and tht control rod drive system capable of rod withdrawal.
(1)
If not performed in previous 7 days.
(2)
Heat balance only, abova 15% of RATED THERMAL POWER.
(3)
Compare incore to excore axial imbalance above 15% of RATED THERMAL POWER.
Recalibrate if absolute difference > 3 percent.
(4)
(Not used)
(5)
Each train tested every other month on a STAGGERED TEST BASIS.
(6)
Neutron detectors may be excluded from CHANNEL CALIBRATION.
(7)
Below P-10.
(8)
Belos P-6.
(9)
Required only when below Interlock Trip Setpoint.
(10) -
The C ANNEL FUNCTIONAL TEST shall independently verify the OPERABILITY of the undervoltage and shunt trip circuits for the Manual Reactor Trip Function.
The test shall also verify the OPERABILITY of the Bypass Breaker trip circuit (s).
(11) -
The CHANNEL FUNCTIONAL TEST shall independently verify the OPERA 31LITY of the undervoltage and shunt trip attachments of the Reactor Trip Breakers.
(12) -
Local manual shunt trip prior to placi.ig breaker in service.
(13) -
Automatic undervoltage_trj The. :r e J,6 i. / sur f e,ill A nt.D iwtcent dating ne. fir 6+ fut e.yd e. m y be. afenh.4 to cowtide, tath comp hinn,f +hi. Pinf tak.lin) 4 i
BEAVER VALLEY - UNIT 2 3/4 3-13 Proposed tJor/iwg
l INSTRUMENTATION 3/4.3.2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRLNENTATION SURVEILLANCE REOUIREMENTS 4.3.2.1.1 Each engineered safety feature actuation system instrumentation chantel and interleck and the automatic actuation logic with master and slave relays shall be demonstrated OPERABLE by the performance of the ESFAS instru-mentation Surveillance Requirements" during the MODES and at the frequencies showr,in Table 4.3-2.
4.3.2.1.2 The logic for the interlocks shall be demonstrated OPERABLE during the at power CHANNEL FUNCTIONAL TEST of channels affected by interlock opera-tion.
The total interlock function shall be demonstrated OPERABLE at least ones per 18 months during CHANNEL CALIBRATION testing of each channel affected by interlock operation.
4.3.2.1.3 The ENGINEERED SAFETY FEATURES RESPONSE TIME.of each ESF fun n
shall be demonstrated to be within the limit at least once per 18 month ach test shall include at least one logic train such that both logic trains tested at least once per 36 months and one channel per function such that all g
channels are tested at least once per N times 18 months where N is the total 4
number of redundant channels in a specific ESF function as shown in the "Total
- 1 No. of Channels" Column of Table 3.3-3.
The specikes is mewtlu surynlla ne.e. hbyd de tk fi,d f u l e p.te., m y k i. est e n de.J to c.ein ci4. m th e etion of Ki. Et rebb3 owfap.j E
.i
- For the automatic actuation logic, the surveillance requirements shall be the application of various sieulated input conditions in conjunction with each possible interlock logic state and verification of the required logje output including, as a minimum, a continuity check of output devices.
For the actuation relays, the surveillance requirements shall be the energitation of each master and slave relay and verification of OPERABILITY of each relay.
The test of master relays shall include a continuity check of each associated slave relay.
The test of slave relays (to be perforined at least once per 92 days in lieu of at 'least once per 31 days) shall includtr, as a minimu9, a continuity check of associated actuation devices that are not testable.
BEAVER VALLEY - UNIT 2 3/4 3-15 frapese.d Wor /h
TABLE 4.3-2 (Continued) 9 ENGINEERED SAFETY FEATURE ACTUATION SYSTEN INSTRUNENTATION
=
SURVIILLANCE REQUIREE NTS i
fp CHANNEL NODES IN WilCH Q
CHANNEL CHANNEL FUNCTIONAL SURVEILLANCE FUNCTIONAL UNIT CHECK CALIBRATION TEST REQUIRED 5
7.
AUXILIARY FEEmdATER (continued) d.
Safety Injection (Start Motor-See 1 above (all SI survelliance requirements)
Driven Pumps) i e.
Trip of Main M.A.
N.A.
R 1,2,3
[
Feedwater Pumps 7
(Start Motor-Driven Pupps) 8.
ENGINEEREDSAFETYFEATUREkMTEkt0CKS a.
Reactor Trip, P-4 N. A.
N.A.
R (3) 1, 2, 3 7t b.
Pressurizer Pressure, P-11 N.A.
R M
1, 2, 3 Y
qo c.
Low-Low T,,g, P-12 N.A.
R M
1,2,3 I
1 2
-.. a
TABLE 4.3-2 (Continued)
TABLE NOTATION gg g g, (1) Manual actuatior. switches shall be tested at lear.t once per 18 months during shutdown. h All other circuitry associated with manual sai'eguards actuation shall receive a CHANNEL FUNCTIONAL TEST at least once per 31 days.
(2) Each train or logic chanael shall be tested at least every other 31 days.
(3) he sfccifit/ SurreillAne.t in ter v A l durIn j the fird h c l ty'It vne.y 1,e evfended te coincid e. wifA co-rletim e f +A first refueliny oat *3e..
Hseti f
This it w entk surveillanc.c inte<ve l d.r;wp the firs t he l cycle vne.y b e. cdend ed to coinc id s.
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S BEAVER VALLEY - UNIT 2 3/4 3-38 fre po sed Wevdlrg
I TABLE 4.3-4 SEISMIC MONITORING INS'sRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL CHANNEL CHAhNEL FUNCTIONAL 1,NSTRUMENTS AND SENSOR LOCATIONS CHECK CALIBRATION TEST 1.
TRIAXIAt. TIME-HISTORY ACCELEROGRAPHS a.
Containment Mat, el.
M*
SA 692'-11" b.
Containment Operating M*
h SA floor el. 767'-10" c.
Switchyard M*
R SA d.
Containment Building - Steam N/A b
N/A Generator.iupport Cubicle No. 1 el. 718'6" e.
Aux. Building - at center of N/A R
N/A I
Mat, el 710'6" t
N/A R
N/A Aux. Building (- at base of f.
480 volt MCC MCC-2-E03),
el. 755'6" 2.
TRIAXIAL PEAK ACCELER0 GRAPHS N/A N/A ContainmentBuildinf2RHS-E21A) a.
RHS heat exchanger el. 715'-6" Containment Buildin
-Six inch N/A N/A b.
SIpipe(2 SIS-006-2k9-1(A))
e1. 741'-5" c.
Aux. Building -
2E03 N/A R
N/A el755'-6%
v r
3.
TRIAXIAL SE13NIC SWITCHES
.<. 2 a.
Containment met N/A N/A 4.
RESPONSE SPECTRUM ANALYZER a.
Control Room N/A R
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re blin <- 46te -
l
- Except seisanc trigger
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BEAVER VALLEY - UNIT 2 3/4 3-48 Propese.d Wer#g
CONTAINM:NT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 2.
Varifying that each automatic valve in low path actuates to its correct position on a test signa 3.
Initiating flow through each Service Water subsystem and its two associated recirculation spray heat exchangers, and verifying a flow rate of at least 12,000 gpm.
f.
At least once per 5 years by performing an air or smoke flow test through each spray headtr and verifying each spray nozzle is unobstructed.
l l
- The specifitd i1 wendr serv <illant.e. interv$l dariaf He Er rt Fu.I eycle m q b o hngej t, esin crJe s,f(
- ornp lafsm of tkt fir d refuelin; ddA)8.
BEAVER VALLEY - UNIT 2 3/4 6-13 Nr.s a W.rai g
CONTAINMENT SYSTEMS f
SURVEILLANCE RfoufREMENTS (Continued) l
~ r l
4.6.3.1.2 Each isolation valve specified in Table 3.6-1 shall be demonstrated l
OPERABLE during 'the' COLD SHUTDOWN or REFUELING MODE at least once per l
18 months by:
a.
Verifying that on a Phase A containment isolation test signal each Phase A isolation valve actuates to its isolation position.
l l
b.
Verifying that on a Phase B containment isolation test si each Phase 6 isolation valve actuates to its isolation positio *
]
c.
Verifying that on a Containment Purge and Exhaust isolation signal, each Purge and Exhaust valve actuates to its isolation position.
1 d.
Cycling each power operated or automatic valve through at least one complete cycle of full travel and measuring the isolation time pursuant to Specification 4.0.5.
e.
Cycling each weight or spring loaded check velve not testable defing plant operation, through one completa cycle of full travel ande '
verifying that each check valve remains closed when the differential; pressure in the direction of flow ~is < 1.2 psid and opens when the O
differential press n the direction of flow is > 1.2 psid but less than 6.0 psid
- f.
Cyclin 2 each manual valve not locked, sealed or otherwise secured in the closed position through at least one complete cycle of full travel.
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p BEAVER VALLEY - UNIT 2 3/4 6-16 frs ya s e.d N"
1 ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 3.
Verifying that a sample of diesel fuel from the fuel storage tank is within the acceptable limits specified in Table 1 of ASTM 0975 when checked for viscosity, water and sediment, 4.
Verifying the fuel transfer pump can be started and transfers-fuel from the storage system to the day tank, 5.
Verifying the diesel starts from ambient condition, 6.
Verifying the generator is synchronized, loaded to > 4,238 kw, and operates for at least 60 minutes, and 7.
Verifying the diesel gendrator is aligned to provide standby power to the associated emergency busses.
8.
Verifying the lubricating oil inventory in stora2e, b.
At least once per 18 mont uring shutdown by:
1.
Subjecting the diesel to an inspection in accordance with pro-cedures prepared in conjunction with its manufacturer's recom-mendations for this clan of standby service, 2.
Verifying the generator capability to reject a load of 1 825 kw without tripping, 3.
Simulating a loss of offsite power in conjunction with a safety injection signal, and:
a)
Verifying de-energization of the emergency busses and load shedding from the emergency busses.
b)
Verifying the diesel starts free ambient condition on the autorttart signal, energizes the emergency busses with per-sanent.1y connected loads, energizes the auto-connected AS.
emergency loads through the load sequencer and operates for
> 5 minutes while its generator is loaded with the emergency 1..
Toads.
4.
Verifying that on a loss of power to the emergency busses, all diesel generator trips, except engine overspeed, generator differential current, and generator overexcitation are automatically disabled.
5.
Verifying the diesel generator operates for at least 60 minutes while loaded to 1 4,238 kw.
% $fet' fail If Mod %s sor veillence, s%hrva { dur'm ff e firs?
fu < l 4.y cl e M6) b e e >fe,$/e d to r ein ci/ c, p'rfk (
tilja o f f4e, l
l firif (cfuel:5.S auf e,
- x BEAVER VALLEY - unAi-2 3/4 8-3 frdpased (M a r 4'
i I
ELECTRIC POWER SYSTEMS SURVEILLANCE REQUIREMENTS 1.
The parameters in Table 3.8-1 meet the Category S limits.
2.
There is no visCle corrosion at either teminals or connectors, or the connectior resistance of these itws is less than 150 x 10.s ches, and 3.
The average electrolyte temperature of every tenth cell of connected cells is above 60*F.
c.
At least once per 18 months by verifying that:
1.
The cells, cell plates, and battery racks show no visual indica-tion of physical d mage or abnormal deterioration, 2.
The cell-to-cell and terminal connections are clean, tight, and coated with anti-corrosi'on material, Theresistanceofeachcell-to-cellandterminalconnectionis,I 3.
less than or equal to 1E0 x 10 8 ohns; and 1,
l 4.
The battery charger will supply at leasi.100 amperes at 140-volts for at less 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
d.
At least once per 18 mont uring shutdown, by verifying that the battery capacity is adequa to supply and maintain in OPERA 8LE status all of the actual or simulated emergency loads for the 2-hour design duty cycle when the battery is subjected to a cattery service test.
l e.'
At least once per 60 months, during shutdown, by verifying that the battery capacity is at least 80% of the manufacturer's rating when subjected to a performance discharge test.
Once per 60 month interval, this performance discharge test may be performed in lieu of the battery service test.
f.
Atleastenschpdr18 months,duringshutdown,performancedischarge tes of betteWy capacity shall be given to any battery that shows si
'of engradation or has reached 85% of the service life expected i
for"the: application.
Degradation is indicated when the battery capecity drops Mrs than 10% of rated capacity from its average on previous performance tests, or is below 905 of the manufacturer's rating.
N hgl9.c.ih*tl lP bunf$s The Jar (iill An c a. InfatVAl duri fke fa'rsY c.y cl e. Mcy le s idenled 40 toincilc Witk copy e'Db of ide, fm t re.6 fig sap.. -
BEAVER VALLEY - UNIT 2 3/4 8-10 froposed Words
ATTACHMENT B Proposed Technical Specification Change Unit 2 - Change No. 2A-17 Safety Analysis Description of Amendment Request:
' 5e proposed amendment would extend the 18-month surveillance interval for certain Technical Specification surveillance requirements to coincide with completion of the first refueling outage.
These 18-month surveillance requirements with the additional 25%
extension permitted by Specification 4.0.2 will come due prior to the beginning of the Unit 2 first Refooling Outage.
The surveillance requirements for which an extension is required can not be performed during operation and would therefore require an otherwise unnecessary plant shutdown to complete.
The currently scheduled date for the Unit No. 2 first Refueling Outage is March 17, 1989.
This outage date will not extend beyond April 1,
1989 if the required 18-month surveillances extended per this amendment request have not been completed by this date.
The following is a
list of surveillanco requirements requiring an extension along with the current dates which these surveillances will expire when adding in the 25% allowable extension:
Specification 4.3.1.1.3 Reactor Trip System Response Time - due 1/3/89 Discussion Tho Reactor Trip System response time testiag includes sensor timo
- response, instrument channel ad protection system logic time responso and reactor trip breaker tine response.
Performance of the Reactor Trip System logic tino response tests involves removing one train of the Reactor Protection System from cervice for an extended period of timo.
The Technical Specifications allow one train to be bypassed for a maximum of only two hours.
Thorofore, this portion of the overall timo responso can not be measured during oporation.
- Likewise, the reactor trip breaker timo responso can not be naasured during operation.
The sensor timo responses are capable of being measured curing oporation.
Based on past operating experience at Unit 1,
when any response time degradation has been obcerved, it has boon associated with the sensor timo responso.
Since the portion of the Reactor Trip System timo responso survoillance which will not be measured in the normal surveillance interval has historically not been a
- problem, this survoillanco extension should not decrease the rollability of the Reactor Protection System. - -
Prcpo:cd T.S. Changa No. 2A-17, cont.
Specification 4.3.1.1.1 Table 4.3-1, Item 24 Reactor Trip Bypass Breakers Automatic Undervoltage Trip Check Due 1/3/89 niscusaion Performance of this surveillance would require generating a
reactor trip signal and therefore can not be performed during operation.
Extension of this surveillance will have a minimum impact on the availability of these breakers since these breakers are only in service for the time required each month to test the Reactor Trip System.
In-addition, the breaker manual shunt trip capability is tested monthly.
Specification 4.3.2.1.3 Engineered Safety Features (ESP) Response Time - due 1/3/89 Discussion ESF response time testing includes sensor time
- response, instrument channel and protection system logic time response and final actuation circuitry and equipment actuation time response.
Sensor time responses (with the exception of the containment pressure sensors) and equipment actuation times are capable of being measured during operation.
However, performance of the ESF System logic time response portion involves removing one train of the protection system from service for an extended period of time.
Therefore, this portion of the overall channel time response can not be measured during operation.
Without the instrument channel anci protection system logic time response
- portion, the overall channel time responses listed in Table 3.3-5 of the Technical Specifications can not be verified.
This small extension beyond the normal surveillance interval should not allow any significant time response degradation such that the reliability of the ES'i Systems and the response times ascumed in the Safety Analyses will be impacted.
Prcpoord T.S.
Ch nga No. 2A-17, cont.
Specification 4.3.2.1.1 Items 1.a, 2.a, 3.b.1 Safety Injection and Feedwater Isolation, Containment Spray and Containment Isolation Phase B Manual Initiation Switches Due 3/1/89 (for SI and FW Isol.), 3/21/89 (for Cnmt. Spray and CIB)
Discussion These manual actuation switches can not be tested during plant operation.
- However, these switches have historically been very reliable.
The automatic actuation signals logic and all other circuitry associated with manual cafeguards actuation are periodically tested as required by the Technical Specification i
surveillance requirements.
l l
l Specification 4.3.2.1.1 Item 8.a Reactor Trip, P-4 Interlock - due 1/3/89 Discussion This interlock circuit is functionally tested d2 ring the Manual Reactor Trip Breaker Time
Response
procedure for Unit 2.
This procedure can not be performed during plant operation, slace the procedure manually trips the reactor trip breakers from the control Room.
However, a partial test of this interlock circuit is performed during the reactor trip breakers monthly tests.
This test does verify proper operation of the breaker's auxiliary switch contacts which generato a P-4 signal.
Thorofore, this surveillance extension should be acceptable.
l Specification 4.3.3.3.1 Soismic Honitoring Instrumentation - duo 3/25/89 l
Discussion The seismic monitoring instrumentation for which an extension of the survoillance interval is requestod are all located inside the Roactor Containment Building.
These instruments are within an i
operating exclusion area and thoroforo, can not be tested at power.
l The overdue dato for this surveillance is currently past the scheduled first refueling outage
- dato, however, with some small schedule
- delays, this timo interval could be exceeded.
Since the surveillance tiino interval extension that may be necessary is small, thera should be no impact on the reliability of those instruments...
Proposed T.S. Changa No. 2A-17, cont.
Specification 4.6.3.1.2.e p
Containment Isolation Check Valves - due 2/19/89 i
.t.
Discussion The containment isolation check valves lift tests are performed during the containment type C leak test and therefore, requires an i
extended outage in Mode 5 to complete.
There are 28 valves tested at l
Unit 2
per this surveillance requirement.
All valves are weight loaded check valves.
A Technical Specification Amendment Request (Amendment Request No.
2A-5) has been submitted to the NRC which i
would delete this testing requirement on 16 of the 28 valves.
In t
- addition, since these valves are all weight loaded check valves (not spring loaded) it is not anticipated that valve opening and closing pressures will change significantly with time.
This small surveillance interval extension should therefore be acceptable.
Specification 4.6.3.1.2.b ContainmeTt Isolation Phase B (CIB) Signal Valve Actuations i
j Due 3/21/T9 DPscussigIt This surveillance is performed by manually actuating a CIB signal from the main Control Room during a plant outage.
Operation of all CID isolation valves during plant operation would cause several undesirable plant disturbances including interrupting component cooling water flow to the Reactor Coolant Pumps.
This test also requires one train of the Quench Spray and Recirculation Spray j
Systems to be taken out of service.
However, as part of the ESF actuation relay testing required by Surveillance Item 4.3.2.1.1, l
proper CIB valve actuations are verificd quarterly for all valves testable at power.
For valves which can not ba stroked during operation, the output relay testing circuitry does verify that the valve control circuit receives an isolation signal, but blocks actual l
valve operation via a blocking relay.
Since most CIB isolation valve
{
actuations are verified during the quarterly output relay testing and for the remaining valves the actuation circuitry excluding actual valve operation is verified quarterly, this surveillance extension l
l should be acceptable.
I i
i i
l l
~4-
Propeacd T.S.
Chtnga No. 2A-17, cont.
Specification 4.6.2.2.e.2 Recirculation Spray System Valve Actuations - due 3/2: 89 Discussion This surveillance is performed by the same test used to satisfy Specification 4.6.3.1.2.b.
That is, by manually actuating a CIB signal from the main Control Room during an outage.
Therefore, this test can not be performed at power.
However, again as part of the quarterly ESF actuation relay
- testing, all automatic valves associated with the Recirculation Spray System are verified to operate on a
test signal with the exception of 2SWS-MOV-106A and B.
Howev?r, the ESF quarterly actuation relay testing does verify that these valves receive a
test signal without actually stroking the valves.
These valves are operated from the Control Room every 92 days during cold shutdown per the ASME Section XI testing program.
These specific valves were stroked in January, 1988.
Since this surveillance is satisfied with the exception of verifying that vcives 2SWS-MOV-106A and B
actuate on a
test signal, this surveillance extension should be acceptable.
Specification 4.8.1.1.2.b Emergency Diesel Generator (EDG) 18-Month Surveillances Due 1/25/89 (Diesel Generator Inspection) 3/1/89 (all remaining 18-month surveillances)
Discussion Surveillance Item 4.8.1.1.2.b.1 requires a maintenance inspection of the EDGs every 18 months.
This is a detailed inspecticn of the EDGs which takes several weeks to complete and therefore cannot be performed during plant operation when both EDGs are required to be operable.
Surveillance Items 4.8.1.1.2.b.2, 3
and 4 is verified during our EDG Auto Load Test.
This test de-energizes the station emergency buses and verifies the EDGs start and properly load sequences all emergency bus loads.
This surveillance also can not be porformed during operation.
While these 18-month surveillance tests will not be completed within the required surveillance interval, availability of the EDGs is demonstrated by the sychronizing of the EDGs to the station buses and fully loading the diesels monthly as per Specification 4.8.1.1.2.a.
In addition, there have been several plant transients at Unit 2 during the first fuel cycle in which power to the emergency buses was lost and the EDGs successfully started and supplied power to the emergency buses.
There have been no EDG failures to date at Unit 2.
Therefore, our current EDG reliability factor for both diesels is 100%.
This small surveillance extension should not degrade the reliability of the EDGs. -
i Prcpo0cd T.S.
Chang 2 No. 2A-17, cont.
Specification 4.8.2.3.2.d Battery Service Test - due 12/22/88 Discussion There are four safety related DC buses and associated batteries at Unit 2.
Only one of these four batteries require an extension of the surveillance interval _ prior to the first refueling.
Performance of the battery service test discharges the battery sufficiently such that the battery cannot be returned to service within the allowable time period and is therefore not performed during plant operation.
With relatively new batteries it is unlikely that the existing battery capacity would degrade significantly during the several month extension requested to not meet the battery service test requirement.
ATTACHMENT C NL Significant Hazard Evaluation Proposod Technical Specification Change Unit No. 2 - Change No. 2A - 17 Basis for Proposed No Significant hazards Consideration Determination:
The commission has provided standards for cetermining whether a
significant hazards consideration exists (10CFR50.92(c)).
A proposed amendment to an operating license for a facility involves no significant hazards consideration 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: (2) create tne possibility of a now or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.
The proposed change does not involve a
significant hazards consideration because:
l 1.
The proposed change will not increase the probability of an accident previously evaluated.
This change will not cause a significant reduction in system reliability nor offect the ability of the systems to perform their design function.
The existing Technical Specification surveillance programs demonstrato the equipment is verified operable through surveillance testing of all testable functions during operation.
The interval extensions requested are short and should not impact the continued operability of safety related equipment and their availability to mitigate the consequences of any postulated l
accidents.
Therefore, no significant increase in the consequences of any accidents previously evaluated results from this chango.
2.
This change would not create the possibility of a
new or different kind of accident from any accident previously l
l ovaluated.
There is no change to system configurations, plant l
equipment or analyses.
The change in surveillance intervals does not create any now types of accidents.
3.
This chango would not involvo a significant reduction in a margin of safety.
Surveillance interval extensions will not impact on any plant safety analysos sinco assumptions contained theroin are expected to remain the samo.
The safety limits assumed in the analyses and the design function of the equipment required to mitigato the consequences of any postulated accidents remains unchanged since only the test frequoney is being extended.
}
Dased on the above consideration, it is proposed to characterize
}
the change ac involving no significant hazards considerations.
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