ML20216D147

Application for Amend to License NPF-42,adding Requirements for Essential Svc Water Flowpaths to Turbine-Driven Auxiliary Feedwater Pump

ML20216D147
Person / Time
Site:	Wolf Creek
Issue date:	09/02/1997
From:	Muench R WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20216D152	List: ML20216D147 ML20216D155
References
ET-97-0075, ET-97-75, NUDOCS 9709090224
Download: ML20216D147 (19)

Text

,..

l W19LF CREEK NUCLEAR OPERATING CORPORATION I

Richard A. Muench i

Vee President Engineering l

September 2, 1997 ET 97-0075 U. S. Nuclear Regulatory Commission ATTN:

Document Control Desk Mail Station Pl-137 Washington, D. C.

20555

Reference:

Letter ET 97-0050, dated May 15, 1997, from R. A. Muench, WCNOC to NRC

Subject:

Docket No. 50-482: Proposed Revision to Technical Specification 3/4.7.1.2, Auxiliary Feedwater System Gentlemen:

This letter transmits an application for amendment to facility Operating License No. NPF 42 for Wolf Creek Generating Station (WCGS).

This request proposes to revise Technical Specification 3.7.1.2, Auxiliary Feedwater System, and associated Bases, to add requirements for the Essential Service Water (ESW) flowpaths to the Turbine-Driven Auxiliary Feedwater Pump (TDAFWP) and other changes consistent with the Technical Specification Conversion application previously submitted by the Reference.

The proposed revisions would:

(a)

Provide an Action and Allowed Outage Time for inoperability of one of the redundant ESW flowpaths to the TDAFWP.

(b)

Incorporate an Action and Allowed Outage Time for inoperability of one of the redundant steam flowpaths to the TDAFWP turbine and other changes to make the Auxiliary Feedwater System LCO and Actions consistent with those previously submitted in the Reference.

The proposed changes regarding the ESW flowpaths to the TDATWP are similar to requirements contained in both the current Technical Specifications and the proposed Improved Technical Specifications for Union Electr_c Company's Callaway Plant with the main exception being the Allowed Outage Time proposed herein is 7 days instead of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

(Note that a proposed 7-day Allowed

,Gg -

Outage Time would have been considered out of scope for the Technical Specification Conversion application for Callaway Plant.)

A Safety Evaluation is provided in Attachment 1; a No Significant Hazards Consideration Determination, in Attachment II.

Attachment III is the related Environmental Impact Determination.

Marked up pages are provided in 1

Attachment IV (for current Technical Specifications and Bases) and in

}

I Attachment V (for Improved Technical Specifications and Bases submitted by the Reference).

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Kansas State Official.

This proposed revision to the WCGS Te7hnical Specifications will be fully implemented within 60 days of formal NRC approval.

9709090224 970902 PDR ADOCK 05000482 ffll]fll]fll]lllfllflllllllllgg P

PDR PO. Box 411/ Durhngton, KS 66839 / Phone. (316) 364-8831 a

(

An Equal OpportuNy Ernpoyee M F HC VE T

ET 97-0075 Page 2 of 2

• If y*ou have any questions concerning this matter, please contact me at (316) 364-8831, extension 4034, or Mr. Richard D.

Flannigan, at extension 4500.

Very truly yours, 4Af Richard A. Muench RAM /jad Attachments:

I

- Safety Evaluation II

- No Significant Hazards Consideration Determination i

III

- Environmental Impact Determination IV Proposed Current Technical Specification Change V

Proposed Improved Technical Specification Change cc:

V.

L. Cooper (KDHE), w/a E.

W. Merschoff (NRC), w/a W.

D. Johnson (NRC), w/a J.

F. Ringwald (NRC), w/a J.

C. Stone (NRC), w/a

STATE OF KANSAS

)

)

ss COUNTY OF COFFEY

)

Richard A. Muench, of-lawful age, being first duly sworn upon oath says that he-is Vice President Engineering of Wolf Creek Nuclear Operating Corporation; that he has read-the foregoing document and knows'the content thereof; that he has ' executed that same for and on behalf of said Corporation with full-

- power and authority to do so; and that the f acts therein stated are true and correct to the best of his knowledge, information and belief.

f By Richard Muench Vice Pre ident Engineering day of h g d /7 1997.

. SUBSCRIBED and sworn to before me this 11k10 b

J WA.DAtE

"***bPublic

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..Pire) 10/2/92

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Expiration Date

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Attachment I to ET 97-0075 Page 1 of-7 ATTACHMENT I SAFETY EVALUATION

Attachment I to ET 97-0075 Page 2 of 7 Safety Evaluation Proposed Changes This license amendment request proposes to revise Wolf Creek Generating Station (WCGS) Technical Specification

3. 7.1. 2, Auxiliary Feedwater Sys'em.

(

The proposed revisions would incorporate an Action and Allowed Outage Time to j

account for the inoperability of one of the redundant Essential Service Water (ESW) flowpaths to the Turbine-Driven Auxiliary feedwater Pump (TDAFWP).

In addition, Specification 3.7.1.2 would be modified to include proposed revisions, as applicable to the Limiting Conditions for Operation (LCO) statement and Actions, previously submitted as part of the WCGS Technical Specification Conversion application via letter ET 97-0050, dated May 15, 1997 Specifically, the previously submitted changes are:

• Actions would be incorporated and an Allowed Outage Time (AOT) specified for the steam supply lines to the TDAFWP.

• The descriptive material related to the definition of an Auxiliary Feedwater (AFW) train would be moved from the LCO to the Bases; the word

" train" would be used in lieu of " pumps and associated flow paths."

The time to shut the plant down following failure to meet che Action requirements would be revised to provide 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, instead of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, to get from HOT STANDBY to HOT SHUTDOWN.

Actions would be modified to add a new, overall, AOT that requires meeting the LCO within 10 days of discovery of failure to meet the LCO.

• A footnote would be added for the condition where all three AFW pumps are inoperable to assure that LCO 3.0.3 would not be entered nor any action taken to force the plant into an unsafe condition.

The associated Bases section would also be revised to reflect these changes by including relevant details from the applicable Bases sections submitted in the Technical Specification Conversion application.

These changes support the removal of details from the LCO statement by incorporating these details into the Bases.

Background

The AFW System contains two motor-driven AFW pumps (MDAFWPs) and one TDAFWP.

Refer to Figure 1.

The AFW System is configured into three independent trains with one pump supporting each train.

Each MDAFWP is powered from an independent Class lE power supply and is aligned to feed two steam generators, although each pump has the capability to be aligned locally to feed the other steam generators.

The TDAFWP receives steam from two of the four main steam lines upstream of the main steam isolation valves.

Each of the steam supply flow paths can supply 100% of the requirements of the TDAFWP.

The TDAFhP can supply flow to any of the four steam generators.

The safety-related, seismic Category I water supply to the TDAFWP is provided by flow paths from the ESW System.

Flow to the TDAEWP can be supplied from either ESW Train A or ESW Train B.

Each of these paths can supply 100% of the water flow rate required for the TDAFWP to perform its required safety functions, a

Attachment I to ET 97-0075 Page 3 of 7 9

Upon receipt of an Auxiliary Feedwater Actuation Signal Turbine Driven r

(AFAS-T), the 4-inch steam supply air operated valves automatically open, and the ' turbine mechanical-trip-and-throttle valve opens to supply steam to the TDAFWP.

The auction lines of all AFW pumps are normally aligned to the Condensate Storage Tank (CST) which provides a source of clean, demineralized water for addition to the steam generators.

However, the CST is not seismically qualified, nor is it protected from tornado missiles.

Therefore, the seismic Category I, fully safety-grade water supply for the AFW System is provided by the ESW System.

When the AFW pumps are operating, motor-operated valves (MOVs) automatically open to provide ESW flow to the suction of the AFW pumps upor. receipt of an AFW pump low suction pressure signal (two-out-of-three logic) which would indicate the loss of available flow from the CST.

If the AFAS-T signal is present, the low suction pressure signal actuates the MOVs in the flow paths from both ESW trains to the TDAPWP.

1he Westinghouse Improved Standard Technical Specifications (NUREG-1431, Revision 1) specifically address the steam flow paths to the TDAFWP.

However, in view of the redundancy of these flow paths, the Improved Standard Technical Specifications assign an AOT of 7 days for the condition where one flow path is inoperable.

While in this condition, the TDAFWP is - still OPERABLE and 1

fully capable of performing its safety function, because a single failure of the other steam flow path is not required to be postulated due to the short duration (7 days) that this condition is allowed to exist.

The current technical specifications do not specifically address the steam flow paths.

The requirements for these flow paths have been established by administrative controls which conservatively assume that the TDAFWP is inoperable whenever either steam supply flow path is inoperable.

However, the WCGS Technical Specification Conversion application has included the requirements for the steam flow paths from NUREG-1431.

There are no current technical specification requirements applicable to the ESW - flow paths to the TDAFWP.

In accordance with administrative controls imposed by WCNOC, a 72-hour AOT is applied to the condition where one of the two flow paths is inoperable either by inoperability of the flow path or the associated ESW train.

The TDAFWP is considered OPERABLE while in this AOT because a single failure need not be postulated while in an Action Statement that is time limited.

Evaluation The proposed changes to the technical specification requirements for the AFW System are discussed and evaluated individually in the following paragraphs.

1.

Steam Supply Flow Path Required Actions This proposed change would add a condition to address an inoperable steam flow

-path to the TDAFWP.

The condition and AOT of 7-days is based on the corresponding requirements from NUREG-1431 which have been proposed in the WCGS Technical Specification Conversion application.

The 7-day AOT would replace an administrative control that the TDAFWP is inoperable whener9r one of the steam supply paths is inoperable.

It is appropriate to employ an AOT for each of these paths because the pump is capable of performing its required functions with either of these fully redundant-lines OPERABLE.

The 7-day AOT-is reasonable for the following reasons:

a.

The redundant OPERABLE steam supply to the TDAFWP; b.

The availability of redundant OPERABLE MDAFWPs; and

,t Attachment-I to ET-97-0075-Page 4 of 7 c.

The low probability of an event occurring that requires the inoperable

' steam supply to the TDAFWP.

While in this cendition, 100% of the steam supply requirements for the TDAFWP would still be available via the redundant flow path.

In addition, the MDAFWPs would t>e available under most conditions.

(If a MDAFWP train were inoperable, the time allowed to return it to OPERABLE status would be 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If this could not be done, or if both MDAFWPs were inoperable, the current technical specifications require that the plant be shutdown to at

.least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.)

Further, the chance of a steam or feedwater line break occurring associated with the steam generator supplying steam to the redundant steam flow path is very remote.

The probability of this type of accident occurring is very small.

And the probability of its

-occurring on one, of four, steam generators and within the 7-day time window allowed by the proposed AOT is also very small.

Therefore, the chances of L

this combination of events occurring is unlikely.

Based on these facts, an AOT of 7. days is acceptable for a steam supply path to the TDAFWP.

The above changes are consistent with NUREG-1431 and were included in the WCGS Technical Specification Conversion application.

2.

ESW Flow Path Required Actions The proposed changes would add an Action to address the condition where one of the two ESW flow paths to the TDAFWP is inoperable.

A 7-day AOT would be applied to this condition.

This would represent an addition. of a new requirement to the current technical specifications.

It would replace administrative controls that impose a 72-hour ACT~ based on the conservative assumption that this condition should apply the. same AOT as the ESW Specification (LCO 3.7.4) for loss of one train (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />).

No credit is given for the other flowpath.from the opposite train ESW to the TDAFWP. Also, no-credit-is given for the availability of the CST.

It is appropriate. to employ an AOT for the ESW flow paths because of their similarity to the steam supply flow paths in supporting TDAFWP operation.

A 7-day AOT is justified in this. case for the following reasons:

-a.

The redundant OPERABLE ESW supply line to the TDAFWP which is analogous to-the redundant steam supply-lines discussed above; b.

The availability of-the preferred, non-safety grade supply of water-from the CST, the OPERABILITY of which is maintained by.LCO 3.7.1.3; c.

The remaining OPERABLE MDAFWP; d.

The low 1 probability of an event occurring that will require the inoperable ESW supply-line to the TDAFWP; and The 7-day AOT is consistent with the AOT for one steam supply flow path e.

to the TDAFWP.

Further justification for an AOT period of 7 days may be based on the testing that-is performed on the motor-operated valves (MOVs) that open to supply ESW flow to the.TDAFWP.

The MOVs are tested quarterly in accordance with the Inservice Testing-Program; this is the same frequency of testing as applied to the_ steam supply valves to the TDAFWP which have a proposed 7-day AOT based on NUREG-1431.

In addition, the MOVs are tested to assure OPERABILITY when required in accordance with the MOV test program.

' Attachment --I - to = ET ' 97-0075 Page 5 of 7 3.

Use of " Trains" Instead of " Pumps. and Associated Flow Paths" and Removal of Unnecessary Details.

-i The proposed technical specification changes would move descriptive material from the LCO and Actions regarding AFW pump flow paths and power supplies.

This detail would be moved to the Bases of the technical specifications.

These Lehanges a;e acceptable because these details are not required to be a part of technical specifications in order to protect the health and safety of the public. The specific requirements that are necessary to assure AFW System i

OPERABILITY are retained.

In addition, the use of " trains" when discussing AFW System requirements instead of " pumps" or " pumps and associated flow paths" is an administrative change and is acceptable because the meaning and scope of the technical specifications are not altered because of them.

The above changes are consistent with NUREG-1431 and were included in the WCGS Technical Specification Conversion application.

.4.

Twelve Hours to HOT SHUTDOWN The time-from failure to meet the Action requirements to shut the plant down would be revised from achieving HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to achieving HOT STANDBY within the next

-6 hours and HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

This is acceptable considering the AFW System capabilities would be limited while in an Action Statement and is consistent with cooling down at a rate that avoids challenges to plant systems.

The likelihood that an accident requiring AFW availability would occur during the-additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> allowed by this proposed change is very_'small.

The proposed change'would allow an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to cool the plant below 350-'F; at=this temperature, an alternative heat removal system, the' Residual Heat Removal System, becomes available.

This change is consistent with NUREG-1431, which has applied this longer time to achieve HOT SHUTDOWN conditions to several LCOs that depend on a degraded AFW System, and-was included in the WCGS Technical Specification-Conversion application.

5.

Additional AOT of 10 Days from-Discovery of Failure to Meet the LCO.

The Actions would be modified to require restoration of - the systems to meet the AFW LCO within 10 days of discovery of failure to meet the LCO.

This is accomplished by adding the words "and within 10 days from discovery of failure

'to meet.the-LCO" to the=72-hour restoration time' for an inoperable AFW train.

and to the proposed restoration time of 7-days for the steam and ESW flow l

1 paths to the TDAFWP.

This new requirement-is intended to prevent-multiple overlapping Action entries.such that the intended AOT is not exceeded.

This ~ proposed change is - acceptable because it results in more stringent, better-defined, technical specification requirements that are both appropriate

and consistent with NUREG-1431.

This change was included in the WCGS Technical Specification Conversion application.

6..

Suspension of LCO 3.0.3 A Note would be added to the Action for three inoperable AEW trains.

The Note I

would state.that "LCO 3.0.3 and all other LCO Actions ~ requiring MODE changes are suspended until one AFW train is restored to OPERABLE status."

This is intended-to avoid plant maneuvering to effect MODE changes with no AFW train available which potentially would be unsafe should an event occur due to.the maneuvering that would require emergency feedwater flow to one or more steam-generators. This provision was implied by the current technical specification Action for no ' AFW trains OPERABLE which has no shutdown requirements - only

-the requirement to-restore at least one AFW train as soon as possible.

Adding

i Attachment I to ET 97-0075 Page 6 of 7 the hote as proposed is considered an administrative change to the technical specification that adds clarification. As the proposed change would not alter

• -any requirements of the technical specificatior, it is acceptaole.

The above change is consistent wit h NUREG-14 31 and was included in the WCGS i

Technical Specification Conversion application.

I Conclusion Baut d on the above discussions and the No Significant Hazards Consideration

'se t

t.ination presented in Attachment II, the proposed changes do not increase the-probab'lity of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the Updated Safety Analysis Report; or create a possibility for an accident or malfunction of = a dif ferent type than any previously evaluated in the safety analyses report; or reduce the margin of safety as defined in the basis for any technical specification.

Therefore, the proposed changes do not adversely aflect or endanger the health or safety of the general public or involve a significant-saiety hazard.

At t achn ent I to ET 97-0075 Pago 7 of 7 FIGuitE 1 TUR131NE Dh1VE!J AUXILI ARY TEEDWATER PUMP STEAM AtJD ESW FLOWPATHS Main Steam Main Steam Loop?

Loop 3 l I l I NC, FO NC, FO 4--

1 I

i 1 r y

Mech Trip &

l Throttle Valve

(.

TURBINE TDAFP a

1

- a a

y NC M

NO M

M NC ESW A ESWB

/

Suct.

-O Pre..

v g Xmitters MDAFP A

, MDAFP B CST

Attachment II to ET 97-0075 0

Page 1 of 7 ATTACHMENT II NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION i

Attachment II t o ET 97-0075 Page 2 of 7 No Significant Hazards Consideration Determination Proposed Changes This license amendment request proposes to revise Wolf Creek Generating Station (WCGS) Technical Specification

3. 7.1. 2, Auxiliary Feedwater System.

The proposed revisions would incorporate an Action and Allowed Outage Time of 7-days to account for the inoperability of one of the redundant Essential Service Water (ESW) flowpaths to the Turbine-Driven Auxiliary Feedwater Pump (TDAEMP).

This change adds a requirement that is not contained in current technical specification.

However, it would replace an interpretation, imposed under administrative controls, that an inoperable ESW supply path would have a 72-hour Allowed Outage Time (AOT).

Therefore, the proposed change is less restrictive than current practice.

l In addition, Specification 3.7.1.2 would be modified to include proposed revisions, as applicable to the Limiting conditions for Operation (LCO) statement and Actions, previously submitted as part of the WCGS Technical Specification Conversion application via letter ET 97-0050, dated May 15, 1997.

Specifically, the previously submitted changes are:

• Actions would be incorporated and an AOT specified for the steam supply valves to the TDAFWP.

The current technical specification defines the TDAFWP as OPERABLE if it can be powered from an OPERABLE steam supply system.

Since no ACTIONS are specified for an inoperable st 'am supply, the TDAFWP must be declared inoperable if one of the two reiundant steam supplies becomes inoperable.

The requirement for two supplies is based upon the steam generator tube rupture (SGTR) and main steam l'ir{e break (MSLB) accidents to assure that a 100 percent redundant steam supply to the TDAFWP is available.

NUREG-1431 provides a Required Action if one of the steam supplies becomes inoperable thus avoiding inoperability of the pump.

NUREG-1431 recognizes that the TDAFWP can continue to perform its intended function with only one steam supply Jince the supplies are redundant.

NUREG-1431 requires that with only a single steam supply OPERABLE that a Required Action be entered.

The tinn to return the inoperable steam supply to an OPERABLE condition is seven days.

This time is reasonable considering that the likelihood of an accident together with the loss of auxiliary feedwater function is very low during this AOT.

This is based on:

1)

A MSLB or SGTR event could eliminate a source of steam to the TDAFWP if the faulted steam generator was one of the steam generators supplying steam for the pump.

However, the probability of these events occurring during the 7-day period is very small.

Furthermore, the redundant MDAFWPs would remain available to support the auxiliary feedwater function.

2)

A station blackout (SBO) event would by definition result in the loss of the MDAFWPs.

However, the probability of a SBO during the 7-day period together with the low probability of failure of the remaining steam supply path is also very low.

Furthermore, the assumed single failure of the remaining steam supp.'y valve is not required to be postuleted for the analysis of a SBO event.

The descriptive material related to the definition of an AFW train would be deleted from the LCO and moved to the Bases; the word " train" is used in lieu-of " pumps and associated flow paths "

. 1 t o E'I 97-0075 Page 3 cf 7 l

Using " trains" instead of " pumps" or " pumps and associated flow paths" represents an administrative change that has no effect on the application of the LCO.

However, this change permits moving details regarding APW pumps and associated flow paths to a licensee-controlled document in this case, the technical specification Bases.

The NRC has previously approved moving this type of detailed information or specific requirement to a licensee controlled document, maintained in accordance with applicable regulatory requirements, since its inclusion in the technical specifications is not necessaty to adequately protect the health and safety of the public.

Therefore, the descriptive information that har, been moved continues to be maintained in an appropriately controlled manner due to the controls which presently exist on the documents where the information will l

reside.

l The time from failure to meet the Action requirements to shut the plant down would be revised to provide 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, instead of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, to get from HOT STANDBY to HOT SHUTDOWN.

This change would allow an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to achieve HOT SHUTDOWN for the AFW System.

This is consistent with NUREG-1431 shutdown requirements for the AFW System, the Condensate Storage Tank (CST), and the atmospheric relief lines if they were inoperable.

Once HOT SHUTDOWN was achieved, the plant would be in a MODE where the Residual Heat Removal (RHR) System would l

be OPERABLE in addition to the OPERABLE AFW train (s)and the support systems used to perform the cooldown to HOT SHUTDOWN conditions.

Since the inoperable AFW train (s) and the support systems may affect the normal cooldown rate, the Improved Standard Technical Speci f ications allow an additional six hours to achieve MODE 4.

The added time provides additional margin to perforn an orderly transfer from the steam generator method of heat removal to the RHR system to maintain the heat removal function without challenging unit systems.

Actions would be modified to add a new, overall, A0T that requires meeting the LCO within 10 days of discovery of failure to meet the LCO.

The addition of this overall 10-day limit on allowed outage for the AFW System is derived from NUREG-1431.

The requirement is intended to prevent the AFW LCO from being entered for more than a total of 10 days even though entering individual Actions, as specified in proposed changes, jn sequence could allow the combined A0T to exceed 10 days.

Adding this restriction, which is not in current technical specifications, represents a change to the technical specification that is more restrictive.

No relaxation in technical specification requirements is involved with this change.

• A footnote would be added for the condition where all three AFW pumps are inoperable to assure that LCO 3.0.3 would not be entered nor any action taken to force the plant into an unsafe condition.

Adding this footnote is an administrative change to the current technical specification because the requirements of this Note are implied in the wording of the current Action for all three AFW pumps inoperable.

This type of change is intended to make the technical specification more understandable to the user.

It does not make any technical changes (either actual or interpretational) to the technical specification.

Thus, this type of change has no impact on safe operation of the plant, r

. 1 to ET 97-0075 Page 4 of 7 Application of Standards The 'following Standards identified in 10 CFR 50.92 have been used to determine whether the proposed changes involve a Significant Hazards Consideration.

Each of the identified proposed changes is evaluated against the three Standards.

Standard 1 - Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated 1.

ESW Flow Path kequired Act ions This change would provide a 7-day A0T_for the ESW supply flow paths to the l

TDAFWP.

This would replace administrative controls that imposed a 72-hour A0T on ESW flow paths to thw TDAFWP.

The proposed change does not result in any hardware changes or changes to operating rnethodologies.

This revision does not affect an accident initiator of any analyzed accident since the TDAFWP ESW supply only provides flow _to equipment required to mitigate the consequences of an accident.

The revision recognizes that the TDAFWP would remain available in most cases for accident mitigation because of the low probability of an accident and subsequent equipment failure requiring the use of the inoperable ESW supply for the TDAFWP.

Changing the A0T from 3 days to 7 days would have a negligible effect on this small probability.

Loss of the AFW function would also require the failure of the MDAFWPs.

In addition, the CST would be OPERABLE in accordance with LCO 3.7.1.3 and would be available for use t.y the TDAFWP for all events except those external-hazards that represent a hazard to the integrity of the tank itself.

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

2.

Steam Supply Flow Path Required Actione This change would provide a i-day A0T for the steam supply flow paths to the TDAFWP.

This would replace an administrative control that required the TDAFWP to be declared inoperable without applying an A0T.

The proposed change does not result in any hardware changes or changes to operating methodologies.

This revision does not affect an accident initiator of any analyzed accident since the TDAFWP steam supply only provides power to equipment required to taitigate the consequences of an accident.

The revision recognizes the low probability of an accident requiring the use of the inoperable steam supply for the TDAFWP coincident with the failure of the MDAFWPs.

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

3.

Use of " Trains" Instead of " Pumps and Associated Flow Paths" and Removal of Unnecessary Details.

This change is partially administrative and partially a movement of provisions not required to be in the technical specifications to other controlled documents.

The administrative change does not impact initiators of analyzed events or equipment assumed in the mitigation of accidents or transient events.

The details moved from the technical specification would be located in the Bases of the technical specification.

Since any changes to the Bases will be evaluated per the requirements of 10 CFR 50.59, proper contrals are in place to _ adequately limit the probability or consequences of ea accident previously evaluated.

Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Attachment II to ET 97-007$

Page 5 of 7 4.

Twelve Hours t o HOT SHUTDOWN This change would allow an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to achieve HOT SHUTDOWN for the APW System. The proposed change does not alter the plant configuratfors or operation or function of any safety system.

Consequently, tne change does not increase the probability of an accident as defined in accident analysis.

W proposed change permits a longer time to cooldown to RHR entry conditior.a however, this would not afftet the consequences of any postulated accidents and is appropriate due to the need to avoid any transients while cooling down with a potentially degraded AFW System.

Therefore, the proposed change would have no significant effeet on the probability or consequences of any previously analyzed accidents, l

S.

Additional AOT of 10 Days from Discovery of Failure to Meet the LCO.

Th9 proposed change imposes more stringent requirements than contained in i

current technical specification.

The more stringent requirements are imposed l

to ensure that the OPERABILITY requirements for the AFW System are maintained l

consistent with the safety analysis and licensing basis.

Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

6.

Suspension of LCO 3.0.3 The proposed change involves clarifying the technical specification.

The proposed revision involves no technical changes to the current technical specification.

As such, this change is administrative in nature and does not impact initiators of analyzed events or assumed mitigation of accidents or transient events.

Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Standard II - Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated 1.

ESW Flow Path Required Actions The proposed change to add a 7-day AOT for the ESW supply flow paths does not require physical alteration to any plant system or change the method by which any safety-related system performs its function.

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

2.

Steam Supply Flow Path Required Actione The proposed change to add a 7-day AOT for the steam supply flow paths does not - require physical alteration to any plant system or change the method by which any safety-related system performs its function.

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

Attachment II to ET 97-0075 8

Page 6 of 7 l

3.

Use of " Trains" Instead of "Purrps and Associated Flow Paths" and Moving of Unnecessary Details.

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or changes in controlling parameters. The proposed chango will not impose any different l

requirements and adequate control of the information moved to the Bases will l

be maintained.

The proposed change will not impose any different requirements.

Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

4.

Twelve Hours to HOT SHUTDOWN The proposed change does not require physical alteration to any plant system or change the method by which any safety-related system performs its function.

As discussed above, the change does allow additional time to complete the transfer from the SG as the method for heat removal to the RHR System, but does not alter the basic methodology.

Therefore, the proposed-change would not create the possibility of a new or different kind of accident.

5.

Additional AOT of 10 Days from Discover of Failure to Meet the LCO.

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or changes in controlling parameters.

The proposed change does impose different (more restrictive) requirements.

However, these changes remain consistent with assumptions made in the safety analysis regarding system OPERABILITY.

Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

6.

Suspension of LCO 3.0.3 The proposed change clarifies an implied requirement from current technical specifications and does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or changes in controlling parameters.

The proposed change will not impose any different requirements.

Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Standard III - Involve a Significant Reduction in the Margin of Safety 1.

ESW Flow Path Required Actions The proposed change to add a 7-day ACT for the ESW flow paths does not change any accident analysis assumptions, initial conditions or results.

Consequently, it does not have an effect on margin of safety.

Therefore, the proposed change does not involve a significant reduction in a margin of safety, 2.

Steam Supply Flow Path Required Actions The proposed change to add a 7-day ACT for the steam supply flow paths does not change any accident analysis assumptions, initial conditions or results.

Consequently, it does not have an effect on margin of safety.

' 1 to ET 97-0075 8

Page 7 of 7 j

Therefore, the proposed change does not involve a significant reduction in a l

margin of safety.

l 3.

Use of " Trains" Instead of " Pumps and Associated Flow Paths" and Removal of Unnecessary Details.

The proposed change will not reduce a margin of safety because it has no impact on the design basis or safety analysis.

In addition, the requirements to be tran. posed from the technical specification to the Bases are the same as the current technical specification.

Since any _ future changes to these requirements in the Bases will be evaluated per the requirements of 10 CFR 50.59, proper controls are in place to maintain an appropriate margin of safety.

Therefore, the changes do not involve a significant reduction in a margin of safety.

4.

Twelve Hours to HOT SHUTDOWN The proposed change does not alter the basic regulatory requirements or change any accident analysis assumptions, initial conditions or results.

Therefore,- the proposed change would have no significant adverse ef fect oon margins of safety.

5.

Additional A0T of 10 Days from Discovery of Failure to Meet the LCO.

The imposition of more stringent requirements on A0T would increase the margin of plant safety by providing additional requirements to maintain AIM System OPERABILITY.

The change is consistent with the safety analysis and licensing basis.

Therefore, this change does not involve a reduction in a margin of safety.

6.

Suspension of LCO 3.0.3 The proposed change will not reduce a margin of safety because it has no impact on the design basis or safety analysis.

This change is administrative in nature. As such, no question of safety is involved.

Conclusions Based on the above discussions, it has been determined that the requested technical specification revisions do not involve a significant increase in the probability of consequences of an accident or other adverse conditions over previous evaluations; or create the possibility of a new or different kind of accident or condition over pre'i us evaluations; or involve a significant reduction in a margin of safety Therefore, the requested license amendment does not involve a significant hazards consideration.

Attachment III to ET 97-0075 Page 1 of 2 I

l ATTACHMENT III ENVIRONMENTAL IMPACT DETERMINATION

" 11 to FT 97-0075 Page 2 of 2 8

Environmental Impact Determination 10 CFR 51.22(b) specifies the criteria for categorical exclusions from the requirement for a specific environmental assessment per 10 CFR 51.21.

This amendment request meets the criteria specified in 10 CFR 51,22 (c ) ( 9) as specified belows (1) the amendment involves no significant hazards consideration As demonstrated in Attachment II, the proposed changes do 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 None of the proposed changes involves a change to the facility or operating proceduren that would cause an increase in the amounts of effluents or create new types of effluents.

(iii) there is no significant increase in individual or cumulative occupational radiation exposure The proposed changes relate to Actions and Allowed Outage Times for the Auxiliary feedwater System.

These changes have no relation to occupational radiation exposure, either individual or cumulative.

Based on the above, it is concluded that there will be no impact on the environment resulting from this change and the change meets the criteria specified in 10 CFR 51.22 for a categorical exclusion from the requirements of 10 CFR 51.21 relative to requiring a specific environmental assessment by the Commission.