Text

Proposed Tech Specs Adding New LCO 3.0.6 to Section 3/4.0, Applicability
	ML20216G101
Person / Time
Site:	Beaver Valley
Issue date:	03/16/1998
From:	; DUQUESNE LIGHT CO.
To:	;
Shared Package
ML20216G097	List: L-98-048, Application for Amends to Licenses DPR-66 & NPF-73,adding New LCO 3.0.6 to Section 3/4.0, Applicability; ML20216G101;
References
	NUDOCS 9803190211
	Download: ML20216G101 (16)
	v • d • e

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ATTACHMENT A-1 Beaver Valley Power Station, Unit No. 1 License Amendment Request No. 255 The following is a list of the affected pages:

Affected Pages: 3/4 0-2 B 3/4 0-5 l

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l 9803190211 980316 PDR ADOCK 05000334 P PDR

OPR-66 l 3 /4. 3 APF1::A2:L:TY SUR*/EILLANCE REQUIREMENTS

1. At least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ,

2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and

3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

This specification is not applicable in MODES 5 or 6.

ZNWAT 4.0.1 I Surveillance Requirements shall be met during the OPERATIONAL MODES or other conditions specified for individual Limiting ,

Conditions for Operation unless otherwise stated in an individual j Surveillance Requirement. I i

4.0.2 Each Surveillance Requirement shall be performed within the i specified time interval with a maximum allowable extension not to exceed 25% of the surveillance interval.

I 4.0.3 Failure to perform a Surveillance Requirement within the i allowed surveillance interval, defined by Specification 4.0.2, I shall constitute noncompliance with the OPERABILITY requirements for l a Limiting Condition for Operation. The time limits of the ACTION requirements are applicable at the time it is identified that a Surveillance Requirement has not been performed. The ACTION requirements may be delayed for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to permit the completion of the surveillance when the allowable outage time limits )

of the ACTION requirements are less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Surveillance Requirements do not have to be performed on inoperable equipment.

4.0.4 Entry into an OPERATIONAL MODE or other specified condition l shall not be made unless the Surveillance Requirement (s) associated l with a Limiting Condition for Operation has been performed within

, the stated surveillance interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements.

4.0.5 Surveillance , Requirements for inservice inspection and testing of ASME Code Class 1, 2 and 3 components shall be applicable as follows:

a.1 Inservice inspection of ASME Code Class 1, 2 and 3 components shall be performed in accordance with section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g).

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BEAVER VALLEY - UNIT 1 3/4 0-2 Amendment No.++t Yi0$0C$ nl&I h

Attachmsnt A-1 Beaver Valley Power Station, Unit No. 1 License Amendment Recuest No. 255 INSERT 1 3.0.6 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to Limiting condition for Operation 3.0.1 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

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DPR-66 APPLICABILITY BASES

' components and devices in the other division must be OPERABLE, or likewise satisfy Specification 3.0.5 (i.e., be capable of performing their design functions and have an emergency power source OPERABLE). In other words, both emergency power sources must be OPERABLE and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE. If these conditions are not satisfied, action is required in accordance with l this specification.

In MODES 5 or 6 Specification 3.0.5 is not applicable, and thus the individual ACTION statements for each applicable Limiting Condition for Operation in these MODES must be adhered to.

SA6 W $-6 Scecification 4.0.1 threuch 4.0.5 establish the general requirements applicable to Surveillance Requirements. These requirements are based on the Surveillance Requirements stated in the Code of Federal Regulations, 10 CFR 50.36 (c) (3) :

" Surveillance requirements are requirements relating to test, calibration, or inspection to ensure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be met".

Seeeification 4.0.1 establishes the requirement that surveillances must be performed during the OPERATIONAL MODES or other conditions for which the requirements of the Limiting Conditions for Operation apply unless otherwise stated in an individual Surveillance Requirement. The purpose of this specification is to ensure that surveillances are performed to verify the operational status of systems and components and that parameters are within specified ,

limits to ensure safe operation of the facility when the plant is in I a MODE or other specified condition for which the associated Limiting Conditions for Operation are applicable. Surveillance Requirements do not have to be performed when the facility is in an OPERATIONAL MODE for which the requirements of the associated Limit-ing condition for Operation do not apply unless otherwise specified.

The Surveillance Requirements associated with a Special Test Excep-tion are only applicable when the Special Test Exception is used as an allowable exception to the requirements of a Specification.

Seecification 4.0.2 establishes the limit for which the specified time interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g., transient conditions or other ongoing surveill-ance or maintenance activities. It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 13-month surveillance interval. It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outages. The limitation of Specification 4.0.2 is based on engineering judgement and the recognition that the most probable BEAVER VALLEY - UNIT 1 B3 0-5 Amendment No. t+P 0%w/4d Wad,y

Attcchssnt A-1 BO vsr VollGy PowIr Station, Unit No. 1 License Amendment Reauest No. 255 I14 SERT 2 Soecification 3.0.6 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this specification is to provide an exception to Specification 3.0.1 (e.g., to not comply with the applicable ACTIONS) to allow the performance of Surveillance Requirements and post maintenance testing to demonstrate:-

a. The OPERABILITY of the equipment being returned to service; or

b. The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the . allowed testing. This specification does not provide time to perform any other preventive or corrective maintenance. Minor corrections such ,

as adjustments of limit switches to correct position indication J anomalies are considered within the scope of this specification.

Other more significant tasks such as valve packing replacement are not permitted by this specification.

It is expected that the testing will confirm equipment operability.

Should the testing demonstrate that the equipment is not operable, the provisions of LCO 3.0.1 will be applied.

An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with ACTIONS and must be reopened to perform the surveillance requirements.

An example of demonstrating _ the OPERABILITY of other equipment is ;

taking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occurring during the performance of a surveillance requirement on another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of a surveillance requirement on another channel in the same trip system. '

ATTACHMENT A-2 Beaver Valley Power Station, Unit No. 2 License Amendment Request No. 124 The following is a list of the affected pages:

Affected Pages: 3/4 0-2 B 3/4 0-5 1

NPF-73 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS

'3N. 0 APPLICA8!LITY LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the

~ succeeding specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

3.0.2 Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

3.0.3 When a Limiting Condition for Operation is not met except as provided in the associated ACTION requirements, within one hour action shall be initiated to place the unit in a MODE in which the specification does not apply by placing it, as applicable, in:

1. At least HOT STAN08Y within the'next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ,

2. At least NOT SHUTOOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and

3. At least COLD SHUTOOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Where corrective measures are completed that pemit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these requirements are stated in the individual specifications.

3.0.4 Entry into an OPERATIONAL M00E or other specified condition shall not be made when the conditions for the Limiting Condition for Operation are not met and the associated ACTION requires a shutdown if they are not met within a specified time interval. Entry into an OPERATIONAL N00E or specified condition may be made in accordance with ACTION requirements when conformance to them j permits continued operation of the facility for an unlimited period of time. 1 This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements. Exceptions to these requirements are stated in the individual specifications.

3.0.5 When a system, subsystem, train, component or device is determined to be inoperable solely because its emergency power source is inoperable, or solely because its novinel power source is inoperable, it may be considered OPERA 8LE for the purpose of satisfying the requirements of its applicable limiting Con-dition for Operation, provided: (1) its corresponding nomal or emergency power source is OPERABLE; and (2) all of its redundant system (s), subsystem (s),

train (s), component (s) and device (s) are OPERA 8LE, or likewise satisfy the ,

requirements of this specification. Unless both conditions (1) and (2) are !

satisfied within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , action shall be initiated to place the unit in a '

M00E in which the applicable Limiting condition for Operation does not apply, by placing it, as applicable, in: 4

1. At least HOT STAN08Y within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ,

2. At least H0T SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and !

3. At least COLD SHUTOOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

This specification is not applicable in M00ES 5 or 6. !

Di$2nfL BEAVER VALLEY - UNIT 2 3/4 0-1 Amendment No. 4 )

Attachment _A-2 Basvar Valley Power Stntion, Unit No. 2 License Amendment Reauest No. 124 INSERT 1 3.0.6 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform. testing required to demonstrate its OPERABILITY or the OPERABILITY _ of other equipment. This is an exception to Limiting condition .for Operation 3.0.1 for the system returned to service under ' administrative control to perform the testing required to demonstrate OPERABILITY.

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' NPF-73 3/4.0 APDLICABILITV BASES (Centinued) trains, components and devices in the other division must be OPERABLE, or like-wise satisfy Specification 3.0.5 (i.e. , be capable of performing their design functions and have an emergency power source OPERA 8LE). In other words, both emergency power sources must be OPERABLE and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE. If these conditions are not satisfied, action is required in accordance with this specification.

In MODES S or 6 Specification 3.0.5 is not applicable, and thus the indi-vidual ACTION statements for each applicable Limiting Condition for Operation in these MODES must be adhered to.

.lTWMT~ k Specifications 4.0.1 through 4.0.5 establish the general requirements applicable to Surveillance Requirements. These requirements are based on the Surveillance Requirements stated in the Code of Federal Regulations, 10 CFR 50.36(c)(3):

" Surveillance requirements are requirements relating to test, calibration, or inspection to ensure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be met." .

Specifications 4.0.1 establishes the requirement that surveillances must be performed during the OPERATIONAL MODES or other conditions for which the requirements of the Limiting Conditions for Operation apply unless otherwise stated in an individual Surveillance Requirement. The purpose of this specifi-cation is to ensure that surveillances are performed to verify the operational status of systems and components and that parameters are within specified limits to ensure safe operation of the facility when the plant is in a MODE or other specified condition for which the associated Limiting Conditions for Operation are appifcable. Surveillance Requirements do not have to be performed when the facility is in an OPERATIONAL M00E for which the requirements of the associated Limiting Condition for Operation do not apply unless otherwise specified. The Surveillance Requirements associated with a Special Test Excep-tion are only apolicable when the Special Test Exception is used as an allow-able exception to the requirements of a specification.

Specification 4.0.2 establishes the limit for which the specified time interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate surveil-lance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g. , transient conditions or other ongoing surveillance or maintenance activities. It also provides flex-ibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 18-month surveillance interval. It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillances that are not perfomed during refueling outages.

The limitation of Specification 4.0.2 is based on engineering judgment and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance i Requirements. This provision is !

l BEAVER VALLEY - UNIT 2 Amendment No. 4,-99=

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Attachment A-2 Brev:r Valley Powsr Station, Unit No. 2 License Amendment Recuest No. 124 INSERT 2 Specification 3.0.6 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this specification is to provide an exception to Specification 3.0.1 (e.g., to not comply with the applicable ACTIONS) to allow the performance of Surveillance Requirements and post maintenance testing to demonstrate:

a. The OPERABILITY of the equipment being returned to service; or

b. The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the ' allowed testing. This specification does not provide time to perform any other preventive or corrective maintenance. Minor corrections such as adjustments of limit switches to correct position indication anomalies are considered within the scope of this specification.

Other more significant tasks such as valve packing replacement are not permitted by this specification.

It is expected that the testing will confirm equipment operability.

Should the testing demonstrate that the equipment is not operable, the provisions of LCO 3.0.1 will be applied.

An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with ACTIONS and must be reopened to perform the surveillance requirements.

An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occurring during the performance of a surveillance requirement on another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of a surveillance requirement on another channel in the same trip system.

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ATTACHMENT B Beaver Valley Power Station, Unit Nos. 1 and 2 License Amendment Request Nos. 255 and 124 EQUIPMENT RETURNED TO SERVICE IN ORDER TO DEMONSTRATE OPERABILITY A. DESCRIPTION OF AMENDMENT REQUEST The proposed change will add a new Limiting Condition for Operation (LCO) 3.0.6 to Section 3/4.0, APPLICABILITY. The new 3.0.6 provides specific guidance for returning equipment to service under administrative control for the sole purpose of performing testing to demonstrate OPERABILITY.

B. BASES Action statements within the Technical Specifications (TS) provide guidance for compensatory actions and other restrictions to be taken when the requirements of an LCO cannot be met. When equipment has been out of service it is necessary to demonstrate that it can perform its required function before it can be returned to an OPERABLE condition. Some action statements require that components be placed in a condition which prohibits the functional testing necessary to return components and/or associated systems to OPERABLE status. In these cases, the proposed change provides guidance for returning equipment to service for the sole purpose of demonstrating OPERABILITY. Two examples are provided below.

As a prudent measure, a decision was made to repair all three Power Operated Relief Valves (PORVs), 2RCS-PCV455C, 455D, and 456, which were leaking, prior to startup from the current Unit 2 outage. When the repair work was completed, a Temporary Operating Procedure (TOP) was written to ensure all administrative controls would be in place before pressurizing the plant for a post maintenance test. For this test, the PORVs must have pressure in order to be stroke tested. During the review of the TOP, the Onsite Safety Committee (OSC) identified that TS 3.0.1 did not allow the Reactor Coolant System (RCS) to be repressurized with all three PORVs inoperable (i.e., without normal overpressure protection system operable). The current TS creates a dilemma in that Unit 2 cannot be pressurized without the PORVs operable and the PORVs cannot be tested to demonstrate operability without pressurizing the plant. The current TS (unlike the Improved Standard Technical Specifications) does not allow changing plant conditions under administrative control to support returning equipment to service.

A second example of this problem with TS 3.0.1 is Specification 3.1.3.3, Position Indication System -

Shutdown. Specification 3.1.3.3 requires that the group demand position indicators be OPERABLE and capable of determining within 2 steps, the demand position for each shutdown or control rod not fully inserted.

This specification is applicable in MODES 3, 4, and 5 when the reactor trip system breakers are in the closed position. The

ATTACHMENT B, continusd

-License Amendment Request Nos. 255 and 124 Page 2

l. action statement requires opening of -the reactor trip system Surveillance'4.1.3.3 requires.that-at least once per breakers.

31 days, certain control rods be moved at least 10 steps in any one direction when the reactor coolant system pressure is greater than 400 psig.

If Surveillance 4.1.3.3 has not been completed within the last.31

! days due to an extended plant shutdown, plant startup will not be possible'since the ACTION statement of-Specification 3.1.3.3 will not permit closing of the reactor trip breakers to perform the necessary testing to demonstrate equipment operability.

Therefore, the application of Specification 3.0.6 is necessary in l

this situation to allow the required testing of the group demand position indicators to. support plant restart. Unit 1 is in this condition at the present time.

Duquesne Light Company, 'therefore, proposes a- new general applicability specification 3.0.6 and associated bases which provide specific guidance on the ability to operate a component under administrative control if necessary to complete a test to demonstrate OPERABILITY.

C. JUSTIFICATION .

This change has no. impact on plant equipment or its operation.

It clarifies that testing necessary to declare equipment OPERABLE, may be completed under administrative control. The exception may be used only for a specific purpose and only on equipment . that the licensee believes .has been repaired or- is otherwise capable of carrying out its TS function. The need for this exception has been recognized by both the industry and the NRC staff and an essentially identical statement is incorporated into the current Standara Technical Specifications for Westinghouse Plants, NUREG-1431, Rev. 1 as LCO 3.0.5.

The proposed BVPS-1 and BVPS-2 change has minor editorial changes from - the wording of NUREG-1431 to reflect the differences in ,

wording of LCO 3~.0.1 of the current BVPS-1 and BVPS-2 Technical !

Specifications and LCO 3.0.1 of the NUREG. The proposed bases for LCO.3.0.6 is essentially the same as the wording of the bases

-for LCO 3.0.5 in NUREG 1431, Rev. 1. The wording is different in !

-that it allows post maintenance testing, in addition to i surveillance testing, to demonstrate ' operability of equipment i being returned to service, or to demonstrate operability of other l equipment. This clarification to add post maintenance testing is j L consistent with the- intent of the exception. Post maintenance testing is performed following maintenance ~ or modification to return components to operable status. This testing may include l steps that go beyond the steps required by the normal l' surveillance test, but are necessary to demonstrate operability.

! The bases for LCO 3.0.6 has also been revised to include guidance for appropriate actions should the testing demonstrate that the i B-2 1

i ATTACHMENT B, continued License Amendment Request Nos. 255 and 124 Page 3 equipment is not operable. In this case, the provisions of LCO 3.0.1 will be applied. LCO 3.0.1, in this case, requires that the associated action requirement be met.

The LCO 3.0.6 bases has also been revised to include minor corrections, such as limit switch adjustments to correct position indication anomalies, within the scope of this specification.

Typically, these adjustments cannot be performed until the associated equipment is placed in service, and is necessary to demonstrate operability of the equipment.

In NUREG-1431, LCO 3.0.1 simply references LCO 3.0.2 for instances of noncompliance and does not mention ACTION statements. LCO 3.0.5 represents an exception to meeting the Required Actions as presented in a given specification, and since LCO 3.0.2 is the specification which directs compliance with the ACTION requirements, it is the only one to which exception must be taken.

The current BVPS-1 and BVPS-2 Technical Specification 3.0.1 contains the phrase " ...upon failure to meet the Limiting Condition for Operation, the associated ACTION requirements shall be met." The current BVPS-1 and BVPS-2 TS 3.0.2 states: I

" Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and the associated ACTION requirements are not met within the specified time intervals." Therefore, since only 3.0.1 of the BVPS-1 and BVPS-2 specifications directs compliance with the ACTION requirements, the proposed 3.0.6 only states that it is an exception to 3.0.1.

The requested change revises the Technical Specifications to prcvide specific guidance that components may be operated under I administrative control in order to demonstrate OPERABILITY. The change is functionally identical to the guidance provided on this issue in the current Standard Technical Specifications for Westinghouse Plants, NUREG-1431, Rev. 1.

D. SAFETY ANALYSIS The present Technical Specifications (TS) for BVPS-1 and BVPS-2 i neither specifically allow nor prohibit re-entry into ACTION l statements. In the Standard Technical Specifications for Westinghouse Plants, NUREG-1431, Vol. 1, Rev. 1, the NRC staff approved a provision, via TS 3.0.5 section, that establishes the l allowance for restoring equipment to service under plant administrative control when it has been removed from service or declared inoperable to comply with ACTIONS statement. The sole purpose of this specification is to provide an exception to the limiting conditions for operation (LCO) 3.0.1 (e.g., to not comply with the applicable Required Action (s)) to allow I performance of surveillance requirements (SRs) to demonstrate:

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l ATTACHMENT B, continusd License Amendment Request Nos. 255 and 124 Page 4 I

a. The OPERABILITY of the equipment being returned to l service; or

b. The OPERABILITY of other equipment.

The current BVPS-1 and BVPS-2 TS 3.0.1 contains the phrase

...upon failure to meet the Limiting condition for Operation, the associated ACTION requirements shall be met." Furthermore, i the current BVPS-1 and BVPS-2 TS 3. 0.2 states: " Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and the associated ACTION requirements are not met within the specified time intervals."

,The addition of TS 3.0.6 and its associated Bases is functionally I consistent with NUREG-1431, provides clarification of the existing BVPS-1 and BVPS-2 LCO 3.0.1 and maintains compliance with the intent of LCO 3.0.1. Further, this change does not i affect the UFSAR accident analyses.

Therefore, this change has been determined to be safe and will l not reduce the safety of the plant.

E. NO SIGNIFICANT HAZARDS EVALUATION

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The no significant hazards considerations involved with the proposed amendment have been evaluated, focusing on the three j standards set forth in 10 CFR 50.92(c) as presented below:

The Commission may make a final determination, pursuant to the procedures in paragraph 50.91, that a proposed amendment 4 to an operating license for a facility licensed under )

paragraph 50.21(b) or paragraph 50.22 or for a testing 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 l consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety. I The following evaluation is provided for the no significant ;

hazards consideration standards, i i

1. Does the change involve a significant increase in the l l

probability or consequences of an accident previously evaluated? I l The proposed change does not affect the operation or design of the plant in,any way. Operation of plant equipment under B-4 I J

' ATTACHMENT B, continu3d License Amendment Request Nos. 255 and 124 Page 5 this change will not differ in any way from its normal operational mode. The normal operation of_ plant equipment is not a precursor to any accident. The - purpose of tests performed using this change is to demonstrate that required automatic actions are carried out. Equipment will be operated under administrative control for only a short period of time. If it should be required, personnel - will be immediately available to take appropriate manual action.-

Therefore, operation of equipment under.this change is not expected to increase the probability. or consequences of an accident previously evaluated.

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed testing allowance will not change the physical plant or the modes of plant operation defined in the operating license. The_ change does not involve the addition or modification of equipment nor does it alter the design or operation of plant systems. Therefore, operation of the facility in accordance with the proposed amendment will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does_the change involve a significant reduction in a margin of safety?

Equipment will be operat'a d under administrative control for only a short period of time. If it should be required, personnel will be immediately available to take appropriate manual action. The purpose of the testing is to restore required equipment to an OPERABLE state which increases the automatic protection available and reduces the reliance on the compensatory measures provided by ACTION statements.

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

F. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the considerations expressed above, it is concluded that the activities associated with this license amendment request L satisfy the requirements of 10 CFR 50.92(c) and, accordingly, a no significant hazards consideration finding is justified.

G. ENVIRONMENTAL CONSIDERATION The proposed amendment adds a new general applicability specification 3.0.6 and associated bases which provide specific i

guidance on the ability to operate a component under l administrative control if necessary to complete testing to i demonstrate OPERABILITY. As determined above in (F), No l Significant Hazards Consideration Determination, the proposed '

amendment does not. involve a significant hazards consideration. )

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F ATTACHMENT B, continusd License Amendment Request Nos. 255 and 124 Page 6 i It has been determined that the proposed amendment involves no significant increase in the amounts, and no significant change in the types of any effluents that may be released offsite. The proposed change does not result in any physical plant changes or new surveillances which would require additional personnel entry into radiation controlled areas. Therefore, there is no significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51. 22 (c) (9) . Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this proposed amendment.

H. UFSAR CHANGES No UFSAR changes are required.

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ML20216G101

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