ML20236K982

Safety Evaluation Supporting Amends 125 & 112 to Licenses DPR-58 & DPR-74,respectively

ML20236K982
Person / Time
Site:	Cook
Issue date:	05/31/1989
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20236K976	List: ML20236K973 ML20236K978 ML20236K982 ML20236K988
References
NUDOCS 9807100167
Download: ML20236K982 (10)

Text

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,f, A, UNITED STATES g g- NUCLEAR REGULATORY COMMISSION

r. WASHINGTON, D. C. 20555

• l h,*...+/ -

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.125TO FACILITY OPERATING LICENSE NO. DPR-58 -

AND AMENOMENT NO. II2TO FACILITY OPERATING LICENSE NO. OPR-74, INDIANA MICHIGAN POWER COMPANY DONALD C. COOK NUCLEAR PLANT, UNITS NOS. 1 AND 2 '

DOCKETS NOS. 50-315 AND 50-316 i 1.0" INTRODUCTION

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, I Letters from Iridiana Michigan Electric Company (the licensee) dated September 28, 1984 and April 24, 1985 for the D. C. Cook Nuclear Power Plant, Units 1 & 2 established {nitial groundwork addressing concerns regarding diesel generator reliability in Generic letter 84-15. In a letter dated January 16, 1987, the licensee submitted a Technical Specification change request attempting to more ,

closely reflect the Standard Technical Specifications ,(STS) enclosed in Generic Letter 84-15. Additional information and improved TS's are included in letters dated June 25, and September 28, 1987. A letter dated November 25, 1987 requests 1

TS changes to two specific portions of the original submittal concerning diesel gener,ator fuel oil surveillance testing and the ten year diesel generator fuel oil storage tank cleaning. Additional infomation on the ten year diesel generator fuel oil storage tank cleaning is contained in a letter dated January 24, 1989.

The portions of the TS submittal dated January 16, 1987 concerning simulated load testing of the station batteries and N-train batteries were resubmitted in a letter dated April 29, 1988 to ensure timely compliance with an INP0 commitment and to reduce outage time. The TS's for surveillance of the station batteries were issued as Amendment Nos. 123 and_110 to Facility Operating License Nos.

DPR-58 and DPR-74, respectively. A letter dated March 23, 1989 provides clarified and corrected TS pages for the 10 year tank cleaning and inspection portion. The licensee provides corrected TSs covering diesel generator surveillance testing in a letter dated April 6,1989. , ,. , , . . , _

For ease of evaluation and clarification of the proposed amendments, the _ _

following evaluation is split into three separate areas of consideration; (2.1)

Diesel Generator Fuel Oil Surveillance Requirements, (2.2) Diesel Generator Fuel 011 Storage Tank Surveillance Requirements, and (2.3) Diesel Generator Surveillance Testing.

l 2.0 EVALUATION I .

2.1 Diesel Generator Fuel Oil Surveillance Requirements n

P gnMOM 2 - . - - - - - - - - - --

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2.1.1 Introduction - -

By letter dated-June.25,-1987, the licensee proposed changes to section 3/4 8.1 of the TSs concerning surveillance requirements for the diesel generator fuel oil I system. Additional information is provided by letters dated September 28 and

• November 9, 1987. The TS change request dated June 25, 1987 was superseded by a {

TS chang.e request dated November 25, 1987. The staff notes that the preposed change's-deviate from the guidelines in the Standard Technical Specifications (STS) for. Westinghouse plants. In addition, the proposed TS changes provide for uniformity in the TSs for both Units 1 & 2. ' , '

2.1.2 Evaluation The primary deviation of the licensee's proposed'TS.from the STS is the deletion l of the requirements for testing of stored fuel oil particulate concentration in accordance with American Society for Testing Materials (ASTM) D2274-70 every 92 days. -In lieu of the above, the proposed TS requires testing of stored-fuel oil for particulate. concentrations every 31 days in accordance with ASTM D2276-83.

The proposed test more closely confirms the actual condition of the fuel oil

'that will be pumped to the diesel generators in terms of particulate matter which could +mpair diesel generator operation or result in diesel generator unavailability. The current STS surveillance requirements (ASTM D2274-70) are orientated to predicting the tendency of fuel oil to oxidize and form I particulate during long term storage rather than determining the particulate concentration that may already exist. The staff. finds that the more frequent testing for actual particulate in the stored fuel oil will'prcvide better indications of fuel conditions as well as. identifying the tendency for formation of particulate under site storage conditions. The preposed tests.would, therefore, be more conservative in establishing.the adequacy of stored fuel oil than'the present STS' guidelines.

' 1 Other proposed changes include (a) replacing the " water sediment" test by centrifuge on new fuel oil per ASTM D1796 with the " clear and bright" test per ASTM D4176-82, (b) use of optional methods of verifying fuel gravity by testing and comparing with the suppliers certification, (c) allowing sulfur analysis to be performed in accordance with ASTM D2262, and (d) extending the time limit for obtaining ASTM D975 test results on new fuel from 14 days to 31 days. During the course of reviewing the McGuire TS changes, the staff reviewed the " clear and b41ght" test (ASTM 4176-82) including a demonstration of the test. principles .. . . _ ,

at the Naval Fuel Laboratory, Norfolk,' Virginia. Based on the above review, the staff tinds the " clear and bright" test to be more sensitive in determining the - -

presence of water and sediment in fuel oil than the " water and sediment" test by centrifug3 (ASTM D1796).

The use of optional methods of verifying new fuel gravity prior to storing by testing and comparing with the supplier s certification is proposed by the

-licensee as a means of simplifying new fuel acceptance procedures. The justification for this change is.that any contamination of fuel oil during -

transportation would be indicated by changes in flash point, gravity, viscosity, or appearance. Incorrect flash point would be detected by testing as discussed further below. Any contamination which could. alter the fuel oil appearance

. would be detected by the " clear and bright" test discussed previously. With tests for flash point and appearance as additional indicators, a verification

7 of fuel oil gravity by testing and comparing to the supplier's certification ,

will provide the necessary assurance that the new fuel is within specification limits. The staff finds the verification of fuel oil gravity by optional methods to be satisfactory. ~

, Current ASTM D975 guidelines for testing new fuel oil sulfur' content indicate that the testing is to be performed in accordance with ASTM D129. ASTM D396,

" Specification for Fuel Oil," however, allows the use of ASTM D2262 tdst methods for sulfur determination in No. 2 grade fuel oil. The staff recognizes both of the above fuel oil specifications and believes that obtaining test results by ASTM D2262 will be equivalent to results obtained by use of ASTM D129.

Therefore, the staff finds the proposed alternate method of determining sulfur content.to be satisfactory, The current STS guidelines indicate that new fuel oil is to be tested for conformance to the limits of the respective fuel oil properties listed in Tabl,e 1 of ASTM D975, and the test results are to be available within 14 days -

following fuel oil delivery. Under the licensee's proposed surveillance'e program, the most important fuel oil properties, with regard to immediate diesel engine .

operability, (flash point, viscosity or gravity,. water, and sediment) are checkedforfSTMD975limitsimmediatelypriortoacceptingthenewfueloil.

The remaining fuel oil properties may affect diesel generator performance only on a long term basis. Thus, the staff finds that the licensee's proposal to extend the time for obtaining test results for the repaining fuel oil properties from 14 days to 31 days would not adversely affect diesel generator r operability.

The proposed changes to the TSs include de.leting the requi ements for testing of s,tored fuel oil in accordance with ASTM 0975 requirements on a 92 day basis.

The rationale for this deletion is that the main fuel oil properties which can affect diesel generator performance (flash point, cetane number, viscosity, 1 cloud point) and are included in ASTM D975 do not change during storage. If these properties are within specification when the fuel oil is placed in storage,

.they will remain within specification unless other non-specific petroleum products are added to the storage tanks. The addition of non-specification petroleum products is precluded by the licensee's proposed new fuel surveillance program as described above. Over prolonged periods stored fuel can oxidize and form particulate which, in significant enough concentrations, could impair diesel generator performance. In addition, bacteria growth can occur.

Particulate concentrations will be monitored every 31 days as discussed previously. Bacteria growth will be prevented by periodic removal of water froin * ~ ~ '

storage tanks. Because fuel oil properties will not change significantly in storage and fuel oil conditions which could affect diesel generator operation _ _

will be closely monitored.(on a 31 day basis), the staff finds that further testing of stored fuel in accordance' with ASTM D975 every 92 days will not provide measurable improvement in diesel generator reliability. Therefore, such testing can be deleted.

The licensee has also proposed two additions to the fuel oil surveillance TSs.

These include (a) testing new fuel for flash point before acceptance, and (b) ~~

testing for and draining water from the fuel oil storage tanks every 31 days.

The flash point test provides an additional indication that new fuel oil is within specification limits; thereby, reducing the possibility of adding " bad fuel" to the fuel oil already in storage. The requirement to drain accumulated L - _ _ _ _ _ - _ _ _ _ _ - _ _ _

l water from the storage tanks every 31 days will be of considerable value in , ,

t reducing the possibility of bacteria contamination of the stored fuel, minimizing the formation of corrosion products on the bottom of the storage tank, and

. preventing water from contaminating the fuel oil transfer system and the diesel r generator fuel system. Both of the above additions represent a more .  !

conservative approach to maintaining quality diesel fuel and diesel generator reliability than current staff guidelines.

2.1. 3 Conclusion l

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. Based on the above, the staff concludes that the surveillance requirements for j ensuring diesel oil adequacy, TS section 3/4 8.1, as proposed by the licensee are more conservative than the guidance in the Standard Technical Specifications.

This conservatism coupled with the simplified testing approach for fuel oil will provide immediate assurance of fuel oil quality on delivery and maintenance of

fuel oil quality during storage. This should increase diesel generator reliability. Therefore, the licensee's proposed TS changes for diesel fu'el' oil-surveillance ar,e acceptable.

- 2.2 Diesel Generator Fuel-Oil Storage Tank Surveillance Testina 2.' 2.1 Introduction -

In a letter dated September 28, 1987, the licensee revised tht. origin 91' diesel generator fuel oil surveillance test requirement to reflect more closely to similarly approved TSs. Groundwork for a proposed Diesel Generator Fuel 011-Storage Tank Surveillance Test was laid. Ioitially, problems such as development l . of procedures and clean tank criterion were identified. Subsequent ~ letters dated November 25, 1987 and January 24, 1989 provided some additional information. In a letter dated March 23, 1989, the licensee addressed all the remaining concerns of the NRC' staff.

2.2.2 Evaluation

Due-to the unique design of the licensee's diesel fuel system, periodic surveillance testing requiring draining of the storage tanks would force the

- licensee to shut down both Units 1 and 2. The licensee's letter dated March 23, 1089, propo nd an alternative method of ensuring adequate surveillance testing of the diesd ive oil storage tanks.

Section 4.8.1.1.2.f of the proposed TS requires that on a 10 year basis the l licensee perform the following steps. ~ ~

L Section 4.8.1.1.2.f.1 of the proposed TS requires that the licensee either (1) drain each storage tank, remove accumulated sediment, and clean the tank, or (2) agitate the fuel oil in the tank while pumping the oil from the bottom of

'the tank through a 5 micron filter. and back into the tank. Additionally, the tanks will be sampled three consecutive times and analyzed according to ASTM D2276-83. If any of the three samples contain more than 10mg/ liter of '

contaminate, the agitation, filtration, and sample process must be' repeated.

If after three consecutive attempts, the sample still fails the contaminate test, the-licensee must drain and clean the storage tank.

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Circulating the fuel oil through a 5 micron filter of at least five tank volumes . -

will provide sufficient cleaning of most normal oxidation and bacteria. If

. excessive oxidation or bacteria growth occurs, the proposed surveillance test will adequately provide for the surveillance of the diesel generator fuel oil storage tanks. By ensuring that the contamination levels in the storage tanks

• do not exceed 10mg/ liter, the licensee will improve diesel generator reliability from that which already exists. Thefailurecriterionrequiringthelicenseeto completely drain and clean the diesel fuel oil storage tanks will provide an adequate path to ensure reasonable reliability of the diesel fuel oil storage systa.

Section 4.8.1.1.2.f.2 of the proposed TS requires that the licensee perform a precision leak test to verify the integrity of the fuel system. The leakage rate is not to exceed .05 gallons per hour.

The precision leak test employs a fuel surface mounted level detector which .

operates on the principal of buoyancy changes. The detection system is.reporte*d to be able'to. detect changes of .05 gallons per hour under worst case conditions.

This approach of surveillance testing the diesel generator fuel oil storage tanks is more conservative than what currently exists in the plants.

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2.2.3 Conclusion ' ' j The staff believes that the licensee's proposal to perform surveillance testing of the diesel generator fuel oil storage system is more conser,vative than what currently exists in the D. C. Cook Units 1 & 2 TSs. Furthermore, the proposed surveillance method provides sufficient failure and clean tank criterion to provide an increase in diesel generator reliability and thus meets the intent of Generic letter 84-15. The proposed solution to ensure diesel generator fuel oil storage tank' cleanliness is, therefore, found to be acceptable. It should be noted, however, that the D. C. Cook diese.1 generator _ fuel oil storage tank surveillance testing program may be subject to further generic guidance.

2.3 Diesel Generator Surveillance Testing 2.3.1 Introduction By a letter dated January 16, 1987, the licensee addressed the diesel generator reliability issue and proposed Technical Sp~ edification changes to more closely resemble the Standard Technical Specifications contained in Generic l'etter 84-15 ' " ~ ~

In a subsequent letter dated November 25, 1987, the licensee provided more , _

l concise TS changes and answered several NRC originated questions regarding l previous submittals. The final submittal dated April 6, 1989, provides concise TS changes concerning increased diesel generator reliability. These TS changes l also provide uniformity between the D. C. Cook Nuclear Plant Units 1 and 2.

2.3.2 Evaluation

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Action statement 3.8.1.1.a This action statement for D. C. Cook Units 1 and 2 currently specifies required actions during the inoperability of one offsite circuit or diesel generator.

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In proposing' changes to this action statement the licensee has distinguished the loss of an offsite circuit from loss of a diesel generator in that the diesel generator power source will be addressed in a new action statement.

This is consistent with the current Standard Technical Specification fonnat and -

is acceptable for D.C. Cook Units 1 and 2.

The licensee has also proposed to perform the surveillance requirement %f 4.8.1.1.2.a.4 on'each diesel generator within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> instead of one hour and delete the requirement of perfonning 4.8.1.1.2.a.4 once every eight hours thereafter. The staff finds this change to be consistent with Generic Letter 84-15 and to be acceptable.

Action statement 3.8.1.1.b

.the Thisproposed new action statement change for D.

to action C. Cook3.8.1.1.a statement Units 1 and 2 is added to address lossas of aa result dieselof. '-

generator separate from loss of an offsite circuit. As stated in item 1 above, this' proposed shange to the TSs is acceptable. The licensee has also proposed to perform the surveillance requirements of 4.8.1.1.2.a.4 on the remaining diesel generator wij;hin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> instead of one hour if the diesel generator became ihoperable due to any cause other than preplanned preventive maintenance or testing and delete the requirement-of performing 4.8.1.1.2.a.4 once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. The staff finds this change to be gonsistent with Generic Letter 84-15 and to be acceptable.

• Additionally the licensee has proposed a 168 t hours out-of service action  !

stat 9 ment for diesel generator inoperability not to exceed an accumulated annual outage time of 576 hours0.00667 days <br />0.16 hours <br />9.523809e-4 weeks <br />2.19168e-4 months <br /> in lieu of current TSs requirement of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

The staff feels that, at present there are no adequate bases to grant D. C. Cook l Units 1 and 2 the requested 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> out-of-service period for diesel generators. i

. Also, the subject of optimum LCOs for safety-related systems is currently a generic study topic for the staff. Therefore, based on the above, we do not recommend this change to the TSs be granted at this time.

Action statement 3.8.1.1.c This action statement for D. C. Cook Units 1 and 2 currently reouires that when one diesel generator and an offsite power circuit are inoperable, the licensee should demonstrate the operability of the remaining diesel generator per - - -~

surveillance requirement of 4.8.1.1.2.a.4 within one hour and at least once per eight hours thereafter. The licensee has proposed to demonstrate the diesel - -

i generator operability requirement of 4.8.1.1.2.a.4 within eight hours if the I diesel generator became inoperable due to any cause other than preplanned .

-preventive maintenance and testing and to delete the requirement of. performing I 4.8.1.1.2.a.4 once every eight hours thereafter. The staff finds this change to be consistent with Generic Letter 84-15 and to be acceptable. '

Action statement 3.8.1.1.d -

This action statement for D. C. Cook Units 1 and 2 currently requires that when two offsite circuits are inoperable, the licensee should demonstrate the operability of two diesel generators per surveillance requirement of j

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p l 4.8.1.1.2.a.4 within one hour and at least eight hours thereafter. The licensee

• has proposed to demonstrate the operability of two diesel generators per the surveillance requirement of 4.8.1.1.2.a.4 within eight hours (unless the diesel

generators are already operating) instead of within one hour and to delete the -

requirement of performing 4.8.1.1.2.a.4 once every eight hours thereafter. We find this change consistent with Generic Letter 84-15 and to be acceptable.

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Action Statement 3.8.1.1.e This action statement for D. C. Cook Units 1 and 2 is currently not part of -

the TSs. The licensee has proposed to demonstrate the operability of the two remaining A.C. circuits by perfonning 4.8.1.1.1.a within one hour if both diesel generators become inoperable and restore at least one diesel generator to operable status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be'in 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 />.

We find this change consistent with Generic Letter 84-15 and acceptable. .

The remaining TSs changes to section 3.8.1.1 are administrative in nature providing clarity and consistency between both D. C. Cook Unit I and Unit 2 TSs.

T5 Section 4.8,1.1.2.a.4 This.section for D. C. Cook Units 1 and 2 currently requires diesel generator surveillance to be performed from ambient conditions and for the diesel' generator to start and accelerate to at least 514 rpm in less: than or equal to 10 sec. The proposed change will require starting each diesel generator at least once per 184 days from ambient conditions and accelerating to 514 rpm in r

less than or equal to 10 sec. We find this' change consistent with Generic Lett6r 84-15 to improve and mainta.in diesel generator reliability by reducing .{

the. number of col.d fast starts of diesel generators and to be acceptable.

,, TS Section 4.8.1.1.2.e.2 l

-This section for Unit I currently requires the generator capability to reject a 4 load greater than or equal to 600kW without tripping. The licensee has proposed more conservative requirements including specific voltage and frequency limits'  ;

that should be met during this test to be consistent with Unit 2 specifications. i This surveillance requirement was accepted by the staff on Unit 2 and is also acceptable for Unit 1.

TS Section 4.8.1.1.2.e.3 ,

This new specification with respect to the full load rejection test has been added for Unit I specification to be consistent with Unit 2 specifications.

The staff finds the proposed change to be acceptable.

TS Section 4.8.1.1.2.e.4.b This section currently requires that the diesel generator starts on the auto- -

start signal within 10 seconds, energizes the auto-connected shutdown loads through the loed sequencer and operates for greater than or equal to 5 minutes.

The licensee has proposed to add. reference to voltage and frequency requirements (for Units 1 and 2) that should be met during this test. The staff finds this change to be more conservative and to be acceptable.

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j TSs'Section 4.8.1.1.2.e.5,6,9 and 10 * '

These specification sections with respect to diesel generator testing have been added for Unit 1 to provide standardization between Unit I and 2 specifications.

The staff finds these additions to be acceptable. In addition to the above. the .

licensee has proposed to add reference to voltage and frequency requirements in

survel) lance requirements of 4.8.1.1.2.e.6.b for Units 1 and 2. The., staff finds this change to be conservative and to be acceptable.

TSs Section ,4.8.1.1.2.e.7 and 8 .

These sections for Unit 2 currently require that the diesel generator operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During'the first two hours of this test, the diesel generator shall be loaded to 3850kW (2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rating) and during the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this test, the diesel generator shall be-loaded to 3500kW (the continuous rating). The licensee has proposed to perfors'24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> testing at 3500kW and delete 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> testing at 3850kW. The licensee has stated that D. C.. Cook diesel ,

generators'are. rated at 3500kW and do not have 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> ratings. The manufacturer of the diesel generators will not support diesel generator operation at 3850kW.

Moreover, the licensee has demonstrated that the worst case loading of'D. C. .

' Cook diesel se'nerators is below the continuous rating of-3500kW. Based on the j above, the staff concludes that testing of diesel generators at 3500kW for 24 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> during these surveillance tests is acceptable. In addition, the licensee I has proposed to add Section 4.8.1.1.2.e.7 and revised'Section ,4.8.1.1.2.e.8 of

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L Unit 1 TSs to be consistent with Unit 2 TSs. The staff finds these changes to be acceptable. '

As part of this request, the licensee has also proposed to delete surveillance

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• requirements of .4.8.1.1.2.c.2 and 4.8.1.1.2.d for Unit 2 and 4.8.1.1.2.b.6 for Unit 1. The surveillance requirements of 4.8.1.1.2.c.2 and 4.8.1.1.2.b.6 are regarding verification of automatic sequence timing relays to assure they are {

/ l within 15% of its required value and surveillance requirements of 4.8.1.1.2.d is '

regarding 10 year testing. Based on the information provided by the licensee, the staff concludes that there are no adequate basis to delete these surveillance requirements from Unit 1 and Unit 2 TSs. Therefore, this proposed change to the  ;

TSs is' denied.

Table 4.8.1 & Attachment 1 and 2 This Table and attachments address reporting and requalification requirements for diesel generators. The. licensee has proposed to include this table and - -

attachments for D. C. Cook Units 1 and 2 TSs. This Table and attachments were part of the performance' specification included in the Generic Letter 84-15.

The' licensees were requested to provide comments on the performance specification  !

. for staff consideration in finalizing surveillance testing requirements for f diesel generators. Subsequently, the NRC staff determined that the actions required by the Table and the Attachment 2 were not necessary and the reporting requirements addressed in Attachment I were adequately met by current reporting -

requirements. Therefore, the STS were revised to incorporate the requirements of  ;

Generic Letter 84-15 and this table and attachments were not included in this-revision of the STS. These proposed changes to D. C.. Cook Units 1 and 2 TSs are not required and are therefore denied.

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9-Table 4.8.2 This table addresses diesel generator surveillance testing frequency. The present requirement bases the diesel generator test frequency on the number of .

failures in the last 100 tests (for Unit 2 only). The licensee has proposed to base the testing frequency in the last 20 tests. The licensee has alsq. included this ' table in Unit 1 TSs to be consistent with Unit 2 TSs. The staff' finds the proposed revised Table 4.8.2 to be consistent with Generic Letter 84-15 and to be acceptable.

In addition to the above proposed TSs changes, the licensee has requested a number of administrative changes to D. C. Cook Units 1 and 2 TSs. These changes are as follows:

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A footnote was added on page 3/4 8-2 for Units 1 and 2 to indicate, that as part  !

of the equipment is restored, the plant should return to an early Action

• statement. This transfer statement also clarifies the starting time.* '

TS 3.8.2.1 of Unit I was changed to be identical to TS 3.8.2.1 currently approved for, Unit 2. Also, in TS 4.8.2.1 of Unit 1, the phrase "other than the diesel generators" was deleted. In Unit 2 TS 4.8.2.1 the phrase "and energized from A.C. sources" was added for clarity.

A footnote was added on pages 3/4 8-9 and 8-10 of Units 1 and'2 to clarify that the 120-volt A.C. Vital buses are energized from their. associated inverter which is connected to a D.C. bus.

• TS 3.'8.2.2 for Unit I was changed to be identical to TS 3.8.2.2 for Unit 2.

Also, in Unit 1, the phrase "other than the diesel generator" was deleted. t The words "and energized" were added to TS 4.8.2.2 for Unit 2 for clarity.

.. l The qualifier "No" was deleted before the letter "N" on page 3/4 8-16 for Units 1 and 2. This qualifier serves no purpose.

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The word "value" is now written each time rather than being indicated by ditto '

marks on page 3/4 8-12 for Units 1 and 2.

Throughout Section 3/4-8 for Units 1 and 2, and the word

• greater. (or less) than or equa. l to" hyphens were were used added the to replace where appropriate, mathematical symbols. In addition, the page numbers and table numbers for TS _ _

Section 3/4-8 for both were revised for both units due to the addition of a number of new pages to accommodate the proposed changes. .

The staff finds the above administrative changes to be acceptable.

3.0 ENVIRONMENTAL CONSIDERATION

This amendment involves a change in the installation and use of a facility component located within the restricted area as defined in 10 CFR part 20 and a change to the surveillance requirements. The staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational t

• 1 radiation exposure. The commission has previously issued a proposed finding that these amendments involve no significant hazards consideration and there has been no public comment on such finding. Accordingly, these amendments meet 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 of environmental assessment need be prepared in connection with the issuance of this amendment. -

4.0 CONCLUSION

We have concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, (3) and the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

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l Date: May 31,1989

. i Pricipal Contributors: Anthony T. Gody Jr., NRR/DRSP Om P. Chopra NRR/SELB ,

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