Proposed Tech Specs,Allowing Changes to Tech Spec Re RHR Flow RequirementsML20244C533 |
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Catawba |
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04/06/1989 |
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DUKE POWER CO. |
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ML20244C528 |
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NUDOCS 8904200257 |
Download: ML20244C533 (6) |
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Category:TECHNICAL SPECIFICATIONS
MONTHYEARML20217F3481999-10-15015 October 1999 Marked-up & Reprinted TS Pages,Changing TS Requirements for Insp of RCP Flywheels ML20212E7851999-09-16016 September 1999 Proposed Tech Specs Pages,Modifying Surveillance Requirements 3.8.4.8,3.8.4.9 & 3.8.4.8 Bases to Allow Testing of DC Channel Batteries with Units on Line ML20210N3151999-08-0404 August 1999 Proposed Tech Specs Changing TSs 3.3.2, ESFAS Instrumentation, 3.3.3, Post Accident Monitoring Instrumentation, 3.4.14, RCS Loops - Test & 5.3, Unit Staff Qualifications ML20196H7551999-06-24024 June 1999 Proposed Tech Specs 2.0, Safety Limits, TS 3.3.1, Reactor Trip Sys Instrumentation & TS 3.4.1, RCS Pressure,Temp & Flow Departure from Nucleate Boiling (DNB) Limits ML20206M9391999-05-0606 May 1999 Proposed Tech Specs,Revising List of Referenced Documents in TS 5.6.5b Re COLR Requirements ML20205C6901999-03-25025 March 1999 Proposed TS Facilitating Treatment of RTS Instrumentation, ESFAS Instrumentation,Lop DG Start 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ML20237A9341998-08-0606 August 1998 Proposed Tech Specs,Deleting SR 4.8.1.1.2i.2 for Pressure Test of DG Fuel Oil Sys ML20237A0361998-08-0505 August 1998 Suppl 8 to Improved TS (Its),Combining Units ITS Pages to Facilitate Ease of Use & Significantly Reduce Vol of Paper That Must Be Processed & Controlled ML20236U1531998-07-22022 July 1998 Proposed Revised Improved Tech Specs,Implementing W Fuel as Described in TRs DPC-NE-2009P & DPC-NE-2009 ML20249B3961998-06-15015 June 1998 Proposed Tech Specs Affecting Requirements for low-temp Overpressure Protection ML20248B5741998-05-22022 May 1998 Proposed Tech Specs Modifying SR 4.4.3.3 for Pressurizer Heaters to Be Consistent W/Plant Design & W/Ts Requirement as Delineated in Improved Tech Specs ML20217E9831998-04-20020 April 1998 Proposed Improved Tech Specs Sections 1.0,2.0,3.0 & 4.0 ML20217E9521998-04-20020 April 1998 Proposed Tech Specs Revising Requirements for Automatic Actuation Logic & Actuation Relays Associated W/Cravs Operation Function,Which Is Part of ESFAS ML20216B9721998-04-0808 April 1998 Proposed Tech Specs 3/4.6.5 Re Ice Condenser Reduction of Required Ice Weight ML20217C7121998-03-20020 March 1998 Proposed Improved TS Section 3.6 Re Containment Sys ML20216B7691998-03-0909 March 1998 Proposed Tech Specs Pages Responding to 980116 RAI Re Improved TS Sections 3.1 & 3.2.Suppl Changes to Improved TS Also Included ML20217Q3741998-03-0303 March 1998 Proposed Tech Specs Re Catawba Safety Review Group ML20197G4391997-12-17017 December 1997 Proposed Tech Specs Referencing Updated or Recently Approved Methodologies Used to Calculate cycle-specific Limits Contained in COLR ML20203H9241997-12-11011 December 1997 Proposed Tech Specs Re ESFAS Instrumentation ML20210U6401997-09-15015 September 1997 Proposed Tech Specs Revising Pressure/Temp Limits, Overpressure Protection & Reactor Vessel Matl ML20140A6201997-05-27027 May 1997 Proposed Tech Specs Deleting References to Steam Generator Tube Sleeving & Repair That Will Not Be Used for Westinghouse Model D5 Steam Generators in Use at Catawba Unit 2 ML20140A6681997-05-27027 May 1997 Proposed Tech Specs,Removing Surveillance Requirement 4.7.13.3a.2 Which Specifies 112,320 Gallon Min Volume of Borated Water Be Available to Supply Standby Makeup Pump ML20141C2281997-05-0808 May 1997 Proposed Tech Specs Allowing Natural Circulation Testing in Mode 3 Following Steam Generator Replacement for Catawba Unit 1 ML20136G2471997-03-0707 March 1997 Proposed Tech Specs Re SGTR Evaluation ML20133E6801997-01-0303 January 1997 Proposed Tech Specs to Eliminate SI Signal on Low Steam Line Pressure.Unnecessary SI Actuation Causes Unnecessary Challenges to Plant Safety Sys,Unnecessary Thermal Transient & Increases Actuation Cycles ML20132F0631996-12-12012 December 1996 Proposed Tech Specs,Section 3/4.3.3.1,for Units 1 & 2 Clarifying Info Re Operation of Radiation Monitors for Plant Operations ML20134H3281996-11-0404 November 1996 Proposed Tech Specs to Licenses NPF-35 & NPF-52,eliminating During Shutdown Restriction for 18 Month Standby Shutdown Sys DG Insp TS Surveillance 4.7.13.1.c ML20113G4431996-09-21021 September 1996 Proposed Tech Specs 8.3 Re Onsite Power Systems ML20117K1011996-08-29029 August 1996 Proposed Tech Specs,Replacing 960516 Response to Concerns Re Proposed Changes for Diesel Starting Air Sys Surveillance Testing ML20116K4601996-08-0808 August 1996 Proposed Tech Specs 6.9.1.9 Re Listings of Core Operating Limit Methodologies ML20113C7201996-06-21021 June 1996 Proposed Tech Specs 3.9.6,revising Term Lifting Loads to Lifting Force Used in Manipulator Crane TS 3.9.6b.2 & Redefining Auxiliary Hoist Min Capacities ML20112G9961996-06-0606 June 1996 Proposed Tech Specs,Reflecting Separate Volumes ML20112F6311996-06-0505 June 1996 Proposed Tech Specs 3/4.6 Re Containment Systems & 3/4.6.1 Re Primary Containment Integrity ML20112A7571996-05-16016 May 1996 Proposed Tech Specs 3/4.8 Re Surveillance Requirements ML20101M4741996-04-0303 April 1996 Proposed TS 3/4.6.4.3 & Bases Re Hydrogen Mitigation Sys ML20101H6101996-03-15015 March 1996 Proposed Tech Specs Re Replacement of SGs ML20100P0521996-03-0404 March 1996 Proposed Tech Specs Re Rev to 10CFR50,App J Which Provided for Reduced Test Frequency for Qualified Containment ML20096E8611996-01-19019 January 1996 Proposed Tech Specs,Providing Approved Revs to TS 6.9.1.9 to Incorporate Anticipated Revs to TRs DPC-NE-3000P-A & DPC-3002-A ML20096E5951996-01-12012 January 1996 Proposed Tech Specs Re Containment Leak Rate Testing Requirements of 10CFR50 App J,Option B 1999-09-16
[Table view] Category:TECHNICAL SPECIFICATIONS & TEST REPORTS
MONTHYEARML20217F3481999-10-15015 October 1999 Marked-up & Reprinted TS Pages,Changing TS Requirements for Insp of RCP Flywheels ML20212E7851999-09-16016 September 1999 Proposed Tech Specs Pages,Modifying Surveillance Requirements 3.8.4.8,3.8.4.9 & 3.8.4.8 Bases to Allow Testing of DC Channel Batteries with Units on Line ML20211A9881999-08-18018 August 1999 Rev 5 to DPC Nuclear Security Training & Qualification Plan ML20210N3151999-08-0404 August 1999 Proposed Tech Specs Changing TSs 3.3.2, ESFAS Instrumentation, 3.3.3, Post Accident Monitoring Instrumentation, 3.4.14, RCS Loops - Test & 5.3, Unit Staff Qualifications ML20210N9641999-07-26026 July 1999 Revised Catawba Nuclear Station Selected Licensee Commitments Manual ML20211C3731999-07-26026 July 1999 Revs to Catawba Nuclear Station Selected Licensee Commitments Manual & List of Effective Pages ML20196H7551999-06-24024 June 1999 Proposed Tech Specs 2.0, Safety Limits, TS 3.3.1, Reactor Trip Sys Instrumentation & TS 3.4.1, RCS Pressure,Temp & Flow Departure from Nucleate Boiling (DNB) Limits ML20210A5911999-06-10010 June 1999 Revised Catawba Nuclear Station Selected Licensee Commitments Manual ML20216D4061999-06-10010 June 1999 Revised Catawba Nuclear Station Selected Licensee Commitment Manual, List of Effective Pages ML20211C3751999-05-19019 May 1999 5 to Catawba Nuclear Station Units 1 & 2 Pump & Valve Inservice Testing Program. Page 1 of 15 in Section 4.1 of Incoming Submittal Not Included ML20195B4181999-05-18018 May 1999 Revised Pages to Catawba Nuclear Station Selected Licensee Commitments Manual ML20206M9391999-05-0606 May 1999 Proposed Tech Specs,Revising List of Referenced Documents in TS 5.6.5b Re COLR Requirements ML20206T0571999-05-0505 May 1999 Revised Catawba Nuclear Station Selected Licensee Commitments Manual. with List of Effective Pages ML20206J4531999-04-22022 April 1999 Revs to Catawba Nuclear Station Selected Licensee Commitments Manual ML20206Q8741999-04-22022 April 1999 Revs to CNS Selected Licensee Commitments Manual,Including Page 5 of List of Effective Pages & Pages 1-11 to Chapter 16.9-13.With ML20206B1271999-04-15015 April 1999 CNS Selected Licensee Commitments Manual, List of Effective Pages ML20206C0391999-04-15015 April 1999 Revs to Catawba Nuclear Station Selected Licensee Commitments Manual ML20205C6901999-03-25025 March 1999 Proposed TS Facilitating Treatment of RTS Instrumentation, ESFAS Instrumentation,Lop DG Start Instrumentation,Cp & Exhaust Isolation Instrumentation & LTOP PORV TS Trip Setpoints as Nominal Values ML20204G2541999-03-16016 March 1999 Revised Pages to Catawba Nuclear Station Licensee Commitments Manual ML20204E5281999-03-15015 March 1999 Proposed Tech Specs Deleting TS for Cravs & Auxiliary Bldg Filtered Ventilation Exhaust Sys Actuation Instrumentation & Adding Note to TS for Cravs Re Chlorine Protection Function ML20204F6931999-03-11011 March 1999 Proposed Tech Specs 3.3.7 & 3.3.8 Re CR Area Ventilation Sys & Auxiliary Bldg Filtered Ventilation,Exhaust Sys Actuation Instrumentation ML20205B1341999-03-11011 March 1999 Revs to Catawba Nuclear Station Selected Licensee Commitments Manual ML20204E7271999-03-0808 March 1999 Chapter 16.5-2,page 1-3 to CNS Selected Licensee Commitments Manual. with List of Effective Pages ML20203A3331999-01-28028 January 1999 Proposed Tech Specs Modifying Flowrate Specified for SR 3.7.13.4 from Value Representative of One Filter Unit/Fan to Value Representative of Entire Fhves Train ML20199H4061999-01-16016 January 1999 Revised CNS Selected Licensee Commitments Manual ML20197G8991998-12-0707 December 1998 Proposed ITS 3.8.3,modifying Inventory Requirements for DG Lube Oil Sys ML20195D6481998-11-11011 November 1998 Proposed Tech Specs,Modifying Details of SRs 3.6.11.6 & 3.6.11.7 to Be Consistent with Design of Containment Pressure Control Sys at Plant ML20155B2111998-10-22022 October 1998 Proposed Revs to Improved Tech Specs,Implementing W Fuel as Described in TRs DPC-NE-2009 & DPC-NE-2009P ML20154L7191998-10-0505 October 1998 Rev 8 to DPC Nuclear Security & Contingency Plan, for Oconee,Mcguire & Catawba Nuclear Stations ML20151Y1821998-09-15015 September 1998 Proposed Improved TSs Providing Changes Necessary to Resolve Items Identified by Util During Review ML20151T9491998-09-0808 September 1998 Proposed Tech Specs & Bases Re Relocation from Current TS & Scheduling of New More Restrictive Surveillance Requirements ML20237B6241998-08-14014 August 1998 Proposed Tech Specs 4.6.5.1.b.2 & 4.6.5.1b.3 Relating to Ice Condenser Ice Bed Changing Portion of Surveillances Pertaining to Lower Inlet Plenum Support Structures & Turning Vanes from 9-month Frequency to 18-month Frequency ML20237B5751998-08-12012 August 1998 Proposed Tech Specs 4.6.5.1b.2 Re Ice Condenser Sys Components W/Respect to Accumulation of Frost or Ice ML20237A6571998-08-0606 August 1998 TS Page 3/4 8-9 Re Notice of Enforcement Discretion Request from Enforcing TS Surveillance Requirement 4.8.1.1.2i.2 ML20237A9341998-08-0606 August 1998 Proposed Tech Specs,Deleting SR 4.8.1.1.2i.2 for Pressure Test of DG Fuel Oil Sys ML20237A0361998-08-0505 August 1998 Suppl 8 to Improved TS (Its),Combining Units ITS Pages to Facilitate Ease of Use & Significantly Reduce Vol of Paper That Must Be Processed & Controlled ML20236U1531998-07-22022 July 1998 Proposed Revised Improved Tech Specs,Implementing W Fuel as Described in TRs DPC-NE-2009P & DPC-NE-2009 ML20236P8671998-07-0606 July 1998 Updated Pages to Catawba Nuclear Station Selected License Commitments Manual ML20249B3961998-06-15015 June 1998 Proposed Tech Specs Affecting Requirements for low-temp Overpressure Protection ML20249B6221998-06-11011 June 1998 Revised Table of Contents for Chapter 16 of Selected License Commitments Manual ML20248B5741998-05-22022 May 1998 Proposed Tech Specs Modifying SR 4.4.3.3 for Pressurizer Heaters to Be Consistent W/Plant Design & W/Ts Requirement as Delineated in Improved Tech Specs ML20247Q9871998-05-11011 May 1998 Revised Chapter 16 to Selected License Commitment Manual ML20217E9521998-04-20020 April 1998 Proposed Tech Specs Revising Requirements for Automatic Actuation Logic & Actuation Relays Associated W/Cravs Operation Function,Which Is Part of ESFAS ML20217E9831998-04-20020 April 1998 Proposed Improved Tech Specs Sections 1.0,2.0,3.0 & 4.0 ML20217F2841998-04-20020 April 1998 Rev 7 to DPC Nuclear Security & Contingency Plan, for Oconee,Mcguire & Catawba Nuclear Stations ML20216B9721998-04-0808 April 1998 Proposed Tech Specs 3/4.6.5 Re Ice Condenser Reduction of Required Ice Weight ML20217C7121998-03-20020 March 1998 Proposed Improved TS Section 3.6 Re Containment Sys ML20216B7691998-03-0909 March 1998 Proposed Tech Specs Pages Responding to 980116 RAI Re Improved TS Sections 3.1 & 3.2.Suppl Changes to Improved TS Also Included ML20217Q3741998-03-0303 March 1998 Proposed Tech Specs Re Catawba Safety Review Group ML20197G4391997-12-17017 December 1997 Proposed Tech Specs Referencing Updated or Recently Approved Methodologies Used to Calculate cycle-specific Limits Contained in COLR 1999-09-16
[Table view] |
Text
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l REFUELING OPERATIONS ,
3/4.9.8 RESIOUAL- HEAT REMOVAL AND COOLANT CIRCULATION i
HIGH WATER LEVEL LIMITING CONDITION FOR OPERATION 1
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3.9.8.1 At 1 east one residual heat removal loop sh'all be OPERABLE and in operation.*
APPLICABILITY: MODE 6, when the water level above the top of the reactor
, vessel flange.is greater than or equal to 23 feet.
ACTION:
With no residual heat removal loop OPERABLE and in operation, suspend all operations involving a,n increase in the reactor decay heat load or a reduction in boron concentration of the Reactor Coolant System and i.mmediately initiate corrective action to return the required residual heat removal loop to OPERABLE and operating status as soon as possible. Close all containment penetrations
- I .providing direct access from the containment atmosphere to the outside atmos-phe,re within 4 nours.
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SURVEILLANCE REQUIREMENTS 4.9.8.1 At least one residual heat removal loop shall be verified in operation~
and circulating reactor coolant et a 'lew rate of greater then er equel te 1 2000 ;pr at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
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- The residual heat removal loop'may be removed from operation for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8-hour period during the performance of CORE ALTERATIONS in the vicinity of the reactor vessel hot legs. .
CATAVBA - UNITS 1 & 2 3/4 9-10 o I. _ - _-- _ _
- .c REFUELING OPERATIONS
- LOW WATER LEVEL:
LIMITING CONDITION-FOR OPE 9ATION 3.9.8.2 Two independent residual heat removal lcops.shall be OPERABLE, and at least one residual heat removal ioop shall be in. operation.*
L APPLICABILITY: MODE 6, when the water level above the top of the reactor.
l vessel flange is less than 23 feet.-
' ACTION:
With.less than the required residual heat removal. loops' OPERABLE, a.
immediately initiate corrective action to return the required resi-dual heat removal. loops to OPERABLE status, or establish greater than or equal to 23, feet of water above the reactor vessel flange, as soon as possible,
- b. With no.re'sid'ual heat removal loop in operation, suspend all operations involving a. reduction in boron concentration of the Reactor Coolant System and immediately-initiate corrective action to return the required' residual heat removal loop to operation.
Close all, containment penetrations providing direct access from the containment atmosphere to the outside atmosphere within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
SURVEILLANCE' REQUIREMENTS.
4.9.8.2 At least one residual heat removal loop shall be verified in operation and circulating reactor coolant :t : f1:u r:t: f gr :ter thar er equel to l
2000 gpr at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
kriortoinitialcriticality,theresidualheatremovalloopmayberemoved from operation for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8-hour period during the performance of CORE ALTERATIONS in the vicinity of the reactor vessel hot legs.
' CATAWBA.- UNITS 1 &.2 3/4 9-11 u_ _ _ _ _ _ _ _ _ _.- ___--- _ __ __ !
l Attachment 2
( .- . Discussion, No Significant Hazards Analysis and Environmental Impact Statement.
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DISCUSSION, NO SIGNIFICANT HAZARDS ANALYSIS AND ENVIRONMENTAL IMPACT STATEMENT The proposed smendment would:
I Change the requirements for Residual Heat Removal to allow reduced flow during times when the Reactor Coolant System is partially drained.
The change would delete the specific requirement to maintain Residual Heat Removal flow at greater than or equal to 3000 gpm as required by specification surveillance 4.9.8.1 ant' 4.9.8.2.
Each unit at Catawba Nuclear Station has two independent Residual Heat Removal (ND) Systems. The normal function of the ND System is to remove heat energy fror, the core and Reactor Coolant (NC) System during cooldown and refueling operations. The ND System is also used to transfer refueling water between the Refueling Water Storage Tank and refueling cavity at the beginning and end of refueling operations. The ND System is also used as part of the Safety Injection System and Containment Spray System during an accident condition.
Detailed information concerning the ND System may be found in section 5.4.7 of the Catawba FSAR.
As stated in the bases of the Technical Specifications on page B 3/4 9-2, the ND System and the required flow rates for the ND System serve two purposes.
The flow rate ensures oufficient cooling capacity is available to remove decay heat and maintain the >ater in the reactor vessel below 140 F as required during refueling. The flow rate also ensures sufficient coolant circulation is maintained through the core to minimize the effect of a boron dilution incident and prevent boron stratification.
On October 17, 1988 the NRC issued Generic Letter (GL) 88-17 to licensees. On page 5 of the attachment to the GL, program enhancement (5) Technical Specifications, recommended that licensees identify and submit appropriate changes to Technical Specifications that restrict or limit the safety benefit of actions identified in GL 38-17. On pages 5 and 6 of Enclosure 1 to the GL in section 2.1.2, vortexing is discussed. Vortexing at the junction of the ND System suction line and the NC System will occur if water level is too low, a situation to be avoided since this may introduce air into the ND System pump suction. Vortexing can occur more easily when flow is high. As stated in section VII.E. of NUREG-1269 on page 32, reduced ND System flow rate would provide a greater margin against vortexing and preclude an inadvertent loss of decay heat removal capability due to air entrainment and cavitation of the ND System pumps. This amendment will allow lower flow rates and reduce our susceptibility to vortexing.
The proposed amendment will not change the bases for specifications 3.9.8.1 and 3.9.8.2. Operations procedures and guidelines will ensure, for the required core condition, ND flow is satisfactory to maintain NC System temputature below 140 F, the effect of a boron dilution incident is minimized and boron stratification is prevented. Depending on the status of the NC System (i.e.
whether the head is on or off, water level in NC system), the temperature of 1
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DISCUSSION, NO SIGNIFICANT HAZARDS ANALYSIS AND ENVIRONMENTAL IMPACT STATEMFET
.the system can be monitored using the incore thermocouple, the wide range RTDs or the temperature indication at the inlet and the discharge of the ND System heat exchangers. When the NC system is at its lowest level the temperature indication at the inlet and the discharge of the ND System heat exchangers is used. In other words, the required flow rate for the ND system will be dictated by the status of the core (e.g. refueling completed - low decay heat, recently shut down - high decay heat removal) and the level of water in the NC System. Allowing the flow rates to be reduced will aid in preventing vortexing and air entrainment into the ND and NC Systems. As long as a ND pump is running, even at minimum flow rates, there is enough mixing in the flow to ensure no boron stratification occurs in the NC System. The ND pumps are also needed to minimize the effect of boron dilution scenario. This is accomplished by mixing the flow to ensure uniform distribution of the boron in the NC System. Mitigation of a boron dilution scenario is performed by a boron injection flow path, a centrifugal charging pump and a borated water source.
Theae are required operable by specifications 3.1.2.1, 3.1.2.3 and and 3.1.9.5 during periods of reduced NC System inventory.
This amendment will also make the surveillance requirements for Technical Specifications 4.9.8.1 and 4.9.8.2 the same as the surveillance requirements for Technical Specifications 4.4.1.4.1.2 and 4.4.1.4.2. This would aid in eliminating operator confusion for the operating requirements of the ND System.
Vortexing is not a concern when the water level above the top of the reactor vessel flange is greater than or equal to 23 feet (reference specification 3/4 9.8.1). The surveillance requirement 4.9.8.1 is being modified to be consistent with surveillance requirements 4.9.8.2, 4.4.1.4.1.2 and 4.4.1.4.2.
10 CFR 50.92 states that a proposed amendment involves no s;gnificant hazards considerations if operation in accordance with the proposed amendment would not:
(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any i accident previously evaluated; or (3) Involve a significant reduction in a margin of safety.
This change, which would allow the flow requirements for the ND System to be reduced to prevent vortexing in the ND System, does not involve a significant increase in the probability or consequences of an accident previously ;
evaluated. The reduction in flow will not keep the ND System from fulfilling '
its safety functions. The ND System will continue to remove enough residual heat to maintain the NC System below 140 F, prevent boron dilution and prevent boron stratification. Two ND pumps (trains) will still be required operable when there is less than 23 feet of water above the reactor vessel flange. This will ensure that a single failure of the operating residual heat removal pump (train) will not result in a complete loss of ND System capability. This change will reduce the probability of an accident since it will reduce the chances of a loss of the ND System due to vortexing or air entrainment.
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DISCUSSION, NO SIGNIFICANT HAZARDS ANALYSIS AND ENVIRONMENTAL IMPACT STATEMENT The change to the flow requirements for the ND System will not create the possibility of a new or different kind of accident from any accident previously evaluated. The ND System will sf.ill be operated as before except at lower flow !
rates. The lower flow rates will still allow the ND System to fulfill its l safety functions. Therefore, no aew or different kind of accident from any accident previously evaluated will be created.
The proposed change to the flow requirements for the ND System will act involve l a significant reduction in a margin of safety. No functional change is being I made to the ND System. The lowering of the flow rate requirements will reduce the chances of rendering the ND System inoperable. This will increase the margin of safety.
Environmental Impact The proposed Technical Specification change has been reviewed against the criteria of 10 CFR 51.22 for the environmental considerations. As shown above, the proposed change does not involve a significant hazards consideration, nor increase the types and amounts of effluents that may be released offsite, nor increase individual or cumulative occupational radiation exposures. Based on this, the proposed Technical Specification change meets the criteria given in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statement.
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