View source for NRC-92-0075, Application for Amend to License NPF-43,changing RCS Unidentified Leakage Rate of Change Limit Applicable in Operational Condition 1,per NRC Position on Leak Detection in GL 88-01

{{Adams
| number = ML20106D391
| issue date = 09/30/1992
| title = Application for Amend to License NPF-43,changing RCS Unidentified Leakage Rate of Change Limit Applicable in Operational Condition 1,per NRC Position on Leak Detection in GL 88-01
| author name = Orser W
| author affiliation = DETROIT EDISON CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000341
| license number = 
| contact person = 
| case reference number = CON-NRC-92-0075, CON-NRC-92-75
| document report number = GL-88-01, GL-88-1, NUDOCS 9210090234
| package number = ML20106D392
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 13
| project = 
| stage = Request
}}

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September 30, 1992 NRC-92-0075 U. S. Nuclear ReguL ory Commission Atto: Docu.aent Cont rol Desk Washington, D. C. 20555                                                                                               --

==References:==
: 1)   Fe nni 2 NRC Docke t No. 50-341 NRC Licence No. NPF-43
: 2) Generic Letter 88-01 "NRC Position on IGSCC in BWR Austonitic Stainless Steel Piping", dated January 25, 1988
: 3) Generic Letter 88-01, Supplement 1, "NRC Position on                                                 ;",
Intergranular Stress Corrosior Cracking (IGSCC) in BWR Austenitic Stainless Stee. Piping", dated February 4,1992
: 4)   Detroit Edison Letter to NRC, " Response to NRC Generic Let ter 88-01", NRC-88-0191, dated August 5, 1988
: 5)   De t roit Edison Letter to NRC, " Revised Response to                                                 -
NRC Generic Lett er 88-01", NRC-89-0088, dated April 27, 1989
: 6)   Detroit Edison Letter to NRC, " Submit
* al of NRC Requested Additional Information on Ge-eric Letter                                                     j 88-01", NRC-89-0106, dated May 12, 1989
: 7) Nhc Letter to Detroit Edison, "NRC Position on IGSCC on BWR Austenitic Stainless Steel piping Generic Letter (GL) 88-01 (TAC No. 69135)", dated January 4                                                    ,
1990
: 8)   Detroit Edison Letter to NRC, " Fermi _2 Response to Generic Letter 88-01, Supplement 1, 'NRC Position on Intergranular Stress Corrosion Cracking (IGSCC) in EWR Austenitic Stainless Steel Piping'",
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USNRC September 30, 1992 l             NRC-92-0075
!             Page 2

==Subject:==
Proposed Technical Specification Change (License Amendment) - Reactor Coolant System Operational Leakage Technical Speci ficetion 3/4.4.3.2 (Implementation of Generic Letter 88-01 and 88-01, Supplement 1 Guidance)
Pursuant to 10CFR50.90, Detroit Edison Company (DECO) hereby proposes to amend Operating License NPF-43 for the Fermi 2 plant by incorporating the enclosed changes into the Plant Technical Specifications (TS). In Reference 8, the DECO response to Generic                            -
Letter GL 88-01, Supplecant 1. DECO commit ted to submit ting a TS amendment that incorporates the Generic Letter GL 88-01 (Reference 2)
NRC Staf f position on leak detecthn which concerns the reactor coolant system unidentified Icakage rate of change limit.
The proposed amendment: (1) changes the reactor coolant system (RCS) unidentified leakage rate of change limit applicable in Operational Condition 1; (2) retains the current RCS unidentified leakage rate of change limit applicable in Operational Conditions 2 and 3; (3) changes the surveillance interval for monitoring RCS unidentified and identified leakage in Operational Condition 1; and (4) incorporates the bases for the above changes in TS Bases. The details of these
* changes are described in Enclosure 1 of this submit tal.
The proposed change in the RCS unidentified leakage rate of change limit applicable in Operational Condition 1 is in accordance with the NRC Staf f position on leak detection in Generic Letter GL 88-01 (Reference 2). Retention of the current RCS unidentified leakage rate of change limit applicable in Operational Conditions 2 and 3 provides a limit that takes into account the expected increase in RCS unidentified leakage experienced during normal, routine reactor s t art u p s. The proposed change in the RCS unidentified leakage surveillance interval in Op7 rational Condition 1 is equivalent to the NRC Staf f acceptable alternate position on the f requency of RCS leakage measurements in Generic Letter GL 88-01, Supplement 1 (Reference 3). The proposed change in the RCS identified leakage surveillance interval in Operational Condition 1 makes it consistent with the proposed RCS unidantified leakage surveillance interval for Operational Condition 1. The preposed change to the TS Bases identifies GL 88-01 and GL 88-01, Supplement 1 as the basis documents for the changes to the RCS unidentified. leakage rate of change limit and th<t RCS unidentified leakage surveillance interval applicable in Operscional Condition 1.
DECr has evaluated the proposed Technical Specifications against the cri eria of 10CFR50.92 and determined that no significant hazards con side ration is involved. The Fermi 2 Onsite Review Organization has approved and the Nuclear Safety Review Group has reviewed the proposed Technical Specifications and concurs with the enclosed

USlh September 30, 1992 NRC-92-0075 i                                   Page 3 de t e rmina tions. In accordance with 10CFR50.91, Detroit Edison has provided a copy of this letter to the State of Michigan.
DECO requests that this amendment be ef f ective 60 days af ter NRC issuance to allow suf ficient time to implerent these changes.
If you have any questions, please contac t Mr. David H. Brown at (313) 586-4213.
Sin ce rel y.
                                                                                          /

==Enclosures:==
Enclosure 1 - Evaluation of Proposed Change Enclosure 2 - Propoced Technical Specifications Mark-up Enclosure 3 - Technical Specification Change Pages cc:  T. Colburn A. B. Davis M. P. Phillipo S. Stasek Supe rvisor, Elect ric Operators. Michigan Public Service Commiccion - J. R. Pad ge t t 1

    ^
USNRC Sept embe r 30. 1992 NRC-92-0,075 .
Page 4 I, WILLI AM S. ORSER, do hereby af firm that the f oregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.
WILLI AM S. ORSER Senior Vice President
!              On this ' lY1            day of M O b MA / d ..21992, before me personally appeared William S. 0rsdr, being first duly sworn and
                                               ~
sayc that he executed the foregoing as his f ree act and deed.
Y    A LC-    -
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FNCIDSURE _1 EVAL.UATION             e OF PitOIM EI6 CllA M E i
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Enclosure to NRC-92-0075 Page 1 INTRODUCTION On January 25, 1988, the NRC issued Generic Letter GL 88-01, "NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping" (Reference 2). This generic letter presented the NRC staff positions on a variety of subjects associated with intergranular stress corrosion cracking (IGSCC) near weldsents in BWR piping. DECO reviewed the staff positions and documented its response in References 4, 5, and 6. On January 4, 1990, the NRC issued a safety evaluation (Reference 7) on the DECO response to GL 88-01. 11s safety evaluation states that the DECO response to GL 88-01 is complete with the exception of the DECO position concerning the technical specification (TS) limiting condition for operation (LCO) 3/4.4 3 2.e leakage limit.
The current LCO 3/4.4.3 2.e states that reactor coolant system (RCS) leakage shall be limited to a 2 gpm increase in unidentified leakage within any 4 hour period. GL 88-01 states that the RCS leakage shall be limited to a 2 gpm increase in unidentified icskage within any period of 24 hours or less.
On February 4, 1992, the NRC issued Supplement 1 to CL 88-01. This supplement provided alternative positions to those delineated in GL 88-01. One such position concerns the RCS leakage monitoring frequency. GL 88-01 requires that containmr nt sump levels be monitored everv 4 hours. GL 88-01, Supplement 1, relares this renuirement by allowing the containment . taps to be monitored once per shift not to exceed 12 hours.
The current surveillance TS 4.4.3 2.1.b and 4.4.3 2.1.c require the primary containment sump flowrate and the drywell floor drain sump level, respectively, to be monitored at least once every 4 hours.
On July 29, 1992, DECO committed tt submitting a TS amendment that incorporates the GL 88-01 NRC Staff position on RCS unidentified leakage limits, The purpose of this proposed TS amendment is to revise TS 3/4.4.3 2 to incorporate the NRC Staff position on leakage limits in GL 88-01, applicable in Operational Condition 1 only; revise the applicability of the current unidentified leakage rate of change limit to Operational Conditions 2 and 3; incorporate the RCS leakage monitoring frequency consistent with the NRC Staff position in GL 88-01, Supplement 1, applicable in Operational Condition 1 only; and revise the applicability of the current RCS monitoring frequency to Operational Jonditions 2 and 3 PROPOSED TFCHNICAL SPFCIFICATION CIIANGES The proposed TS mark-up is contained in Enclosure 2 and Enclosure 3 contains the TS change pages. The specific changes are discussed below.

Enclosure to NRC-92-0075 Page 2
: 1. LCO 3.4.3.2.e The proposed LCO 3.4 3 2.c changes the unidentified leakago rate of charge limit from a 2 gpm increase in RCS unidentified leakage within any 4 hour period to a 2 gpm increase in reactor coolant leakage within any 24 hour period. It also limits the applicability of the proposed limih to Operational Condition 1. This change brings the unidentified leakage rate of change limit into egreement with the NRC Staff position-on leakage limits in GL 88-01.                                                           ,
j
: 2. LCO 3.4.3 2.f                                                                   !
The proposed LCO 3 4 3 2.f retains the current RCS unidentified leakage rate of change limit (2 gpm increase within eny 4 hour period) but makes it applicable in Operational Coaditions 2 and 3 only. This change prevents the unnecessary entry into the unidentified leakage rate of change action statement due to the changes in RCS unidentified leakage experienced during     ,
routine startups.
3   TS 3.4.3.2, Action Statement e The proposed TS 3.4.3.2 Action Statement e also changes the unidentified Icakage rate of change limit from a 2 gpm increase in RCS unidentified leakage within any 4 hour period to a 2 gpm increase in RCS unidentified leakage within any 24 hour period. This change makes Action Statement e consistent with the proposed change in LCO 3 4 3 2.e.
: 4. TS 3.4.3.2 Action Statement f The proposed TS 3 4 3 2 Action Stateme. f retains the current RCS unidentified leakage rate of change limit (2 gpm increase within any 4 hour period) but makes it. applicable in Operational Conditions 2 and 3 only.
This change makes Action Statement f consistent with the proposed LCO 3.4.3 2.f.
: 5. Surveillance Requirement 4.4.3.2.1.c The proposed Surveillance Requirement 4.4 3.2.1.c changes the drywell floor drain sump level monitoring frequency in Operational Condition 1 from at least once per 4 hours to at least once per 12 hours. The current 4 hour drywell floor drain sump level monitoring frequency is retained in Operational-Conditions 2 and 3      A note is also added to ensure that the 25% surveillance interval extension provision in TS 4.0.2 is not applicable to the surveillance requirement in Operational Condition 1. The change to the drywell floor drain' sump-level monitoring frequency for Operational Condition 1 is equivalent to the NRC staff position on RCS leakage monitoring intervals discussed ir. GL 88-01, Supplement 1.

Enclosure to NRC-92-0075 Pe,re 3
: 6.             S rveillance Hoquirement 4.4.3.2.1.b 1he proposed Surveillance Requirement 4.4 3 2.1.b changes the primary containment sump flowrate monitoring frequency in Operaticnal Condition 1 from at least once per 4 hours to at least once per 12 hours. The current 4 hour primary containment sump flowrate monitoring frequency is retained in Operational Conditions 2 and 3                                                                   A note is also added to ensure that the 25% surveillance interval extension provision in TS 4.0.2 is not applicable to the surveillance requirement in O L erational Condition 1. This change makes the Surveillance Requirement 4.4 3 2.1.b monitcring frequency consister>t with the frequency proposed in Surveillance Requirement                                                                              __
4.4.3 2.1.c.
7               Bases 3/4.4.3 2 The proposed Bases 3/4.4 3 2 includes a statement that the proposed unidentified leakage rate of increase limit and surveillance interval for Operational Condition 1 meet the guidance of GL 88-01 and GL 88-01, Supplement 1.                             1his change provides the basis for the unidentifled Icakage rate of change limit proposed in LCO 3 4 3 2.e, LCO 3 4 3 2.f, and the proposed surveillance interval in Surveillance Requirement 4.4 3 2.1.c.
DISCUSSION RCS operationa) leaksge TS 3/4.4 3 2 ensures that the integrity ol'the reactor coolant pressure bcunaary is maintained in Operational Conditions 1, 2, and 3 by pro.2 ding limits for pressure boundary leakage, total leakage, unJdentified leakage, and pressure isolation valve leekage. RCS leakage is detern.ned to be within the TS limits by:                                                                                                                                        -
: 1. Monitoring primary gaseous radioactivlty;
: 2. Monitoring the primary containment sump flowrate for identified leakage and the drywell floor drain sump level for unidentified leakage; 3   Monitoring the reactor sessel head flange leak detection system;
: 4. Leak testing pressure isolation valves; and
: 5. Verifying the high/ low pressure interface valve leakage monitor alarm setpoints.
The propose: TS changes deal with: (1) the RCS unidentified leakage rate of change lin' and (2) the surveillance intervals for 1onitoring the primary containment . ump flowrate and drywell floor drain sump level. The purpose of LCo 3.4.3 2.e, TS 3 4 3 2 Action Statement e, and Surveillance Requirement 4.4 3 2.1.c is to provide the unidentified leakage rate of change limit and s.trveillance interval need( J to maintain the integrity of the RCS and, in e-- _    _ _ _ _                     . - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _                                                  _             . .     ..

s Enclosure to NRC-92-0075 Page 4 particular, type 304 and 316 austenitic stainless steel piping that is subject to high stress or that contains relatively stagnant, intermittent, or low flow Cluids. GL 88-01 and GL 86-01, Supplement 1, provide both the NRC Staff rasitions on leakage limits and the suF/elllance intervals to fulfill this purpose.
The proposed change to LCO 3 4 3 2.e brings the unidentified leakage rate of change limit into agreement with the subject NRC position as defined in GL 88-01. The proposed luakage rate of change limit is one-sixth of the existing TS limit. Therefore, the proposed limit enhances the ability to identify and take action to correct a RCS leak in austenitic stainless steel piping because the proposed limit is sensiti9e to a much smaller rate of change la unidentified leakage. Therefore, action will be taken to identify the leak source and take corrective measures eariter than the current TS require.
ine applicability of the proposed change to LCO 3 4 3 2.e is limited to Operational Condition 1. This is necessary 'o ensure that the expected increase in unidentified leakage associated >th reactor vessel heatup and pressurization during routine startups does not cause an unnecessary shutdown due to temporarily exceeding the 2 gpm increase in unidentified leakage over 24 hours limit. The unidentified leakage associated with a routine startup attains a steady state value and is net indicative of weld or pipe failures due Lo IGSCC. Leak'ge due to IGSCC induced wold or pipe cracks would continue to increase as the plant operates in Operational Condition 1 and, therefore6 would t'e limited by the proposed LCO 3.4 3 2.e.
l l      The proposed I ;0 3 4.?.2.f maintains the curr ent utidentified Icakage rate of change limit and ensures that the RCS is monitored for 1GSCC related failures-throughout startup.
The proposed change to TS 3.4.3 2 Action Statement e makes it consistent with the proposed change to LCO 3.4 3 2.e.
The proposed TS 3.4.3 2 Action Statement f maintains tie same requirements contained in the current Fermi 2 TS 3.4 3 2 Action Statement e except that it limits applicability to Operational Conditions 2 and 3.        This change is consistent with the proposed LCO 3 4.3 2.f described aboca.
The proposed change to Surveil)ance Requirement 4.4 3 2.1.c for Operational Condition 1 is in agreement with the NRC position on RCS leakage monitoring intervals deceribed in GL 88-01, Supplement 1. In GL 88-01, Supplement 1, the NRC concluded that a 4 nour monitoring interval (the current interval in Formi 2 TS) would create an unnecessary hardship for plant operators. The NRC has determined that the once per shift, not to exceed 12 hours monitoring interval is an acceptable alternative that facilitates the implementation of GL 88-01.
The proposed 12 hour surveillance interval meets both the once per shift and the.12 hour maximum . surveillance. interval requirements of GL 88-01, Supplement 1, because the shift surveillance interval defined in Fermi 2 TS Table 1-1,
       " Surveillance Frequency Notation", is at least once per 12 hours. Therefore, the proposed surveillance interval is equivalent to the GL 88-01, Supplement 1 m       -   , ,,._w---,-.--y +-a ~         +-

                                  .           .~           .
Enc'losure to NRC-92-0075 Page 5 interval. The addition of the note, "The provisions of Specificat,lon 4.0.2 are
.                                                not, applicable to the. surveillance requirement in Operational Condit.lon 1", to Surveillance Requirement 4.4 3.2.1.c ensures that the 25% maximum allowable extension is not applied to the surveillance interval.
Retaining the 4 hour surycillance interval in Surveillance Requirement 4.4 3 2.1.c for Operational Conditions 2 at.d 3 ensures that the RCS unidentified Icokag9 rate of change is measured at a frequency compatible with                                                       ,
the 2 gpm increa e over 4 hour limit in the proposed LCO 3.4 3 2.f and TS                                                            '
3.4 3 2 Action Statement f.
The proposed change to Surveillance Requirement 4.4 3 2.1.b makes its monitoring frequency consistent with the frequency proposed in Surveillance Hequirement 4.4 3 2.1.c as discussed above. There is no individual RCS identified leakage limits in TS. Identified leakage is used, along with unidentified Icakage, to demonstrate that the total leakage is within the 25 gpu total leakage limit of LCO 3.4.3 2.c. More frequent monitoring in Operational Condition 1 is unnecessary because quantifying identified leakage by itself will not demonstrate that RCS operational leakage is within the limits of LCO 3 4.3 2.
The proposed change to TS Bases 3/4.4 3 2 ident11 a; ct 88-01 and at 88-01, Supplement 1, as the documents that provide the oa.ses for the unidentified leakage rate of change limit and the surveillance interval proposed for Operat.ional Condition 1.
The proposed amendment does not, change t.he remaining TS 3.4.3 2 limiting conditions for operation (or their respective action statements) that concern no RCS pressure boundary leakage, the 5 gpm unidentified leakage limit, the 25 gpm tot,a1 leakage limit, or t.he RCS pressure isolation valve limit,.
Based on the abcVe discussion, DECO finds the proposed TS changes acceptable.
h0 SIGNICANT llAZARDS CONSIDERATION In accordance with 10CFR50 92 DECO has made a determination that, the proposed l                                                amendment involves no significant haze ds considerations. To make this l                                                determination, DECO must establish that operation in accordance with the i                                                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 vf accident from any socident previopsiv evaluated, or (3) involve a significaat rtduction in a margin of safety.
l The proposed TS changes deal with: (1) the RCS unidentified leakage rate of
!                                                change limit and (k) t.he aurveillance int.orvals for. monitoring t,he primary l                                                contairment sumo flowrate and drywell floor drain sump level. The purpose of I                                                LCO 3 4 3.2.e,                  3.4.3 2 Action Statement e, and Surveillance Requirement-l 4.4 3 2.1.c is to provide the unidentifie t leakage rate of change limit er.
1

Enclo:uro to NRC-92-0075 Page 6 sur veillance interval needed to maint. tin the integrity of RCS type 304 and 316 austenitic stainless steel piping that is subject to high stress or that contains relatively stagnant, intermittent, or low flow fluids. GL 88-01 and GL 88-01, Supplement 1, provide both the NRC Staff position on leakage limits and the surveillance intervals to fulfill this purpcso.
5his amendment:
: 1) Does not involve a significant increase in the probability or consequences of an accident previously evaluated. This amendment does not alter the design, function, or operation of the RCS or the RCS leakage detection system. The proposed changes for the HCS unidentified Icakage rate of change limit and the drywell floor drain sump level monitoring interval proposed for Operational Condition 1 are based on the NRC staff positions in GL 88-01 and GL 88-01, Supplement 1.       Limiting the applicability of the GL 88-01 based RCS unidentified leakage rate of change limit to Operational Condition i ensures that the reactor is not unnecessarily shut down if the increase in unidentified leakage experienced during routine plant startups temporarily exceeds the 2 gpm over 24 hour limit. The proposed RCS unidentified Icakage rate of change limit, for Operational Conditions C and 3 naintains the current limit and ensures that, the RCS is monitored for ICSCC related failures throughout the reactor startup. The proposed TS ensures that, when the unit-is in Operational Condition 1, action is tskan to identify and correct RCS leaks in austenitic st,ainless steel piping earlier because the proposed limit is one-sixth of the current limits.       In GL 88-01, Supplement 1, the LRC found that a 4 hour monitoring interval (the current interval in Fermi 2 TS) creates an unnecessary hardship for plant operators. The NRC has determined that, the once per shift, not to exceed 12 hours monitoring interval is an acceptable alternative that facilitates the implementation of GL 88 01 leak detection requirements.
The proposed 12 hour surveillance interval for Operational Condition 1          ,
meets t,ath the once per shift and the 12 hour estimum surveillance interval requirements of GL 88-01, Supplement 1, because it is in accordance with the shift surveillance interval dsfinition in Fermi 2 TS. The proposed changes also ensure that the 12 hour surveillance interval for Operational l                                  Condition 1 cannot be extended by incorporating the requirement, that TS j                                  4.0.2 is not applicable. The current 4 hour surveillance interval in Operational Conditions 2 and 3 is retained and is more conservative t.han i
the requirements of GL 88-01, supplement 1. The proposed change to the l                                  primary containment sump flow rate monitoring interval in Operational Condition 1 does not change the total leakage limit in TS 3/4.4 3 2 and is consistent with the proposed drywell floor drain sump level moultoring interval. The current primary containment sump flowrate monitoring interval in Operational Conditicns 2 and 3 is not changed. The proposed
,                                  changes t,o the TS Bases reference GL 88-01 and GL 88-01, Supplement 1 as l                                  'he basis documents. for the RCS unidentified leakage. rate of- change limit, and unidentified leakage monitoring interval in Operat.lonal Coneition 1 and, therefore, reflect the proposed LCO and Surveillance Requirements discussed aboves

Enclosure to MRC-92-0075                           '
Page 7
: 2) Does not create the possibility of a new or different, kind of accident, from any accident previously evaluated. The proposed amendment, does not, alter the configuration of the faellity, plant, oprations, or the acoident, analysis assumptions. The proposed amendment does not change the methods by which RCS unidentified leakage is measured. In Operat,lonal Condition 1, act,lon to identify and correct RCS leakage in aust.cnitic st.ainicas piping is taken for a smaller rate of change in RCS unidentified leakage. In Operational Condit,lons 2 and 3, the current Feral 2 TS unidentified leakage rate of change limit is maint,ained. As stated above, t,he NRC has det.crained tnat t,he once per shift., not to exceed 12 hours monitoring interval for unidei.tified RCS leakage is an acceptable alternative that facillt,ates the implementat,lon of GL 88-01. As stated above, t,he proposed 12 hour surveillance int.orval for Operational Coadition 1 la equivalent, to
,              the NRC Staff posit,lon in GL 88-01, Supplement, 1. The current 4 hour surveillance interval in Operational Conditions 2 and 3 is ret.ained and remains more conservative than the GL 88 01, supplement I requirements.
The proposed primary cont,ainment sump flow rate monitoring interval for Operat!onal Condit,lon 1 does not, change the limit for t.otal leakage in TS 3/4.4 3 2 and is consistent with the proposed drywell floor drain sump level monitoring interval. The current I hour aurveillance interval for Operational Conditions 2 and 3 is not changed. The proposed changes t,o the TS Beses reference GL 88-01 and GL 88-01, Supplement 1, as t.he basis docut Ants and therefore reflect the LCO and Surveillance Requirements proposed in this amendment, request.
: 3) Does not, involve a significant reduction in t,he margin of safety. For j              Operational Conditicia 1, the proposed amendment, incorporat,es the more stringent, RCS unidentified leake.go rate of change limit required by G' 88-01 . This limit is one-sixth of the current TS limit, and is, therefore, more conservative. For Operat,lonal Conditions 2 and 3, t,he proposed change maint,ains the current Fermi 2 TS unidentified leakage rate of change limit.. 'the proposed amendment also incorporates a drywell floor drain sump level monitoring surveillance int.erval for Operational Condition 1 that is equivalent to t.he int.orval found acceptable by the NRC in GL 88-01, Supplement, 1. The current, 4 hour surveillance interval in Operat,lonal Conditions 2 and 3 is retained and is more conservative than the requirements of GL 88-01, supplement,1. The proposed change to the primary containment, sump flow rate monit,oring interval in Operat.lond. Condit,lon 1 does not change tho' limit for total Icakage in TS 3/4.4.3.2 and is consistent with the propo*.i drywell floor drain sump' level monitoring int,orval . The current, primary conta!nment sump flowrate monitoring interval for Operational Conditions 2 and 3 is not changed. The proposed changes to the TS Bases reference GL 88-01 and GL 88-01, Supplement,1 as -
the basis documents for the RCS anidentified Icakage rate of change limit and unident,1fied leakage monitoring interval in Operational Condition 1 and, therefore, reficct the proposed LC0 and Surveillance Requirements discussed above.
Based on the above, DECO has determined that, the proposed emendment, does not involve a significant, hazards consideration.
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* Enclosure to NR('-92-0075 Page 8 2NVIHONKDITAL IMPACT DECO has reviewed the proposed TS changes against the criteria of 10CFRbl.22 for environmental considerations. The proposed changes do not . involve a significant hazards consideration, nor significantly chango the types or significantly increaso the amounts of effluents that may be released offsite, nor significantly increase the individual or cumulative occupational radiation orposures. Based on the foregoing, DECO concluder that the proposed TS do meet         ,
the criteria given in 10 CFR51.22(c)(9) for a categorical' exclusion from the requirements for an Environmental Impact Statement.
CONCI.USION Based on the evaluation above: 1) thero is reasonable assurance that 'he health and safety of the public will not be endangered by operation in the proposeJ manner, and 2) such activities will be conducted in compliance with the Commission's regulations and proposed amendments will not be inimical to the common defense and security or to the health and safety of the public.
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