ML20207B941

Application for Amend to License NPF-3,revising Tech Spec Tables 3.3-7, Seismic Monitoring Instrumentation & 4.3-4, Seismic Monitoring Instrumentation Surveillance Reguirements. Fee Paid

ML20207B941
Person / Time
Site:	Davis Besse
Issue date:	07/21/1988
From:	Shelton D TOLEDO EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20207B945	List: ML20207B941 ML20207B948
References
1539, TAC-67393, NUDOCS 8808040351
Download: ML20207B941 (16)

Text

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l TOLEDO 3

% EDISON L

n' I DONALD C SHELTON

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• 2" 2" Docket No. 50-346 License No. NPF-3 Serial No. 1539 July 21, 1988 l

l United Ststes Nuclear Regulatory Commission Document Control Desk

{ Vashington, D. C. 20555 Subj ec t : License Amendment Application to Revise Seismic Monitoring Instrument Locations and Frequency Range Gentleman:

The enclosed application requests that the Davis-Besse Nuclear ?over Station (DBNPS), Unit No. 1 Technical Specifications be revised to reflect the changes attached. The proposed a.hanges involve Technical Specification 3.3.3.3 Table 3.3-7, "Seismic Monitoring Instrumentation", and Table 4.3-4, "Seismic Monitoring Instrumentation Surveillance Requirements."

The proposed changes vould: 1) reflect the actual and appropriate configuration of the station site strong motion triaxial accelerometer and the u.ield bui?. ding peak recording accelcrometer and 2) revise the measurement (frequency) range of the station site strong motien triaxial accelerometer seismic trigger. The changes ate consistent with Regulatory Guide 1.12, Rev. 1, "Instrumentation for Earthquakes" and ANSI /ANS-2.2-1978, "Earthquake Instrun,entation Criteria for Nuclear Power Plants" while maintaining DBMPS vithin its design basis for seismic event detection and monitoring.

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Toledo Edison reauests that these changes be issued in an amendment to the

- DBNPS Technical Specifications by December 1, 1998. While these changes are not needed to correct a safety problem or support continued plr.nt operation, they e.r2 needed to ensure the Technical Specificacions reflect actual plant L configuration and to remove unnecessary restrictions regarding replacement equipment.

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pn THE TOLEDO EDSON CCMPANY EDISOP. PLAZA 300 MAD! SON AVENUE TOLEDO. OH!O 43652 2

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Docket No. 50-346 License No. NPF-3 Serial No. 1539 Page 2 Enclosed is a check for $150.00 as required by 10CFR170.12(c) for a License Amendment Application.

Very tru yours, M

RMC/ sag' cc: DB-1 NRC Resident Inspector A. B. Davis, Regional Administrator (2 copies)

A. V. DeAgazio, NRC/NRR Davis-Besse Projec.c Manager State of Ohio e

.;, ; Doedot No.,50-346

. Lic nss N6. NPF-3

.Strici No. 1539 Enclosure Page 1 APPLICATION FOR AMENDMENT TO FACILITY OPERATING LICENSE NO. NPF-3

, FOR DAVIS-BESSE NUCLEAR POVER STATION UNIT NO. 1 Attached are requested changes to the Itavis-Besse Nuclear Power Station, Unit No. 1 Facility Operating License No. NEF-3. Also includad are the Safety Evaluation and Significant Hazards Consideration.

The proposed changes (submitted under cover letter Serial No. 1539) concern:

Technical Specification Section 3/3.3.3, Seismic Instrumentation , Tables 3.3-7 and 4.3-4.

By D.C. Shelton, Vice Presidsnt Nuclear Svorn and subscribed before me this 21st day of July,1988.

Il[ O[ c Ak /

' Notary Public, State of Ohio LAURIE A.HINKLE Notary Pubic.Stak of Ohio My Ommission Expires May 15.1991

, , Dockot Na. 50-346 Liesnsa No. NPF-3 Strial No. 1539 Enclosure Page 2 The following information is provided to support issuance of the requested changes to the Davis-Besse Nuclear l'over Station, Unit No.1 Operating License No. NPF-3, Appendix A Technical Specifications Section 3/4.3.3.3 Tables 3.3-7 and 4.3-4.

A. Time required to Implement: This change vill be implemented within 45 days of the issuance of the requested amendment.

B. Reason for Change Revise the Technical Specifications to:

1) reflect the actual'and appropriate configuration of the station site strong motion triaxial accelerometer and ths shield building peak recording accelerometer and 2) revise the measurement (frequency) range of the station site strong motion triaxial accelerometer seismic trigger to remove' unnecessary t..strictions on selection and procurement of replacement equipment.

C. Safety Evaluation: See attached Safety Evaluation (Attachment 1)

D. Significant Hazards Consideration: See attached Significant Hazards Consideration (Attachment 2)

E. Technical Specification Change Pages (Attachment 3) f

0, Doc'kat No. 50-346 Licinso No. NPF-3 Ssrial No. 1539 Attachment 1 Page 1 SAFETY EVALUATION DESCRIPTION OF PROPOSED ACTIVITY Th,e purpose of this safety evaluation is to review proposed changes, Seismic Monitoring Instrumentation revisions, to the Davis-Besse Nuclear Power Station (DBNPS), Unit No. 1 Operating License, Appendix A, Technical Specifications to ensure that no unreviewed safety question exists. These changes affect Technical Specification Table 3.3-7, Seismic Monitoring Instrumentation, Instruments and Sensor Locations, Items 1.d, 2.a, and 3.a; and Measurement Range, Item 3.a; and Table 4.3-4, Seismic Monitoring Instrumentation Surveillance Requireronts, Instruments and Sensor Locations, Items 1.d, 2.a, and 3.a. This safety evaluation is being performed to meet the requirements of 10CFR50.59.

The proposed changes involve revising the cited location of the seismic trigger (Item 3.a) and its associated strong motion triaxial accelerometer (Item 1.d) from "300 feet from containment vessel," ss Table 3.3-7 and Table 4.3-4 presently state, to a "minimum of 300 feet from containment vessel within the site boundary" to reflect the actual location of the equipment and to provide flexibility in future instrumentation relocation as necessary. The cited location of the peak recording accelerometer at the sbield building top (Item 2.a of the two tables) should be changed from its preser.tly stated "Elev.

809" to "minimum Elev. 812 ft" to reflect its actual and proper location and to msintain its location at a minimum for correlation with the upper mass-point as

.shown in Updated Safety Analysis Report Figure 3.7-4, Seismic System Analysis Mathematical Model of Shield Building. The measurement (frequency) range for the seismic trigger (Item 3.a of Table 3.3-7) should be revised from "0.053 -

20Hz" to "I-10 Hz" to be consistent with Regulatory Guide 1.12, Rev. 1, "Instru-mentation for Earthquakes," and ANSI /ANS-2.2-1978, "Earthquake Instrumentation Criteria for Nuclear Power Plants." In addition the single asterisk (*) note for the seismic trigger measurement range should be revised to read "Minimum Frequency Response Range". A range "0.005g to 0.02g***" should also be added below the seismic trigger range with a triple asterisk (***) clarifier adder' to the page which states "actuation range." These changes are consistent vi d the l recommendations of Regulatory Guide 1.12, Rev. 1 and ANSI /ANS 2.2 - 1978.

Implementing the changes related to cited locations vill reflect the actual and j appropriate configuration of the instrumentation. Revising the measurement l

(frequency) range and including an actuation range for the seismic trigger vill l remove unnecessary restrictions regarding replacement equipment while still maintaining the station within its design basis for seis nic event detection and monitoring.

SYSTEMS AFFECTED The proposed change affects the Seismic Moni oring System.

Dockat No.,50-346 i Licinsa No. NPF-3 l S3rici No. 1539 Attachment 1 Page 2

. DOCUMENTS AFFECTED SP 1105.17, Seismic Monitoring System AP 3009.31, Station Seismic Instrument on HS-EP-02820, Earthquake Updated Safety Analysis Report, Revision 5, Section 3.7.4.2 Technical Specification 3.3.3.3, Tables 3.3-7 and 4.3-4 SAFETY FUNCTION OF SYSTEMS AFFECTED The Seismic Monitoring System detects and records, on magnetic tape, the vibrations in the earth at DBNPS due to a local earthquake or other seismically violent events. In addition, the system vill record the vibrations of station structures as a result of an earthquake. The data acquired vill contribute to the assessment of damage to determine if structures and equipment important to safety have exceeded their design loading.

l The triaxial accelerometers are used to monitor and record strong seismic motion in the three mutually orthogonal directions. Two triaxial accelerometer transducers are located in containment at or near the containment center of gravity and another is rigidly mounted to the basement floor of the Auxiliary Building.

An external free-field seismic trigger and t xial accelerometer are located remote from structures in surroundings fre am normal vehicular traffic and where reflective waves from station founda, .ns vill not be picked up. The seismic trigger provides a signal to start the time history accelerograph and recording for a time period of 10 seconds beyond the last vibration above the triggering threshold. The recording equiptent is capable of recording continuously for 30 minutes.

The peak accelerometers are instruments requiring no power source and are used to permanently record peak accelerations. These recordings are used to verify the dynamic analysis of seismic Class I structures, systems, and components by comparison with the recorded acceleration time history after a seismic event.

reak accelerometers are located at the top of the Shield Building, the roof of the Auxiliary Building and the vall of the Control. Room.

EFFECTS ON SAFETY The criteria for which the DBNPS seismic monitoring instrumentation was selected is based upon the Maximum Probable Earthquake and the Maximum Possible Earthquake with maximum ground accelerstions of 0.08g and 0.13g, respectively, and, per Technical Specification Bases Section 3/4.3.3.3, "...is consistent with the recommendations of Regulatory Guide 1.12 "Instrumentation for Earthquakes",

April 1974."

The DBNPS Technical Specification Table 3.3-7, Item 3.a, "Heasurement Range",

specifies the frequency range for the Seismic Trigger as 0.053-20 Hertz (Hz).

This frequency range is consistent with the manufacturer's published range for j the equipment as was originally installed at DBNPS. However, this frequency l range is specific to the particular manufacturer's model and is overly l

, .. Doc'kst N3. 50-346 Licinsa No. NPP-3 Smrial No. 1539 Attachment 1 Page 3 restrictive as to the acceptable replacement equipment which can be installed at DBNPS. In order to remove this unnecessary restriction, a revision to the frequency range (to cite a minimum frequency range) and inclusion of an actuation range is proposed based on the Regulatory Guide 1.12, Rev. 1 (April 1974) reference to ANSI N18.5, "Earthquake Instrumentation Criteria for Nuclear Pover Plants," as being acceptable to the NRC Staff for satisfying the seismic instrumentation requirements of the Regulatory Guide. The cited ANSI Standard was revised and reissued as ANSI /ANS-2.2.-1978, and was cited as acceptable by the NRC in the Proposed Revision 2 to Regulatory Guide 1.12 dated July 1981. The revised ANSI /ANS Standard provides, la Section 5.4, for the Seismic Trigger frequency range to be 1 Hz to 10 Hz and an actuating level of 0.005g to 0.02g.

The DBNPS Updated Safety Analysis Report (USAR) Figure 2C.3-6, "Recommended Response Spectra for Horizontal Vibratory Ground Motions of Maximum Probable Earthquake (Smaller Earthquake) (0.08g) for Several Damping Ratios," provides the most conservative response spectra for system actuation. As stated in USAR tetion 3.7.1.2," ... frequencies smaller than 0.5 cps [Hz] are insignificant in the design of structures and equipment." In addition, between 0.5 cps and 1.0 cps, anticipated maximum accelerations will not be produced at these lov frequencies to cause exceedance of the bounding response spectra presented in Figure 2C.3-6 (attached). Further, it can be seen from Figure 2C.3-6 that the frequency range and actuation range cited by ANSI /ANS-2.2-1978 provide sufficient margin prior to reaching design values for actuating the recording instrumentation to monitor anticipated earthquake accelerations since the structures and systems are designed to withstand seismic events well above the trigger setpoint. Therefore, the proposed change to cite a minimum frequer.cy range of 1 Hz to 10 Hz and the addition of an actuation range of 0.005g to 0.02g for the seismic trigger vill have no effect on safety.

The location of the seismic trigger and strong motion triaxial accelerometer (free-field accelerometer) should be such that its function is unaffected by surrounding structures. The cited location in Technical Specification Tables 3.3-7 and 4.3-4 of 300 feet is intended as a minimum to maintain sufficient distance from station structures to preclude influence from these structures' reflective waves. At the preposed range of a minimum of 300 feet from the containment structure within the site boundary, the seismic trigger and strong motion triaxial accelerometer vill perform their intended function and vill allow relocation, if necessary, based on future construction at the site.

Therefore, the proposed location range change for the seismic trigger and triaxial accelerometer has no effect on safety.

The revised location of the peak accelerometer at the top of the Shield Building vill reflect the accelerometer's actual installed location and specify the minimum elevation where the accelerometer may be located to correspond its data with the highest mass point originally used in the Shield Building structural analysis (refer to USAR Figure 3.7-4). Therefore, there is no effect on safety.

' , . Doc'kst No.,50-346 Licinsa No. NPF-3 S2 riel Wo. 1539 Attachment 1 Page 4 Unreviewed Safety Question Evaluation Seismic Trigger: Frequency Range and Trigger Actuation Range The proposed action vill not increase the probability of occurrence of an accident previously evaluated in the USAR because the seismic trigger is an actuation device for seismic event data recording for post event evaluation and has no effect on initiation of an accident or seismic event. The proposed ranges will still ensure the information collected is proper and meaningful for determining the effect of a seismic event on structures and components important to safety (10CFR50.59(a)(2)(i)).

The proposed action vill not increase the consequences of an accident previously evaluated in the USAR because the seismic trigger serves no mitigation function during an accident or seismic event. The seismic trigger provides for actuation of recording equipment at a seismic acceleration range to permit collection of meaningful seismic information for post event evaluation (10CFR50.59(a)(2)(i)).

The proposed action vill not increase the probability of occurrence of a malfunction of equipment important to safety previously evaluated in the USAR because the frequency range change and inclusion of a specified actuation range does not introduce a failure mechanism. The ranges are in accordance with accepted standards and still allow collection of meaningful seismic information for post event evaluation (10CFR50.59(a)(2)(1)).

The proposed action vill not increase the consequences of a malfunction of equipment important to safety previously evaluated in the USAR because the seismic trigger provides for actuation of recording equipment to collect seismic information for post event evaluation. The proposed ranges vill still allow the seismic trigger to perform its function as intended to ensure meaningful and useful data is collected (10CFR50.59(a)(2)(i)).

The proposed action vill not create a possibility for an accident of a different type than any previously evaluated in the USAR. The seismic trigger is an actuation device for seismic event data recording for post event evaluation and has no effect on the initiation of any accident or seismic event. The proposed ranges vill still ensure the data collected and used in the evaluation of a seismic event's effect on structures and components important to safety is meaningful (10CFR50.59(a)(2)(li)).

The proposed action vill not create the possibility for a malfunction of equipment of a different type than any evaluated previously in the USAR because the frequency range change and inclusion of a specified actuation range does not introduce a failure mechanism. The ranges vill still ensure actuation of the seismic instrumentation at a level which vill yield meaningful data for post event evaluation (10CFR50.59(a)(2)(ii)).

The proposed action vill not reduce the margin of safety as defined in the basis to .uy Technical Specification. The proposed minimum frequency range and actuation range remain consistent with the recommendations of Regulatory Guide I 1.12 as stated in the existing Basis 3/4.3.3.3. (10CFR50.59(a)(2)(iii)).

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,. DockotLNo.; 50-346 )

' Lic0'nca No. NPF-3 l S$ rial No. 1539 Attachment 1 Page 5 i

Seismic Trigger, Peak Recording Accelerometer: Revised Locations The proposed action vill not increase the probability of occurrence of an accident previously evaluated in the USAR because the seismic instrumentation has no effect on the' initiation of an accident. The revised. locations provide further assurance that the instrumentation vill perform as intended and will still collect data meaningful in post seismic event evaluation (10CFR50.59(a)(2)(1)).

The proposed action vill not increase the consequences of an accident previously evaluated in the USAR because the seismic instrumentation only provides seismic event data for later evaluation (10CFR50.59(a)(2)(1)).

The proposed action vill not increase the probability of occurrence of a malfunction of equipment; important to safety previously evaluated in the USAR.

The location range for the seismic trigger.and its associated strong motion triaxial accelerator will further ensure the instrumentation vill perform as intended in a free-field manner and, thereby, vill maintain its safety function.

The revised location for the peak recording accelerometer provides the actual location of the accelerometer and limits its. location such that it vill correspond to the highest mass point utilized in.the structural design of the Shield Building. The seismic instrumentation provides no function in mitigating any accident, but rather, provides data collection for post seismic event evaluation of the event's effects (10CFR50.59(a)(2)(1)).

The proposed action vill not increase the consequences of a malfunction of equipment important to safety previously evaluateo in the USAR because the seismic instrumentation serves no direct accident or seismic event mitigation function. The seismic instrumentation provides for data collection for post seismic event design evaluation. The proposed locations vill still ensure the function of the instrumentation to collect meaningful data for that evaluation (10CFR50.59(a)(2)(i)).

The proposed action vill not create a possibility for an accident of a different type than any previously evaluated in the USAR. The seismic instrumentation provides no accident initiation mechanism, but rather, provides for seismic data collection for post event evaluation. The proposed locations vill still ensure

.the function of the instrumentation to collect meaningful data for post seismic event evaluation (10CFR50.59(a)(2)(ii)).

i The proposed action vill not create the possibility for a malfunction of equipment of a different type than any evaluated previously in the USAR. The revision to the cited locations does not introduce a failure mechanism to the seismic instrumentation or any other systems. Adequate redundancy and reliability exist to ensure a proper evaluation of a seismic event can be performed for determination of the effects of the event. The proposed locations L vill still ensure the instrumentation affected by this change vill function to collect meaningful data for post seismic event evaluation. The revised locations are proper and acceptable for instrumentation operation (10CFR50.59(a)(2)(11)).

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1. , , Dockat No. 50-346-Licinsa No. NPF-3 Ssriel No. 1539 Attachment 1 Page 6 The proposed action vill not reduce.the margin of safety as defined in the basis to any Technical Specification. The proposed revisions to instrument location remain consistent with the recommendations Regulatory Guide 1.12 as stated in the' existing Basis 3/4.3.3.3 (10CFR50.59(a)(2)(iii)).

Conclusion:

Based on the above, the proposed frequency and actuation ranges for the seismic trigger, and the proposed locations for the seismic trigger (with its associated strong motion triaxial accelerometer) and the peak recording accelerometer do not create any unreviewed safety question.

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FOR SEVERAL DAMPING RATIOS WMAI 68-192 FIGURE 2C.3-6 REVISION O JULY 1982

', t Dock 2t No. 50-346 i Licinsa No. NPF-3 l S: rial No. 1539 Attachment 2 Page 1 SIGNIFICANT HAZARDS CONSIDERATION PURPOSE The purpose of this Significant Hazards Consideration is to review proposed changes, Seismic Monitoring Instrumentation revisions, to the Davis-Besse Nuclear Power Station (DBNPS), Unit No. 1 Operating License, Appendix A, Technical Specifications. These changes affect Technical Specification Table 3.3-7, Seismic Monitoring Instrumentation, Instruments and Sensor Locations, Items 1.d, 2.a, and 3.a; and Measurement Range, Item 3.a; and Table 4.3-4, Seismic Monitoring Instrumentation Surveillance Requirements, Instruments and Sensor Locations, Items 1.d, 2.a, and 3.a.

The proposed changes involve revising the cited location of the seismic trigger (Item 3.a) and its associated strong motion triaxial accelerometer (Item 1.d) from "300 feet from containment vessel," as Table 3.3-7 and Table 4.3-4 presently state, to a "minimum of 300 feet from containment vessel within the site boundary" to reflect the actual location of the equipment and to provide flexibility in future instrumentation relocation as necessary. The cited location of the peak recording accelerometer at the shield building top (Item 2.a of the two tables) should be changed from its presently stated "Elev.

809" to "minimum Elev. 812 ft" to reflect its actual and proper location and to maintain its location at a minimum for correlation with the upper mass point as shown in Updated Safety Analysis Report Figure 3.7-4, Seismic System Analysis Mathematical Model of Shield Building. The measurement (frequency) range for the seismic trigger (Item 3.a of Table 3.3-7) should be revised from "0.053 -

20Hz" to "1-10 Hz" to be consistent with Regulatory Guide 1.12, Rev. 1, "Instru-mentation for Earthquakes," and ANSI /ANS-2.2-1978, "Earthquake Instrumentation Criteria for Nuclear Power Plants." In addition the single asterisk (*) note for the seismic trigger measurement range should be revised to read "Minimum Frequency Response Range". A range "0.005g to 0.02g***" should also be added below the seismic trigger range with a triple asterisk (***) clarifier added to the page which states "actuation range." These changes are consistent with the recommendations of Regulatory Guide 1.12, Rev. 1 and ANSI /ANS 2.2 - 1978.

Implementing the changes related to cited locations vill reflect the actual and appropriate configuration of the instrumentation. Revising the measurement (frequency) range and including at: actuation range for the seismic trigger vill remove unnecessary restrictions regarding replacement equipment while still maintaining the station within its design basis for seisnic event detection and monitoring.

SYSTEMS AFFECTED The proposed change affects the Seismic Monitoring System.

., 't Dockst No. 50-346 Licinsa No. NPF-3 Strial No. 1539 Attachment 2 Page 2 DOCUMENTS AFFECTED SP 1105.17, seismic Monitoring System AP 3009.31, Station Seismic Instrument On HS-EP-02820, Earthquake Updated Safety Analysis Report, Revision 5, Section 3.7.4.2 Technical Specification 3.3.3.3, Tables 3.3-7 and 4.3-4 SAFETY FUNCTION OF SYSTEMS AFFECTED The Seismic Monitoring System detects and records, on magnetic tape, the vibraa 9 in the earth at DBNPS due to a local earthquake or other seicmically violei. events. In addition, the system vill record the vibrations of station structures as a result of an earthquake. The data acquired vill contribute to the assessment of ocsage to determine if structures and equipment important to safety have exceeded their design loading.

The triaxial accelerometers are used to monitor and record strong seismic motion in the three mutually orthogonal directi ons. Two triaxial accelerometer transducers are located in containment at or near the containment center of gravity and another is rigidly mounted to the basement floor of the Auxiliary Building.

An external free-field seismic trigger and triaxial accelerometer are located remote from structures in surroundings free from normal vehicular traffic and where reflective waves from station foundations vill not be picked up. The seismic trigger provides a signal to start the time history accelerograph and recording for a time period of 10 seconds beyond the last vibration above the triggering threshold. The recording equipment is capable of recording continuously for 30 minutes.

The peak accelerometers are instruments requiring no power source and are used to permanently record peak accelerations. These recordings are used to verify the dynamic analysis of seismic Class I structures, systems, and components by comparison with the recorded acceleration time history after a seismic event.

Peak accelerometers are located at the top of the Shield Building, the roof of the Auxiliary Building and the vall of the Control Room.

EFFECTS ON SAFETY The criteria for which the D3NPS seismic monitoring instrumentation was selected is based upon the Maximum Probable Earthquake and the Maximum Possible Earthquake with maximum ground accelerations of 0.98g and 0.15g, respectively, and, per Technical Specification Bases Section 3/4.3.3.3, "...is consistent with the recommendations of Regulatory Guide 1.12 "Instrumentation for Earthquakes",

April 1974."

The DBNPS Technical Specification Table 3.3-7, Item 3.a. "Heasurement Range",

specifies the frequency range for the Seismic Trigger as 0.053-20 Hertz (Hz).

This frequency range is consistent with the manufacturer's published range for the equipment as was originally installed at DBNPS. However, this frequency range is specific to the particular manufacturer's model and is overly

,, , Dockst No. 50-346 Licthsa No. NPF-3 S2 rial No. 1539 Attachment 2 Page 3 restrictive as to the acceptable replacement equipment which can be installed at DBNPS. In order to remove this unnecessary restriction, a revision to the frequency range (to cite a minimum frequency range) and inclusion of an actuation range is proposed based on the Regulatcry Guide 1.12, Rev. 1 (April 1974) reference to ANSI N18.5, "Earthquake Instrumentation Criteria for Nuclear Power Plants," as being acceptable to the NRC Staff for satisfying the seismic instrumentation requirements of the Regulatory Guide. The cited ANSI Standard was revised and reissued as ANSI /ANS-2.2.-1978, and was cited as acceptable by the NRC in the Proposed Revision 2 to Regulatory Guide 1.12 dated July 1981. The revised ANSI /ANS Standard provides, in Section 5.4, for the Seismic Trigger frequtney range to be 1 Hz to 10 Hz and an actuating level of 0.005g to 0.02g.

The DBNPS Updated Safety Analysis Report (USAR) Figure 2C.3-6, "Recommended Response Spectra for Horizontal Vibratory Ground Motions of Maximum Probable Earthquake (Smaller Earthquake) (0.08g) for Several Damping Ratios," provides the most conservative response spectra for system actuation. As stated in USAR Section 3.7.1.2," ... frequencies smaller than 0.5 cps [Hz] are insignificant in the design of structures and equipment." In addition, between 0.5 cps and 1.0 cps, anticipated maximum accelerations vill not be produced at these lov frequencies to cause exceedance of the bounding response spectra presented in Figure 2C.3-6 (attached). Further, it can be seen from Figure 2C.3-6 that the frequency range and actuation range cited by ANSI /ANS-2.2-1978 provide sufficient margin prior to reaching design values for actuating the recording instrumentation to monitor anticipated earthquake accelerations since the structures and systems are designed to withstand seismic events well above the trigger setpoint. Therefore, the proposed change to cite a minimum frequency range of 1 Hz to 10 Hz and the addition of an actuation range of 0.005g to 0.02g for the seismic trigger vill have no effect on safety.

The location of the seismic trigger and strong motion triaxial accelerometer (free-field accelerometer) should be such that its function is unaffected by surrounding structures. The cited location in Technical Specification Tables 3.3-7 and 4.3-4 of 300 feet is intended as a minimum to maintain sufficient distance from station structures to preclude influence from these structures' reflective vaves. At the proposed range of a minimum of 300 feet from the containment structure within the site boundary, the seismic trigger and strong motion triaxial accelerometer vill perform their intended function and vill allow relocation, if necessary, based on future construction at the site.

Therefore, the proposed location range change for the seismic trigger and triaxial accelerometer has no effect on safety.

The revised location of the peak accelerometer at the top of the Shield Building vill reflect the accelerometer's actual installed location and specify the minimum elevation where the accelerometer may be located to correspond its data with the highest mass point originally used in the Shield Building structural analysis (refer to USAR Figure 3.7-4).

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,, , Dockpt No., 50-346 Liesnsa No.'NFF-3 Ssrial No. 1539 Attachment 2 Page 4 SIGNIFICANT HAZARDS CONSIDERATION The Commission has provided standards in 10CFR50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an Operating License for a facility involves no significant hazards consideraticn if operation of the facility in accordance with the proposed amendment would not:

1) involve a significant increase in the probability or consequences of an accident previously evaluated; 2) create the possibility of a new or different kind of accident from any accident previously avaluated; or 3) involve a significant reduction in the margin of safety. Toledo Edison has reviewed the proposed change and determined that:

1. The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated because the seismic instrumentation and trigger have no effect on the initiation of an accident or seismic event. The proposed locations and ranges vill still ensure the information collected is proper and meaningful for determining the effect of a seismic event on structures and components important to safety (10CFR50.92(c)(1))

2. The proposed changes do not create the possibility of a new or different type of accident because the seismic instrumentation and trigger provide no accident initiation mechanism. (10CFR50.92(c)(2))

3. The proposed changes do not involve significant reduction in a margin of safety because the proposed locations and ranges remain consistent with the recommendation of Regulatory guide 1.12 as stated in the existing Technical Specification Basis 3/4.3.3.3. (10CFR50.92(c)(3))

Conclusion:

Based on the above, Toledo Edison has determined that the proposed changes do not involve a significant hazards consideration.

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/o#. ope *-

A .' t M tX. ./

04 N/X/tf%% A %' xx/ w o-I b /Y\ / YN 'x

- kv kNV\4\n3 03 'b -4/- [ ' OX\ - DM

N//^x (>MWl /

Y[.X M \ Mj/ ]

x }y ;

O2 y k' I

( I'6%$.[V M/SK[ XN3 O.t /X , X , VM O2 03 04 06 08 f 2 3 4 6 8 10 20 3'O Frequency, cy/sec I A = Ratio of critical damping RECOMMENDED RESPONSE SPECTPA FOR HORIZONTAL

! VIERATORY GROUND MOTIONS OF l MAXIMUM PROBABLE EARTHQUAKE (SMALLER EARTHQUAKE)

(0.08 g)

FOR SEVEPAL DAMPING RATIOS l WMAI 68-192 FIGURE 2C.3-6 l REVISION O l JULY 1982