ML20216G854

Proposed Tech Specs Change to TS 4.5.2.b & Associated Bases Bringing Byron Unit 1 & Braidwood Unit 1 Requirement in Conformance W/Unit 2 Requirements Approved by NRC in 970813 Ltr

ML20216G854
Person / Time
Site:	Byron, Braidwood
Issue date:	09/08/1997
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20216G841	List: ML20216G834 ML20216G854
References
NUDOCS 9709160069
Download: ML20216G854 (16)

Text

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ATTACllMENT B-1 MARKED UP PAGES FOR PROPOSED Cl{ANGES TO APPENDIX A, TECilNICAL SPECIFICATIONS, OF FACILITY OPERATING LICENSES NPF-37 AND NPF-66 BYRON STATION UNIT 1 AND UNIT 2 REVISED PAGES:

3/4 5 4 3/4 5-4 a 3/45-4b B 3/4 5-2 B 3/4 5-2a

. n:\byrbwd\newvent. doc Page1of 1 Attachment B-1 9709160069 970908 DR ADOCK 050004 4

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SURVEILLANCE REQUIREMENTS

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BYRON - UNITS 1 & 2 3/4 5-4 AMENDMENT NO. 90

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SURVElllANCE REQUIREMENTS 4

'4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:

a. ' At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the following val es are in the indicated positions with power to the valve opera rs removed:

Valve Number Valve Function- Valve Po ition M0V SI8806 Suction to the SI 0 'n Pumps MOV S18835 SI Pump Discharge Open*

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To RCS Cold legs MOV SIB 813 SI Pump Recirculation Open To The RWST MOV SIB 809A RHR Pump Discharge t Open*

q RCS Cold legs

'\ MOV SI8809B RHR Pump 01scharg to Open*

RCS Cold Legs MOV SIB 840 RHR Pump Disch- ge to Closed RCS Hot Legs MOV S18802A SI Pump Dis arge to Closed RCS Hot L s MOV SIB 802B SI Pump scharge to Closed RCS Ho Legs

b. For Unit 1, through Cycl 8, at least once per 31 days by:

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1) Venting the pump asings and discharge piping high point vent valves outside containment (applicable to idle RH and SI systems only) and

2) Verifying t at each valve (manual, power-operated, or automatic in the flow path that is not locked, sealed, or otherwis secured in position, is in its correct position (applic le to CV, RH, SI systems). l

3) Veri ng the CV system is full of water by ultrasonically exa ining the discharge portion of the idle CV pump up to the d charge check valve and the stagnant portion of the piping stream of the ISI8801A and B of the 1SI045 valve (applicable to CV system only).

c. B a v.isual inspection which verifies that no loose debris (rags, trash', clothing, etc.) is present in the containment which could be transported to the containment sump and cause restriction of the pump suctions during LOCA conditions. This visual inspection shall be performed:

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• Valves may be realigned for testing pursuant to Specification 4.4.6.2.2.

BYRON - UNIT 1 3/4 5-4o AMENDMENT N0.90

SURVElllANCE RE0Vir.EHENTS

' 4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the following valves are in the indicated positions with power to the valve operators removed:

Valve Number Valve Function Valve Position MOV S18806 ~ Suction to the SI Open Pumps i

MOV S18835 SI Pump Discharge Open*

To RCS Cold Legs i

MOV SI8813 SI Pump Recirculation Open

! To The RWST MOV S!8809A RHR pump Discharge to Open*

RCS Cold legs HOV S188098 RHR Pump Discharge to Open*

RCS Cold legs MOV SIB 840 RHR Pump Discharge to Closed RCS Hot Legs HOV SI8802A SI Pump Discharge to Closed RCS Hot legs HOV S!8802B SI Pump Discharge to Closed RCS Hot Legs

b. At least once per 31 days by:

1) Venting the ECCS pump casings and discharge piping high point vent valves outside of containment (applicable to idle RH and SI systems only), and

2) Verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position (applicable to CV, RH, SI systems).

3) Verifying the CV system is full of water by ultrasonically examining the discharge portion of the idle CV pump up to the discharge check valve, the stagnant portjon of the piping upstream of th @SI8801 A and B at f7, BIO 45 valve, and the piping at the V206 valve if the um to the CV sys em only). c.V/ p is idle (applicable

c. By a visual inspection which verifies that no loose debris (rags, trash, clothing, etc.) is present in the containment which could be transported to the containment sump and cause restriction of the pump suctions during LOCA conditions. This visual inspection shall be performed:

• Valves may be realigned for testing pursuant to Specification 4.4.6.2.2.

BYRON - UNIl5 2 3/4 5-4 AMENDMENT NO.

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. BASES

,' ECCS SUBSYSTENS (Continued)

The limitation for a: maximum of one centrifugal charging pump to be OPERABLE and the Surveillance Requirement to verify all charging pumps except the required OPERABLE Charging pump to be inoperable in MODE 4 with one or more of the RCS cold legs less than or equal to 330*F, MODE 5, and MODE 6 with the reactor vessel head on, provides assurance that a mass addition pressure transient can be relieved by the operation of a single PORY or RHR suction relief valve. Similarly, the requirement to verify all Safety Injection pumps are inoperable in MODE 4 with the temperature of one or more of the RCS Cold legs less than or equal to 330*F, in MODE 5 with pressurizer level greater than 5 percent (Level 409.5') and in MODE 6 with pressurizer level greater than 5 percent and the reactor vessel head resting on the reactor vessel flange, provides assurance that . Mass addition pressure transient can be relieved by a single PORV or RHR suction relief valve.

In MODE 5 and MODE 6 with pressurizer level less than or equal to 5 sercent, at least one Safety injection pump or gravity feed from the RWST must 3e available partially to mitigate drained the effects of a loss of decay heat removal during conditions.

but prevent inadvertent actuation during these modes. Surveillance The desired requirements assure a flow path for the SI pump or gravity feed varies with RCS configuration and is, therefore, procedurally addressed.

The Survetilance Requirements define what constitutes an adequate hot side vent for various plant conditions. It was determined that removing the reactor vessel head was an adequate vent under all conditions. Other venting alterna-tives have restrictions based on time from shutdown and RCS temperature. The values-in the surveillance were taken from the graph on page B 3/4 5-3.

l The Surveillance Requirements provided to ensure OPERABILITY of each component ensures that at a minimum, the assumptions used in the safety analyses are met and that subsystem OPERABILITY is maintained. Surveillance Requirements for throttle valve position stops and flow balance testing provide assurance that proper ECCS flows will be maintained in the event of a LOCA.

Maintenance of propor flow resistance and pressure drop in the piping system to each injection point is necessary to: 1) prevent total pump flow from exceeding runout conditions when the sys(tem is in its minimum resistance configuration, (2) provide the proper flow split between injection points in accordance with the assumptions used in the ECCS-LOCA analyses, and (3) provide an acceptable level of total ECCS flow to all injection points equal to or above that assumed in the ECCS-LOCA analyses. The Surveillance Requirements for leakage testing of ECCS check valves ensures that a failure of one valve will not cause an intersystem LOCA. In Mode 3, with pressurizer pressure below 1000 psig, the accumulators will be available with their isolation valves either closed but energized, or open, whenever a SIBB09 valve is closed to perform check valve leakage testing.

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Fur Un lance Requirement 4.5.2.b.1 re casings and e-t stu ggg valves be vented on

• i p- a 31 day frequency. This vent trrveTTlance d a ly to subsystems in communication with o ti g systems because the flows an prevalent o res e systems are sufficient to provide confidence tha ha h occurs from voiding would not result in unacceptable dynamic BYRON - UNITS 1 & 2 B 3/4 5-2 AMENDMENT N0. h ' '

EMERGENCFCORFC00EINn Sf5TEMS BASES ECCS SUBSYSTEMS (Continued) i Ibads. During normal operation, this exclusion would apply to the High HeMV' l

' Safety' Injection subsystem. During shutdown cooling operation, the excitis' ion would apply to-the single required centrifugal charging pump a3dape' rating RH pump, in addition'to-the ECCS piping in comunication with the operating purps, u[

W Because the centrifuga1' charging pumps are not equipped 'with pump casing vent valves, and the pump design and-system piping, configuration allow the pumps to be maintained under positive pressure-when-in standby, manual venting of these pumps is not required.

'N The surveillance r of piping involves the'equirement idle CV pumpto ultrasonically' discharge pi examine selected portions valve on the pumfdischarge and miniflow lines,and pingthe upstagnant' tb'the first checkof the portion piping yfovid,upstr,eam of the e added assurance ISIB801A/B that adjacent the piping is water solid. to the vent valve ISIO45NThis will X

Of[rW2 L Surveillance Requirement 4.5.2.b.1 requires that the RH and S1 (

pumpcaslngsan)ddischargepipinghighpointventvalvesbeventedona31 d frequency. This venting surveillance does not apply to subsystems in comunication with operating systems because the flows in these systems are

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sufficient to provide confidence that water hammer which could occur from voiding would not result in unacceptable dynamic loads. During shutdown 3

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cooling operation, the exclusion would apply to the operating RH pump, in ,

addition to the ECCS piping in communication with the operating pump. (

The TS 4.5.2.b.3 surveillance requirement to ultrasonically examine )

selected portions of piping involves the idle CV pump discharge piping up to '

the first check valve on the pump discharge and miniflow lines, the stagnant (

lortion of the piping upstream.pf the;tSI8801A/B adjacent to the vent valve o l045, and the piping at th tpffV206' valve if the This (N 7@ examination will provide added assurancepiping that the;'gB is waterCV pump is idle.

solid.

BYRON - UNITS 1 & 2 B 3/4 5-2a AMENDMENT NO. [ ' j

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ATTACllMENT B-2 MARKED UP PAGES FOR PROPOSED CilANGES TO APPENDIX A, TECliNICAL SPECIFICATIONS, OF FACILITY OPERATING LICENSES NPF 72 AND 77 BRAIDWOOD STATION UNIT I AND UNIT 2 REVISED PAGES:

3/4 5-4 3/45-4a 3/45-4b B 3/4 5-2 B 3/4 5-2a n:\byrbwd\newvent. doc Page1of 1 Attachment B-2

9 EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE RE0VIREMENTS

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l BRAIDWOOD - UNITS 1 AND 2 3/4 5-4 AMENDMENT NO. 83

( i EMERGENCY CORE COOLING SYSTEMS g4%

, SURVEILLANCE REQUIREMENTS 1

4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the following va)ves are in the indicated positions with power to the valve operators removed:

Valve Number Valve Function Valve Pos tion MOV Sl8806 Suction to the SI Ope Pumps MOV SI8835 SI Pump Discharge en*

To RCS Cold legs MOV SIB 813 SI Pump Racirculation Open To The RWST MOV SI8809A RHR Pump Discharge to

Open*

RCS Cold Legs MOV SI88098 RHR Pump Discharge to Open*

RCS Cold legs MOV SI8840 RHR Pump Discharge ,to Closed RCS Hot Legs MOV SI8802A SIPumpDischarge/o t Closed RCS Hot Legs M0V SI8802B SI Pump Dischar/ ge to Closed RCS Hot Legs /

b. at/ least once per 31 days by: l ForUnit1,throughCycle7,/

1) Venting the pump casings and discharge piping high point vent valves outside of containment (applicable to idle RH and SI system only), and '

2) Verifying that each valve (manual, power-operated, or automatic) in thf flow path that is not locked, sealed, or otherwise secured in position, is in its correct position (applicable t6 CV, RH, SI system). l

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3) Verifying ,the CV system is full of water by ultrasonically examining'the discharge portion of the idle CV pump up to the discharge check valve and the stagnant portion of the piping upstream of ISI8801A and B at the 1S1045 valve (applicable to CV system only).

c. By a v)s/ ual insppction which verifies that no loose debris (rags, trash ( clothing, etc.) is present in the containment which could be transported to the containment sump and cause restriction of the pump suctions-during LOCA conditions. - This visual inspection shall be performed:

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• Valves ay be realigned for testing pursuant to Specification 4.4.6.2.2.

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BRAIDWOOD - UNIT 1 3/4 5-4a AMENDMENT NO. 83 l

EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE RE0VIREMENTS 4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:'

a.

At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the following valves

are in the indicated positions with power to the valve operators removed

Valve Number Valve Function MOV SI8806 Valve Position Suction to the SI Open Pumps MOV SI8835 SI Pump Discharge Open*

To RCS Cold legs MOV SIB 813 SI Pump Recirculation Open To The RWST MOV SI8809A RHR Pump Discharge to Open*

RCS Cold legs MOV SIB 809B RHR Pump Discharge to Open*

RCS Cold legs MOV SI8840 RHR Pump Discharge to Closed RCS Hot legs MOV SI8802A SI Pump Discharge to Closed RCS Hot Legs MOV SI8802B SI Pump Discharge to Closed RCS Hot Legs

b. At least once per 31 days by:

1)

Venting the ECCS pump casings and discharge piping high point vent valves outside of containment (applicable to idle RH and SI systems only), and

2) Verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position (applicable to CV, RH, SI systems). I I

3)

Verifying the CV system is full of water by ultrasonically examining the discharge portion of the idle CV pump up to the discharge check valve, the stagnant po on of the piping Qs 1 upstream of thec 18801 A and B at the 1045 valve, and the 16M # Dinino at the 4"JWa,lve if th mp is idle (applicable acNOp] to the CV system only). C )

R c.

By a visual inspection which verifies that no loose debris (rags, trash, clothing, etc.) is present in the containment which could be transported to the containment sump and cause restriction of the pump be suctions during LOCA conditions. This visual inspection shall performed:

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• ValvesmaybereajignedfortestingpursuanttoSpecification4.4.6.2.2.

E BRMWOOD - Eh 3/4 5 AM M PUNT NO

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BASES ECCS SVBSYSTEMS (Continued)

The limitation for a maximum of one centrifugal charging pump to be OPERABLE and the Surveillance Requirement to verify all charging pumps except the required OPERABLE Charging pump to be inoperable in MODE 4 with one or more of the RCS cold legs less than or equal to 330*F, MODE 5, and MODE 6 with the reactor vessel head on, provides assurance that a mass addition pressure transient can be relieved by the operation of a single PORY or RHR suction relief valve. Similarly, the requirement to verify all Safety Injection pumps are inoperable in MODE 4 with the temperature of one or more of the RCS Cold Legs less than or equal to 330'F, in MODE 5 with pressurizer level greater than 5 percent (Level 409.5') and in MODE 6 with pressurizer level greater than 5 percent and the reactor vessel head resting on the reactor vessel flange, provides assurance thac a mass addition pressure transient can be relieved by a single PORV or RHR suction relief valve.

In MODE 5 and MODE 6 with pressurizer level less than or equal to 5 percent, at least one Safety injection pump or gravity feed from the RWST must be available to mitigate the effects of a loss of decay heat removal-during partially drained conditions. Surveillance requirements assure availability, but prevent inadvertent actuation during these modes. The desired flow path for the 51 pump or gravity feed varies with RCS configuration and is, therefore, procedurally addressed.

The Surveillance Requirements define what constitutes an adequate hot side vent for various plant conditions. It was determined that removing the reactor vessel head was an adequate vent under all conditions. Other venting alterna-tives have restrictions based on time from shutdown and RCS temperature. The values in the surveillance were taken from the graph on page B 3/4 5-3. l The Surveillance Requirements provided to ensure OPERABILITY of each component ensures that at a minimum, the assumptions used in the safety analyses are met and that subsystem OPERABILITY is maintained. Surveillance Requirements for throttle valve position stops and flow balance testing provide assurance that proper ECCS flows will be maintained in the event of a LOCA.

Maintenance of proper flow resistance and pressure drop in the piping system to each injection point is necessary to: (1) prevent total pump flow from exceeding runout conditions when the system is in its minimum resistance configuration, (2) provide the proper flow split between injection points in accordance with the assumptions used in the ECCS-LOCA analyses, and (3) provide an acceptable level of total ECCS flow to all injection points equal to or above that assumed in the ECCS-LOCA analyses. The Surveillance Requirements for leakage testing of ECCS check valves ensures that a failure of one valve will not cause an intersystem LOCA. In Mode 3, with pressurizer pressure below 1000 psig, the accumulators will be available with their isolation valves either closed but energized, or open, whenever a SI8809 valve is closed to perform check valve leakage testing.

For-Unit a.,Jurveillance Requirement 4.5.2.b.1 requires that the_ECCS pump -

casings and dTsaiarge pipingAigh points equipped _with-vent 7aTves be vented on g@ a 31 day frequency. This vent.ing~iUrveiluncetdoes not apply to subsystems in W communicatioLwith-oper&tEg systems because the fliMnnd/or-pressures prevgTE Fin these systems are sufficient to provide confidence thaf voiding ~

BRAIDWOOD - UNITS 1 & 2 B 3/4 5-2 AMENDMENT N0. [

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mmETwgE- wgI ING- sy s i tMs BASES ECCS SUBSYSTEMS (Continutd) i

• %)ch couliT riiUWTH unacie%bls~dinVic'ToTdihgs wilrirot' occur. D0rtng -

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norial~op subsystem >eration, this exclusion would apply to the High Head Safety, Injection During shutdown cooling operation, the exclusion would' apply to the h, D single required ~Centfifugal Charging pump and operating RRpump, in addition tc the ECCS piping in communication with the operating Because the bentrifugal charging pumphire not equipped with-pumpumps.p casing vent valves, an'd s

,the pump design and system pipihg'co.nfigurat16n allow the pumps to be paintained under positive pressure' wifencin standby, manual venting of these pumps is not required.

The surveillance requirement to ultrasonically examDe' selected portions of pipinginvolves-thsidleCVpumpdischargepipinguptothe'firstcheckvalve on the pump-discharge and miniflow lines, and the stagnant portio'n'ofs the hipjng'upstreamofthe 1518801 A/B adjacent to the vent valve 15I045. "This wu l_ provide _added_ assurance _that_the_ piping _is_ water _ solid _ _ -- '

OFNU$l Q Surveillance Requirement 4.5.?.b.1 requires that the RH and 51 pump casings and discharge piping high point vent valves be vented on a 31 day frequency. This venting surveillance does not apply to subsystems in communication with operating systems because the flows in these systems are sufficient to provide confidence that water hammer which could occur from voiding would not result in unacceptable dynamic loads. During shutdown cooling operation, the exclusion would apply to the operating RH pump, in addition to the ECCS piping in communication with the operating pump.

The TS 4.5.2.b.3 surveillance requirement to ultrasonically examine selected portions of piping involves the idle CV pump discharge piping up to the first check valve on the pump discharge and miniflow lines, the stagnan portion of the piping upstream _of thestSI8801A/B adjacent to the vent valv 1045, and the piping at the(CV20trinlve if the willprovideadded'Tissurancethatthe'fBCVpumpisidle.

piping is water solid.This examination

.vs c.@o7 ocvam

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t BRAIDWOOD - UNITS 1 & 2 B 3/4 5-2a AMENDMENTN0.h m

A'ITACllMENT C EVALUATION OF SIGNIFICANT llAZARDS CONSIDERATIONS FOR PROPOSED CilANGES TO APPENDIX .A, TECifNICAL SPECIFICATIONS, OF FACILITY OPERATING LICENSES NPF-37, NPF-66, NPF-72, AND NPF-77 Commonwealth Edison has evaluated this proposed amendment and determined that it involves no signincant hazards considerations. According to Title 10 Code of Federal Regulations Section 50 Subsection 92 Paragraph c (10 CFR 50.92 (c)), a proposed amendment to an operating license involves no signi6 cant hazards considerations if operation of the facility in accordance with the proposed amendment would not:

1. Involve a signincant 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 accident previously evaluated; or

3. Involve a signincant reduction in a margin of safety.

A. INTRODUCTION t amonwealth Edison (Comed) proposes to revise Byron and Braidwood Technical SpeciRcation (TS) 4.5.2.b and associated bases as they relate to the requirement to vent the Emergency Core Cooling System (ECCS) pump casings and discharge piping high points outside containment. The change will revise the Unit I requirement for ultrasonic examinations every 31 days to also include ultrasonic examination of the piping at the ICV 206 valve for Byron (ICV 207 valve for Braidwood)if the IB CV pump is idle. These changes are required to align the surveillance requirements for Unit I with those of Unit 2. In addition, the cor.dition that the Unit I requirements will be applicable only until the end of the current cycle is deleted consistent with the Unit 2 requirements. With these changes there will no longer be the need to maintain separate pages for Unit I and Unit 2 requirements.

n:\byrbwd\newvent. doc Page 1 of 3 Attachment C

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4 H. , NO SIGNIFICANT IIAZARDS ANAINSIS

1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed changes will align the surveillance requirements for both Units I and 2 with the installed system design and normal operating conditions. No increase in the probability of an accident will occur as a result of this change. The conduct of surveillances required by the Technical Speci0 cations is not postulated to initiate an accident. The level of surveillance performed to date has provided conndence that the objective of the current surveillance requirement has been met. As such, the proposed change does not result in a signincant increase in the probability of occurrence of a previously analyzed accident.

The consequences of a previously analyzed accident are not increased. Operating experience has shown that the level of surveillance performed to date is sufncient to provide con 0dence that no signiGeant voiding has occurred in the afTected piping.

Ultrasonic examinations have confirmed the water solid condition of the piping.  ;

Although voiding is not expected, evaluation of postulated voided conditions confirm that unacceptable dynamic loading would not occur, and, therefore, the integrity of the ECCS piping is not compromised. Thus, the ECCS will be capable of performing its design function of cooling the reactor core and providing shutdown capability following initiation of the certain accidents. This will ensure that the consequences of a previously analyzed accident are not signincantly increased.

Therefore, these proposed revisions do not result in a signincant increase in the probability or consequences of an accident previously analyzed.

2. The proposed change does not create the possibility of a new os different kind of accident from any accident previously evaluated.

The proposed changes do not create the possibility of a new or different kind of accident.

Comed has evaluated the piping configuration for the ECCS discharge piping of the ECCS subsystems. A specine engineering evaluation of both a voided 2-inch and 8-inch Rii line was performed. This evaluation concluded that the piping can withstand the dynamic loads caused by the maximum credible air void. Due to the higher-pressure rating and smaller size of the Si and CV discharge piping, this evaluation is considered bounding for the ECCS subsystems. The results of the evaluation were submitted for staff review in a letter dated March 12,1990, in support of Amendments 47 and 36 to the Operating Licenses for Byron and Braidwood, respectively. The proposed changes will not result in new failure modes because no new equipment is installed, and installed equipment is not operated in a new or different manner. Manual venting operations have been performed as permitted by system operation and piping con 6guration. This venting n:\byrbwd\newvent. doc Page 2 of 3 Attachment C l

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surveillance does not apply to subsystems in communication with operating systems

, because the flows and/or pressures prevalent in these systems are suf6cient to provide confidence that water hammer which could occur from voiding would not result in unacceptable dynamic loads from water hammer will not occur. Accordingly this change will not create the possibility of a new or dilTerent kind of accident.

3. The proposed change does not involve a significant reduction in a margin of safety.

The margin of safety is not signi6cantly reduced because the proposed change will provide sumcient assurance that excessive voiding will not occur. This will assure proper system functioning. Venting of the idle subsystems, in conjunction with the operating conditions of the subsystems in operation, provides confidence that voiding is not present. This has been con 6rmed by the performance of ultrasonic examinations of the piping ofinterest. This meets the objective of the surveillance requirement and thus preserves the margin of safety.

Therefore, based on the above evaluation, Comed has concluded that these changes involve no signi6 cant hazards considerations.

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n:\byrbwd\newvent doc Page 3 of 3 Attachment C

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ATTACllMENT D ENVIRONMENTAL ASSESSMENT FOR PROPOSED CilANGES TO APPENDIX A, TECilNICAL SPECIFICATIONS, OF FACILITY OPERATING LICENSES NPF-37, NPF-66, NPF-72 AND NPF-77 Commonwealth Edison Company (Comed) has evaluated this proposed license amendment request against the criteria for identification oflicensing and regulatory actions requiring environmental assessment in accordance with Title 10, Code of Federal Regulations, Part 51, Section 21 (10 CFR 51.21). Comed has determined that this proposed license amendment request meets the criteria for a categorical exclusion set forth in 10 CFR 51.22(c)(9). This determination is based upon the following:

1. The proposed change involves the issuance of an amendment to a license for a reactor pursuant to 10 CFR 50 which changes a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or which changes an inspection or a surveillance requirement;

2. this proposed license amendment request involves no significant hazards considerations;

3. there is no significant change in the types or significant increase in the amounts of any etliuent that may be released offsite; and

4. there is no significant increase in individual or cumulative occupational radiation exposure.

Therefore, pursuant to 10 CFR 51.22(b), neither an environmental impact statement nor an environmental assessment is necessary for this license amendment request.

n:\byrbwd\newvent. doc Page1of 1 Attachment D