ML20116N418

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Application for Amends to Licenses DPR-71 & DPR-62,changing TS 3.3.3, ECCS Actuation Instrumentation, to Allow Min Number of Operable Channels for One Reactor Steam Dome to Be Reduced from Two Channels to One Channel
ML20116N418
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 11/16/1992
From: Starkey R
CAROLINA POWER & LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20116N427 List:
References
NLS-92-296, NUDOCS 9211240009
Download: ML20116N418 (11)
v • d • e


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Carolina Power & Light Company P.O Box 1551

  • Raiutgh. N c. 27602 a

NOV 161992

. R B sTARKEY.JR.

, Vce President SERIAL: NLS-92-296 Nudear Servces Department 10 CFR 50.90 i

TSC 92TSB09 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk

, Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 & 50 324/ LICENSE NOS. DPR 71 & DPR 62 REQUEST FOR LICENSE AMENDMENT ECCS ACTUATION INSTRUMENTATION OPERABILITY i

Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power & Light Company hereby requests a one-time amendment to Appendix A or Operating Licenses DPR-71 and DPR-62 (the Technical Specifications) for the Brunswick Steam Electric Plant (BSEP), Units 1 and 2.

The proposed amendment will allow a one-time revision to the requirements of Technical
Specification 3.3.3, EMERGENCY CORE COOLING SYSTEM ACTUATION INSTRUMENTATION, I when in OPERATIONAL CONDITION 4 (COLD SHUTDOWN). The proposed amendment will allow I

the minimum number of operable channels for one reactor steam dome pressure -low instrumentation trip system to be temporarily reduced from two (2) channels to one (1) channel.

This will allow, on three separate occasions, one reactor steam dome pressure low (injection permissive) channel to be placed in the inoperable status for up to seven days without invoking

. ACTION statement requirements. This one-time revision to the Technical Specifications is needed I to support modifications to upgrade the seismic qualification of instrument racks H21 P009 (Unit 2

j. only) and H21 P010 (Unit 1 and Unit 21.

Enclosure 1 provides a detailed description of the proposed chai.ges and the basis for the changes.

_ Enclosure 2 details, in accordance with 10 CFR 50.91la), the basis for the Company's determination that tP 1roposed changes do not involve a significant hazards considerations Enclosure 3 provides an environmental evaluation which demonstrates that the proposed

, amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR-51.22(b), no environmental assessment needs to be prepared in connection with issuance of the amendment.

Enclosure 4 provides page change instructions for incorporating the proposed revisions. .l i \

Enclosure 5 provides markups of the preposed Technical Specificaticn pages for Unit 1. l Enclosure 6 provides markups of the proposed Technical Specification pages for Unit 2.

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1 Document Cotitrol Dask NLS 92 296 / Page 2 Carolina Power & Light Comp &ny is pieviding, in accordance with 10 CFR 50.91(b), Mr. t sne H.

Brown of the State of North Carolina with a copy of the proposed license amendment.

The Plant Nuclear Safety Committee has reviewed and recommended approval of this one time license amendment regeest.

To support imp!cmentation of the seismic qualification upgrades discussed herein, CP&L requests prompt NRC res;iew and approval of these proposed license amendments. Based on the Company's current work schedule, issuance of these proposed amendments is requested no later than December 31,1997. In order to allow time for procedure revision and orderly incorporation into i

copies of the Technical Specifications, CP&L requests that the proposed amendments, once approved by the NRC, be issued with an effective date to be no .ater than 30 days from the issuance of the amendments.

Please refer any questions regarding this submittal to Mr. D. B. Waters at (91W 546 2710.

Yours very truly, R. B. Starke), Jr.

WRM/wrm (nis92296.wpf)

Enclosures-

1. Basis for Change Request
2. 10 CFR 50.92 Evaluation
3. Environmental Considerations
4. Page Change Instructions
5. Technical Specification Pages Unit 1 (Markups)
6. Technical Specification Pages - Unit 2 (Markops)

R. B. Starkey, Jr., having been first duly sworn, did depose and say that the information contained herein is (rue and correct to the bast o' his information, knowledge and belief; and the sources of his information are officers, employees, contractors, and agents of Carolina Power & Light Company.

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ENCLOSURE 1 BRUNSWICK STEAM Ll.ECTRIC PLANT, UNITS 1 AND 2 NRC DOCKET NOS. 50 325 & 50 314 OPERATING LICENSE NOS. DPR 71 & DPR 62 REQUEST FOR LICENSE AMENDMENT ECCS ACTUATION INSTRUMENTATION OPERABILITY BASIS FOR CHANGE REQUEST Hackaround:

The units of the Brunswick Steam Electric Plant (BSEP) are both currently in mid cycle outages.

The outapes were initiated when ec.ncems arose that seismic design requirements in the diesel generator building were not satisfied. Work that must be completed prior to resumption of the current operating cycles har been identified and modifications are being made to upgrade t.s seismic qualification of several structures and components. For both units, the scope of work includes modifying various instruraent racks located in the reactor building.

The Company currently plans to upgrade the seismic qualification of ;he instrument racks, H21 P009 (Unit 2 only) and H21 P010 (Unit I and Unit 2), containing the B21 PT-N021C and 821 PT N021D reactor steam dome pressure low pressure transmitters, prior to either Brunswick Piant unit resurMng operatiom These instrument rack modifications will require that the 1 B21 PT-N021D,2 B21 PT N021C and 2 B21 PT N021D pressure transmitters be takcn out of service for a period of time that exceeds the Technt:al Specificatic specified restoration time for the equipment affected.

Current Reaulrement:

Technical Specification 3.3.3, ACTION v aquires that with une or more inoperable emergency core cooling system (ECCS) actuation instrumentation channels, take the ACTION required by Table 3.3.3-1. With fewer than two OPERABLE reactor steam dome pressure low (injection permissive) instruments per trip system, ACTION 31 of Table 3.3.31 requires that the associated l

i ECCS be declared inoperable. The ECCS associated with these instruments are the low pressure l coolant injection system (LPCI) and the core spray system.

l l Technical Specification 3.5.3.2 requires that two independent low pressure coolant injection subsystsms of the res~ dual heat removal system be OPERABLE when the unit is in OPERATIONAL CONDITION 1,2,3,4, or 5. ACTION b uf Technical Specification 3.5.3.2 states that in i OPERATIONAL CONDITIONS 4 or 5 with one or more loit pressure coolant injection subsystems

! inoperable, take the ACTION required by Specification 3.5.3.1. Technical Specificat!on 3.5.3.1 i requir'is that two independent core spray system subsystems to be OPERABLE when the unit is in l OPERATIONAL CONDITION 1,2,3,4, or 5. ACTION b.2 of Technical Specification 3.5.3.1 states that with both core spray system subsystems inoperable, operation may continue provided that at least one low pressure coolant injection subsystem is OPERABLE and both low pressure coolant injection subsystems are OPERADLE within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Oinerwise, suspend all operat*ons that have a potential for draining the reactor vessel and verify that at least one low pressure coolant injection subsystem is OPERABLE within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

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i Preocted Chanag:

j The proposed amendment will allow a one time revision to the requirements of Technical i Specification 3.3.3, EMERGENCY CORE COOLING SYSTEM ACTUATION INSTRUMENTATION, when in OPERATIONAL CONDITION 4 (COLD SHUTDOWN). The propost.d amendment will allow the minimum number of operabl6 channsis for one reactor steam dome pressure low d

instrumentation trip system to be temporarily reduced from two (2) channels to one (1) chcnnel.

! During these instrument rack modifications for each unit, the following compensatory actions will

! be implemented:

> (1) The inoperable channel shall be placed in the condition that will satisfy the logic for allowing injection by the associated ECCS with the reactor steam dome pressure below 410 psig i 15 psig.

1 (2) Both channels in the other vip system shall be maintained OPERABLE.

1 j (3) The reactor vessel head vent shall be maintained in the open position.

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Enjis:

The Brunswick Plant design includes two low pressure Emergency Core Cooling System s (ECCS) comprised of the core spray system and the low pressure coolant injection mo6 of the residual heat removal system. Both the core spray system and the residual heat removal system consist of two subsystems.

l Technical Specification 3.5.3.1 tequires that two independent core spray system (CSS) subsystems to be OPERABLE when the unit is in OPERATIONAL CONDITION 1,2,3,4, or 5. Technical Specification 3.5.3.2 requires that two independent low pressure coolant injection subsystems of i the residual heat removal system be OPERABLE when the unit is in OPERATIONAL CONDITION 1, 2, 3, 4, or 6.

The emergency core cooling system actuation instrumentation shown in Technical Specification 4

Table 3.3.3-1 is required to be operable in the MRATIONAL CONDITIONS specified therein.

Actuation of either the low pressure coolar.t M}sc'.lon system or the core spray system occurs upon receipt of either of the following two signals:

1. Drywell pressure high coincident with reactor steam dome pressure low, or
2. Reactor v9ssel water level low level 3 Either of the actuation signal combinations above would indicate conditions that may require injection of additional coolant to msintain reactor vessel inventory and would actuate the low pressure emergency core cooling systems. Following actuation, each of these systems is designed to inject when the pressure vessel pressure is less thsq the reactor steam dome pressure -low (injection permissive) setpoint (410 psig 2 15 psig). The reactor steam dome pressure low (injection permissive) logic is a one-out-of two taken twice configuration.

Additionally, this instrumentation provides another logic function. When reactor vessel pressure is below 310 i 15 psig and an initiation signalis present, the recirculation pump discharge and discharge bypass valves are signalled to close. This logic is intended to prevent diversion of low El 2 3

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oressure coolant injection flow through a ruptured recirculation pump suctinn line break.

Three of four instrument racks (instrument rack H21 P010 for Unit 1 and instrument racks H21@009 and H21 P010 for Unit 2) , ontaining one each of the four reactor steam dome pressure low pressure transmitter

  • regaire modificatinn to restore seismic qualification to current licensing
basis requirements. The inttrument rack modifications will require that the reactor steam dome e pressure transmitter (2-821 PT N021C for instrument rack H21 P009; 1821 PT N021D and 2 821 PT N021D for instrument rack H21 P010) be taken out of service for approximately five (5) days. Technical Specification 3.3.3, ACTION b requires that with one ter more inoperable emergency core cooling system (ECCS) actuation instruments, the ACTION required by Table 3.3.31 be followed. ACTION 31 of Table 3.3.31 requires that, with less than two OPERABLE reactor stecm dame prec2ure low (injection permissive) instruments per trip sylstem, the associated ECCS be dgwed inxerable. The ECCS associated with these instruments are the low pressure coolant injection sWtsin (LPCI) and the core spray system. Note that the recirculation loop pump discharge valve actuation function of t'e reactor steam dome pressure low (injection permissive) instruments is only applicable to the low pressure coolant injection systen,.

Technical Specification 3.5.3.2 requires that two independent low pressure coolant injection subsystems of the residual her removal system be OPERABLE when the unit is in OPERATIONAL -

CONDITION 1,2,3,4, or 5. v.; TION b of Technical Specification 3.5.3.2 states that in OPERATIONAL CONDITIONS 4 or 5 with one or more low pressure coolant injection subsystems inoperable, take the ACTION required by Specification 3.5.3.1. Technical Specification 3.5.3.1 requires that two iridependent core spray system subsystems to be OPERABLE when the unit is in

> OPERATIONAL CONDITION 1,2,3,4, or 5. ACTION b.2 of Technical Specification 3.5.3.1 states that with both core spray system subsystems inoperable, operation may continue provided that at least one low pressure coolant injection subsystem la OPERABLE ar.d both low pressure coolant injection subsystems are OPERABLE within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Otherwise, suspend all operations that have a potential for dralning the reactor vessel and verify that at least one low pressure coolant injection subsystem is OPERABLE within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

The proposed revision will allow, for each instrument rack modification, the minimum number of OPERABLE channels for one reactor steam dome pressere low injection permissive instrument trip system to be temporarily reduced from two (2) channels to one (1) channel. During the periods when the affected instruments are out of service, the following compensatory actions will be implemented:  ;

(1) The Inoptrable reactor steam dome pressure low (injection permissive) channel will be placed in the condition that will satisfy the logic for allowing injection by the associated ECCS with the reactor steam dome pressure below 410 psio

  • 15 psig.

(2)' Both reactor ; team dome pressure low (injection permissive) channels in the other trip system will be OPERABLE.

(3) The reactor vessel head vent will be maintained in the open position, f

The first actio7 compensates for the loss of instrumentetion redundancy in the a'fected trip system by manually accomplishing the required function for ECCS injection. Both Brunswick Plant units are-currently in COLD SHUTDOWN (OPERATIONAL CONDITION 4); therefore, a valid injection .

permissive signal (i.e., less than or equal to 410 psig i 15 psig) is currently present.

The second action will ensure that normal reactor cteam dome pressure Icw instrumentation redundancy is available when the modification work is initiated. Because each instrument rack modification w!!! be implemented separately, the redundancy of the reactor steam dome pressure .

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l - low (injection permissivel function for the other trip system will not be affected. Additionally the operable cnannels la the other trip systein will be capable of generating an cutomatic closure signal

, on a high pressure condition.

The third action is to compensate for the reduction in redundancy associated with closing the affected valves at pressures above the setpoints. Although the logic would be expected to function, this action ensures that even if the logic failed (due to the reduced redundancy) there would be no adverse offect. The closure of the injection valves protects the low pressure components of the low pressure coolant injection and core spray systems. The only credible event that would r ause a pressure increase above the shutoff head of core spray (approximately 310 prig) for the current plant ennditions would be due to filling the vessel to a near solid condition (most likely due to an inadvertent low reactor vessel level (low level #3) signal) combined with the effect of control rod drive injection and/or vessel inventory heatup. Maintaining the head vent line open will provide a flow path of adequate capa:lty to offset the effects of control rod drive flow and vessel inventory heatup.

Overall, these compensatory actions will ensure that the capability exists to actuate and inject low pressure emergency core cooling system flow, if required. They also ensure that the reduction of j instrumentation redundancy for closing the injection valves will have no affect it should be noted that the reactor vessel low water level and drywell high pressure signals which initiate the pumps for both the low pressure coolant injection system and core spray system are indepenoent of the injection permissive function provided by the reactor steam dome pressure low instrumentation.

Because placing the Inoperable reactor steam dome pressuto low (injection permissive) instrument in the condition that will satisfy the injection logic will not affect the actuation / initiation capability of the low pressure emergency core cooling systems, there will be no increase in the likelihood and no increase ni the consequences of a reactor low level condition requiring low pressure emergency

, core r:ocling system actuation. Since the reactor vessel head vent will be maintained open, there will be no potential of a .)ressurization event that could damage the low pressure coolant injection or core spray systems.

Conclusion:

i The proposed amendment will allow the minimum number of operable channels for one reactor steam dome pressure low instrumentation trip system to be temporarily reduced from two (2)

hannels to one (1) channel. The compensatory measuret, outlined ::bove will ensure the ability of LPCI and core spray to provide emergency core cooling system flow, if requirsd. The compensatcry measures will also ensure that the reduced redundancy for the injection valve closure will not lead to any adverse condition. The affected instruments will be removed from service on one occasion on Unit 1 and on two occasions on Unit .2.

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ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKET NOS. 50 325 6 50-324 OPERATING LICENSE NOS. DPR 71 & DPR 62 REQUEST FOR LICENSE AMENDMENT ECCS ACTUATION INSTRUMENTATlON OPERABILITY 10 CFR 50.92 EVALUATION The Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license for a facility involves no sigruficant hazards consideration if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in th) pobability or consequences of an tecident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.

Pursuant to 10 CFR 60.91(a)(1), Carolina Power & Light Company has reviewed this proposed license amendment request and d6termined that its adoption would not involve a significant hazards consideration. The bases for this determination are as follows:

Proposed Chanae:

The proposed amendment will allow a one time revision io the requirements of Technical Specification 3.3.3, EMERGENCY CORE COOLING SYSTEM ACTUATION INSTRUMENTATION, when in OPERATIONAL CONDITION 4 (COLD SHUTDOWN). The proposed amendment will allow the minimum number of operable channels for one reactor steam dome pressure low instrumentation trip system to be temporarily reduced from two (2) channels to one (1) channel.

During these instrument rack modifications for each unit, the following compensatory actions will be implemented:

(1) The inoperable channel shall be placed in the condition that will satisfy the le,gic for allowing injection by the associated ECCu with the reactor steam dome pressure below 410 psig i 15 psig.

(2) Both channels in the other trip system shall be maintained OPERABLE.

(3) The reactor vessel head vent shall be maintained in the open position.

Dmjji:

The change does not involve a significant hazards consideration for the following reasons:

1. The proposed amendment does not mvolve a significant increase in the probability of an accident previously evaluated. The intent of the requirement that Pere t' at least two operable injection permissive instrument channels per trip system is to ensure sufficiet.1 instrument redundancy exists such that a single instrument failure could not disable the ability to actuate and inject emergency core cooling, if required. No accident initiators or precursors ars changed by the proposed one-time revision. Neither the low pressure emergency core cooling system actuation instrumentation nor the low pressure emergency core cooling system injection instrumentation willinitiate an accident. The reactor vessel low water level and dr/well high pressure signals that initiate the pumps for both the low pressure coolant i

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$ inJcction system and core spray system are independent of the injection permissive function j provided by the reactor steam doue pressure -low instrument and are not affected by this

! change. Overall, the compensatory actions being taken will ensure that the capability exists ,

l to actuate and inject low pressure emergency core cooling system flow, if required. The l actions will also compensate for the reduced redundancy of the injection valve closure logic.

j Therefore, there will be no increase in the probability of failure of the components of the low '

piessure coolant injection or core spray systems that could lead to an accident. Thereforo, _

the one time revision to allow the minimum number of operable channels for one reactor i steam dome pressure -low instrumentation trip system to be temporarily reduced from j two (2) channels to one (1) channel will not involve a significant increase in the probability of

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an accident previous!v evaluated.

The proposed amendment does not involve a significant increase in the consequences of an

accident previously evaluated. The planned cospensatory action of placing the affected

. injection permissive channel in the condition that satisfies the logic will ensure that there is no

! reduction of redundancy in the logic that assures the capability to actuate and inject low i pressure emergency core cooling system flow, if required. The w:tions will also compensate j for the reduced redundancy of the injection valve closure logic by ensuring that the logic will

! not be challenged. The reactor vessel low water level and drywell high pressure signals that

initiate the pumps for both the low pressure coolant injection system and core spray system
are independent of the injection permissive funct on provided by the reactor steam dome

! pressure low instrument and are not affected by this change. Therefore, the proposed one-time revision to allow the minimum number of operable channels for one reactor steam dome 1

pressure low instrumentation trip system to be temporarily reduced from two (2) channels to j one (1) channel does not involve a significant increase in the consequences of any accident

previously evaluated.

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2. The proposed amendment does not create the possibility of a n3w or different kind of accident 3

from any accident previously evaluated. The instruments affected are designed to provide a j signal to open the injection valve for the low pressure emergency core cooling systems when

the reactor vesse! pressure is sufficiently low. The planned compensatory action to place the l

affected instrument channel in the condition that will satisfy the icgic for allowing injection

fulfills the instrument's safety function for emergency core cooling syster injection. Also, requiring the three remaining instruments to be operable during the two periods will ensure -

i that sufficient instrument redundancy is maintained fur the injection logic. The actions will j also compensate for the reduced redundancy of the injection valve closure logic by ensuring j that the logic will not be challenged. The planned compensatory act!ons will therefore ensure

that the emergency cere cooling system actuation instrumentation logic will actuate as l

designed. Thus, the proposed one time reduction in the required number of operable channels per trip system for the reactor steam dome low pressure injection permissive function does

< rot create the possibility of a new or different kind of accident from any accident previously evaluated.

l 3. The proposed amendment does not involve a significant reduction in the margin of safety.

l The intent of the Technical Specification requiiement that there be at least two operable injection permissive instrument channels per trip system is to ensure sufficient instrument

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redundancy exists such that a single instrument failure could not disable the ability to actuate 4 rnd inject emergency core cooling, if required. _The planned compensatory action of placing .

the affecteu injection permissive channel in the condition that satisfies the logic will ensura j the capability to actuate and inject low pressure emergency core cooling rystem flow if l . required. The requirement that the remaining three injection permissive instruments be

' operable during the modification perbd will ensure st.fficient redundancy is maintained such '

that the injection permissive logic will actuate if required. The planned ccmpensatory actions E2 2 i

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will also compensate for the reduced redundancy of the injection valve closure logic by ensuring that the logic will not be challenged. Therefore, based on the compensatory actions

! being taken the proposed one-time revision in allow the minimum number of operable i channels for onu reactor steam dome pressure -low instrumentation trip system to be l

temporarily reduced from two (2) channels to one (1) channel does not involve a significant j reduction in the margin of *afety.

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ENCLOSURE 3 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKET NOS. 50 325 & 50 324 OPERATING LICENSE NOS DPR 71 & DPR 62 REQUEST FOR LICENSE AMENOMENT ECCS ACTUATION INcTRUMENTATION OPERABILITY FNVIRONMENTAL CONSIDERATIONS 10 CFR 51.22(c)(9) provides criterion for and Identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment to an operat'ng license for a facility requires no environmental assessment if operation of the facility in accoriance with the proposed amendment would not: (1) involve a significant hazards consideration; (2) result in a si;;nificant chrnge in the types or significant increase in the amounts of any effluents that may be released offsite: (3) result in an increase in individual or cumulative occupational radiation exposure. Carolinc Power & Light Company has reviewed this request and determined that the proposed amendment meets the eligibility criteria for categorical exclusion set fortn in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the amerdment. The basis for this determination follows:

Proposed Chanae:

The proposed amendment will allow a one time revision to the requirements of Technical Specification 3.3.3, EMERGENCY CORE COOLING SYSTEM ACTUATION INSTRUMENTATION, when in OPERATIONAL CONDITION 4 (COLD SHUTDOWN). The proposed amendment will allow the minimum number of operable channels for one reactor steam dome pressure low lastrumentation trip system to be temporarily reduced from two (2) channels to one (1) channel.

1 During these ir.strument rack modifications for each unit the following compensatory actions will be implemented:

(1) The inoperable channe! shall be placed in the condition that will satisfy the logic for allowing injection by th".e associated ECCS with the reactor steam dome pressure below 410 psig i 15 psig.

(2) Both channels in tne other trip system shall be maintained OPERABLE.

(3) The reactor vessel head vent shall be maintained in the open position.

llittl
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rhe change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the following reasons
1. As demonstrated in Enclosure 2, the proposed amendment does not involve a significant hazards consideration.

! 2. The proposed amendment does not result in a significant change in the types or ,tignificant increase in the amounts of any effluents that may be released offsite. The proposed amendment does not introduce any new equipment nor does it require any existing l

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equipment or systems to perform a different type of function than they are presently designed to perform. The instruments affected are designed to provide a signal, under accident conditions, to open the injection valve for the low presrure emergency core cooling systems when the reactor vessel pressure is sufficiently low. Thc proposed one-time amendment will not alter the function of this instrumentation, and the planned compensatory actions will ensure that the consequences of any previously evaluated j accident are not increased. Therefore, there will not be a significant increase the types or i arnonnts of any effluent that may be released offsite and, as such, the proposed j

' arn .dment does net involve irreversible environmental consequences beyond those alread,-

associated with normal r.onation. As such, the change cannot affect the types or amounts l of any effluents that may be released offsite.

3. Tha proposed amendment does not result in an increase in individual or cumulative occupational radiation exposure. The Instrument racks being seismically upgraded are not physically located in an area with minimal background radiation exposure levels; therefore, neither the modifications nor implementation of the planned compensatory actions will have a significant affect on either Individual or cumulative occupational radiation exposure.

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