Text

Proposed Tech Specs Bases Section 3/4.4.4, Relief Valves, Specifically Crediting Automatic Function of PORVs to Provide Mitigation for Inadvertent Operation of ECCS at Power Accident
	ML20248C551
Person / Time
Site:	Byron, Braidwood
Issue date:	05/29/1998
From:	; COMMONWEALTH EDISON CO.
To:	;
Shared Package
ML20248C535	List: ML20248C530; ML20248C551;
References
	NUDOCS 9806020186
	Download: ML20248C551 (15)
	v • d • e

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ATTACIIMENT B-1 MARKED-UP PAGES FOR PROPOSED CIIANGES TO TECIINICAL SPECIFICATIONS, BYRON STATION UNITS 1 & 2 CREDIT FOR AUTOMATIC PORV ACTUATION REVISED PAGES:

3/4 4-12 B 3/4 4-2a 9006020186 980529 PDR ADOCK 05000454 P PDR 1 Attachment B - Revised Pages

r l REACTOR COOLANT SYSTEM 3/4.4.4 RELIEF VALVES LIMITING CONDITION FOR OPERATION 3.4.4 Both power-operated relief valves (PORVs) and their associated block valves shall be OPERABLE. 3 APPLICABILITY: MODES 1, 2, and 3.

ACTION:

a. With one or more PORV(s) inoperable because of excessive seat leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the PORV(s) to OPERABLE status or close the associated block valve (s) with power maintained to the block valve (s); otherwise be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and 4

. r w u r- d

,in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . S d+. 'With one PORV inoperable due to causes other than excessive seat leakagg, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the PORV to OPERABLE status or close the associated block valve and remove power from the block o r a. ufo m M c valve; restore the PORV to OPERABLE status within the following t h_k l^l 7d;? SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .72 hours or be in HOT STAN p

+. With both PORVs inoperable due to causes other than excessive seat e

leakage} within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore at least one PORV to OPERABLE J

j status or close its associated block valve and remove power from <

the block valve and be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and (

in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . )

4. With one or more block valves inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore the k

-F block valve (s) to OPERABLE status or place its associated PORV in j manual control. Restore at least one block valve to OPERABLE status >

witisin um next hour if Luth block valves are inoperable; restore ;

any remaining inoperable block valve to OPERABLE status within 72 i ho'urs; otherwise, be in at least H0i STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months j and HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . 1 The provisions of Specification 3.0.4 are not apolicable.

SURVEILLANCE REQUIREMENTS 4.4.4.1 In addition to the requirements of Specification 4.0.5, each PORV shall be demonstrated OPERABLE at least once per 18 months by:

a. Performance of a CHA; DEL CALIBRATION of the actuation instrumentation, and

b. Operating solenoid air control and check valves on associated air accumulators in the PORV control system through one complete cycle

(

of full travel, and p

c. Operating the valve through one complete cycle of full travel during h MODES 3 or 4. (

4.4.4.2 Each block valve shall be demonstrated OPERABLE at least once per 92 days by operating the valve through one complete cycle of full travel unless W block valve is closed with power removed in order to meet the requirements of ALi1CN for.c?'of Specification 3.4.4.

d. e. g

" BYRON - UNIYS 1 & 2 3/4 4-12 AMENDMENT NO. UtM4(

r INSERT A

b. With one PORV inoperable because of automatic actuation circuitry failure, within I hour either restore the PORV to OPERABLE status or close the associated block valve and maintain power to the block valve; restore the -

PORV to OPERABLE status within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c. With both PORVs inoperable because of automatic actuation circuitry failure, within I hour either restore at least one PORV to OPERABLE states or close its associated block valve and maintain power to the block valve and be in at j least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

i i

REACTOR COOLANT SYSTEM BASES 3/4.4.4 RELIEF VALVES (Continued)

The OPERABILITY cf the PORVs and block valves is determined on the basis of C their being capable of performing the following functions: )

A. Manual control of PORVs to control reactor coolant system pressure. )

This is a function that is used for the steam generator tube rupture e -. accident and for plant shutdown. This function has been classified (

] as safety related for more recent plant designs.

/ g. Maintaining the integrity of the reactor coolant pressure boundary. )

c' This is a function that is related to controlling identified leakage (

and ensuring the ability to detect unidentifi or coolant '

pressure boundary leakage. g gym

g. Manual control of the block valve to: unblock an isolated PORV 1

b. to allow it to be used for manual 1 control of reactor coolant system )

pressure (Item A , and (2) isolate a PORV with excessive seat.

leakage (Item . gg I

)

4 Manual control of a block valve to isolate a steck-open PORV.

Surveillance Requirements provide the assurance that the PORVs and block i valves can perform their functions. The block valves are exempt from the surveillance requirements to cycle the valves when they have been closed to )

cely Wb the ACTION requirements. TM s p ecludes the need to cycle the (

valves with full system differential pressure or when maintenance is being )

performed to restere an inoperabin PORV to operabic state. j Surveillance requirement 4.4.4.1.b has been added to include testing of the k mechanical and electrical aspects of control sytems for air-operated PORVs.

Testing of PORVs in HOT-STANDBY or HOT SHUTDOWN is required in order to simulate the temperature and pressure environmental effects on PORVs. In many PORY designs, testing at COLD SHUTDOWN is not considered to be a representative test for assessing PORV performance under normal plant operating conditions. ,

)

The PORVs are equippe with automatic actuation circuitry and manual con-

trol capability. 9h;;;;e credit for PORV eperation is taken in the FSAR analyses for Mode 1, 2 a 3 transients, the PG L ... cereis ted-OPERA 8tri W eith:r th tic rr,A F It should be noted that the automatic mode is the preferred configuration, as this providet pressure relieving capability without reliance on operator l action.

\ e g t &c m A'f M o^ O h Inadverter.t Tnzri O Iq ec%n of p eer eve &%+-^

' BYRON c UNI 15 1 & 2 B 3/4 4-2a AMENDMENT NO. 44-

INSERT B 4

B. Automatic control of PORVs to control reactor coolant system pressure. This

' is a function that reduces challenges to the Code Safety Valves for an Inadvertent Safety Injection at Power event.

INSERT C Both manual and automatic capabilities are required for the PORVs to be considered OPERABLE; if the automatic actuation circuitry of any PORV is inoperable in Modes 1,2, and 3, that PORV is considered inoperable. Placing the PORV in manual control does not render the PORV inoperable as long as the automatic actuation circuitry is available.-

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l l~

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_ _ ___a

ATTACHMENT B-2 MARKED-UP PAGES FOR PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS, BRAIDWOOD STATION UNITS 1 & 2 CREDIT FOR AUTOMATIC PORV ACTUATION REVISED PAGES:

3/4 4-12 B 3/4 4-2a l

1 l.

t i i

2 Attachment B - Revised Pages

REACTOR COOLANT SYSTEM 3/4.4.4 RELIEF VALVES LIM'ITING CONDITION FOR OPERATION 3.4.4 Both power-operated relief valves (PORVs) and their associated block valves shall be OPERABLE. (

APPLICABILITY: MODES 1, 2, and 3.

ACTION:

a. With one or more PORV(s) inoperable because of excessive seat leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the PORV(s) to OPERABLE status or close the associated block valve (s) with power maintained to the block k h6CT b valve (s); otherwise be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

i f] [ With one PORV inoperable due to causes other than excessive seat leakagt within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the PORV to OPERABLE status

' y gg or close the associated block valve and remove power from the block valve; restore the PORV to OPERABLE status within the following acAAaM 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT <

cheaHwg SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

O b yc c [. With both PORVs ineperable due to causes other than excessive seat (

leakagen within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore at least one PORV to OPERABLE )

status or close its associated block valve and remove power from (

the block valve and be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and ,

in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

[ [ With one or more block valves inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore the block valve (s) to OPERABLE status or place its associated PORV in (

manual control. Restore at least one block valve.to OPERABLE status )

wi6isin che inext hour 11 both block viived are inoperable; restore

)

any remaining inoperable block valve to OPERABLE status within 72 incurs; otherwise, be in et ieast HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . f j [ The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.4.4.1 In addition to the requirements of Specification 4.0.5, each PORV shall be demonstrated OPERABLE at least once per 18 months by:

a. Performance of a CHANNEL CALIBRATION of the actuation

~ C instrumentation, and '

b. Operating solenoid air control and check valves on associated air 6 accumulators in the PORV control system through one complete cycle h of full travel, and

c. Operating the valve through one complete cycle of full travel during MODES 3 or 4.

('.'

4.4.4.2 Each block valve shall be demonstrated OPERABLE at least once per 92 days by operating the valve through one complete cycle of full travel unless the block valve i ,fclosed with power removed in order to meet the requirements of ACTION or f. of Specification 3.4.4.

BRAIDWOOD - UNITS 1 & 2 3/4 4-12 AMENDMENT NO. 2 ssh l

INSERT A

b. ' With one PORV inoperable because of automatic actuation circuitry failure, within I hour either restore the PORV to OPERABLE status or close the associated block valve and maintain power to the block valve; restore the PORV to OPERABLE status within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c. With both PORVs inoperable because of automatic actuation circuitry failure, within I hour either restore at least one PORV to OPERABLE status or close its associated block valve and maintain power to the block valve and be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . j l

I i

L___________________.___ . _ _ . _ _

1 I

REACTOR COOLANT SYSTEM

. BASES l 3/4.4.4 RELIEFVALVES(Continued) .

(

The OPERABILITY of the PORVs and block valves is determined on the basis of i their being capable of performing the following functions: t A. Manual control of PORVs to control reactor coolant system pressure.

This is a function that is used for the steam generator tube rupture accident and for plant shutdown. This function has been classified bM as safety related for more recent plant designs. ),

Maintaining the integrity of the reactor coolant pressure boundary. (

6. [ This is a function that is related to controlling identif )

'and ensuring the ability to detect unide tifie f p pc or coolant pressure boundary leakage. gg gggg

+- '

3 A. Manual control of the block valve to: (1) unblock an isolated PORV to allow it to be used for manualtcontrol of reactor coolant system pressure (Itc.s a isolate a PORV with excessive seat leakage (Iten f)., g b

E A. Manual control of a block valve to isolate a stuck-open PORV. (.

Surveillance Requirements provide the assurance that the PORVs and block valves can perform their functions. The block valves are exempt from the k

/

surveillance requirements to cycle the valves when they have been closed to rr W ~it' the ACTIO" Mir-~ents. TMs precluder. 'P need te cycle th? ( 4 valves with full system differential pressure or when maintenance is being e perferned to rcstere an 'ncpr. rabic POR" t oper.-bla status, k Surveillance requirement 4.4.4.1.b has been added to include testing of the mechanical and electrical aspects of control sytems for air-operated PORVs. (

Testing of PORVs in HOT STANDBY or HOT SHUTDOWN is required in order to simulate the temperature and pressure environmental effects on PORVs. In many PORV designs,' testing at COLD SHUTDOWN is not considered to be a representative test for assessing PORV performance under normal plant operating conditions.

The PORVs are equipped w h automatic actuation circuitry and manual '

control capability.44use credit for PORV operation is taken in the FSAR analyses for Mode 1

+ " '-- " - --' -, 2 andm ^3 ransients, L .T"!;be

-- 9 It should cr:noted

::idored that theOPEP"LE automatic i't9/

mode is the preferred configuration, as his provides pressure relieving capability without reliance on operator action.

O don of 1 pSERT b exceft for mi the. InadvevM^ bk I Tn ecAon of power evcAt, BRAIDWOOD - UNITS 1 & 2 B 3/4 4-2a AMENDMENT NO. 13 l

p .

l :

INSERT B B. Automatic control of PORVs to control reactor coolant system pressure. This is a function that reduces challenges to the Code Safety Valves for an {

Inadvertent Safety Injection at Power event.

Ii i

! INSERT C.

Both manual and automatic capabilities are required for the PORVs to be

- considered OPERABLE; if the automatic actuation circuitry of any PORV is '

inoperable in Modes I,2, and 3, that PORV is considered inoperable. Placing the PORV in manual control does not render the PORV inoperable as long as the automatic actuation circuitry is available.

1 i

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' ATTACHMENT C

~ SIGNIFICANT HAZARDS CONSIDERATION

~ Comed has evaluated this proposed amendment and determined that it involves no significant hazards consideration. According to 10 CFR 50.92(c), a proposed amendment to an operating

_. license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

-

Involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated; e ' Create the possibility of a new or different kind of accident from any previously analyzed;

- or e Involve a significant reduction in a margin of safety.

- Comed proposes to amend Facility Operating Licenses NPF-37, NPF-66, NPF-72, and NPF-

77. The proposed change revises Byron and Braidwood (B/B) Technical Specification (TS)

Section 3/4.4.4, " Relief Valves," and the corresponding TS Bases. The proposed revision to Byron and Braidwood Limiting Condition for Operation (LCO) 3.4.4 includes two new

- actions to address pressurizer power operated relief valve (PORV) inoperability due to !

. automatic circuitry failures. A change is also proposed to Surveillance Requirement 4.4.4.2 to reflect the changes made to the LCO._ Comed also proposes to revise TS Bases Section

'3/4.4.4, " Relief Valves," to indicate that the automatic control function of the pressurizer PORVs is credited on a limited basis to mitigate the Inadvertent Operation of Emergency .

Core Cooling System (Spurious SI) at Power tramient only. In addition, the proposed

' revision to the Bases states that both manual and automatic operation capabilities are required for the PORVs to be considered operable. The TS Bases further state that if the automatic

- actuation circuitry of a PORV is inoperable, that PORV is considered inoperable.

Subsequent to NRC approval of this request, the UFSAR description in Section 15.5.1 will be updated to reflect the revised design safety analysis.

The determination that the criteria set forth in 10 CFR 50.92 are met for this amendment request is indicated below:

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

The changes to the TS LCO, Surveillance Requirements, and Bases do not involve an i increase in the probability or consequences of the Spurious SI at Power transient. ;

Crediting the PORVs in the maximum pressurizer overfill case for this transient does 1 not increase the probability of the occurrence of the transient since the automatic 1 Attachment C - Significant Hazards Consideration

_A__.___. -__.,___________________.______.-___m__._m_ _ _ _ _ _ _ . _ _ _ _ . _

1 i

1: -

t I $

function of the PORVs for Reactor Coolant System (RCS) pressure control is not an )

l initiator for the Spurious SI at Power transient. This change allows for the NRC Standard Review Plan (NUREG-0800) acceptance criteria to be met for the Spurious SI 1 at Power transient, ensuring that the consequences of this transient remain within acceptable levels. I As documented in various Safety Evaluation Reports (SERs) from the NRC, the overpressure protection function of the PORVs was not originally considered to be a safety related function. In response to Generic Issue 70, the NRC performed a regulatory analysis related to PORV and block valve reliability in Pressurized Water l Reactor (PWR) plants. This regulatory analysis is documented in NUREG-1316,

" Technical Findings and Regulatory Analysis Related to Generic Issue 70, Evaluation of Power-Operated Relief Valve and Block Valve Reliability in PWR Nuclear Power Plants," where the NRC staff concluded that it was not cost effective to backfit non-safety related PORVs to upgrade them to safety related status to perform safety related functions. The safety related functions were those detailed in Section 2.1 of NUREG-1316 and any other safety related function identified in the future. As an example, the PORVs are credited for the cold overpressure protection function of the reactor pressure vessel during low temperature operations. The analysis documented in this License Amendment request demonstrates that the PORVs provide an acceptable level of quality and performance to allow them to be credited to mitigate the consequences of the Spurious SI at Power transient documented in Byron and Braidwood UFSAR <

Section 15.5.1. The PORVs are equipped with safety related actuators and safety related accumulator tanks which maintain valve function during a loss of instrument air. The position indication and control switches in the Main Control Room (MCR) l are safety related. All pressurizer PORV open/close functions and circuitry are 4

supplied with uninterruptible Class 1E power supplies. The automatic portion of the PORV circuitry which processes the high pressurizer and high RCS pressure at low temperature is designated non-safety related and is isolated from the safety related portions of the circuitry by safety related interposing relays which actuate on a faulted condition. However, both Byron and Braidwood Stations have implemented

. modifications for both Units 1 and 2. which ensure that automatic control of both PORVs is available during loss of offsite power conditions. In addition, the PORV function is monitored within the scope of the Maintenance Rule Program and the postulated failure of the PORV automatic function does not result in unacceptable risk.

The probability of a Spurious SI at Power transient is not affected by this proposed change and the above analysis demonstrates that the PORVs will adequately function in automatic mode to mitigate the consequences of the transient. As such, there are no changes in the type or amount of any effluent released offsite as a result of this change.

Therefore, based on this evaluation, this proposed amendment does not involve a significant increase in the probability or consequences of an accident previously 1 evaluated. l l

2 Attachment C - Significant Hazards Consideration

2. The change does not create the possibility of a new or different kind of accident {

from any accident previously evaluated.

l This proposed change does not create the possibility of a new or different accident from any accident previously evaluated. This change would specifically allow for the PORV automatic function to be credited in Modes 1,2, and 3 for the Spurious SI at Power transient only. This change allows for added assurance that the acceptance criteria as documented in the NRC Standard Review Plan (NUREG-0800) for ANS Condition II transients will be met. The acceptance criteria of concern is that a Condition II transient must not lead to an event (Condition III or IV) of more significant consequences without additional failures occurring. The PORV automatic {'

function is to be credited with mitigating the maximum pressurizer overfill case for the l Spurious SI at Power transient. This case has the acceptance criteria that the L pressurizer must not go water solid prior to RCS pressure reaching the setpoint of the pressurizer safety relief valves (PSRVs). This conservative acceptance criteria is based on the fact that the PSRVs are not qualified to pass subcooled water and reseat, thereby creating a concern for an uncontrolled release path from the RCS. This proposed change helps ensure that the acceptance criteria for this accident are met. There is a small probability that the PORV function, either automatic or manual, would not successfully mitigate this transient due to the failure of one or both PORVs. However, the low likelihood of a total failure of the PORV function during the Spurious SI at Power transient does not create a new accident because a similar scenario is already addressed by UFSAR Section 15.6.1, " Inadvertent Opening of a Pressurizer Safety or Relief Valve." The UFSAR analysis for the Section 15.6.1 ANS Condition II tmsient indicates that the radiological consequences of this transient are significantly ,ess than that of a LOCA and are therefore, acceptable. The same arguments for radiological consequences apply to the Spurious SI at Power transient in the event the PORV automatic function fails and water relief occurs through the PSRVs.

The proposed change to the LCO requirements in TS Section 3/4.4.4 would allow for the PORV block valve to be closed but cemain energized in the event a PORV was considered inoperable due to the automatic actuation circuitry. Currently, the PORV block valve is closed but remains energized only if a PORV is considered inoperable due to excessive seat leakage. The proposed change would extend the allowance to include the circumstance where the PORV was inoperable due to the automatic actuation circuitry. This allows a PORV to remain functional in the mam.Al mode for other safety related functions consistent with the discussion contained in NRC NUREG-1316. However, this revised LCO requirement would not represent a new failure mode or accident over what has been previously evaluated.

In summary, the proposed changes documented in this TS amendment to credit the automatic PORV function and to revise the TS LCO requirements for PORV inoperability do not create the potential for any new or different accidents from what was previously evaluated.

3 Attachment C - Significant Hazards Consideration l

,. e j 3. The change does not involve a significant reduction in a margin of safe +y.

' The current TS bases do not credit the function of the pressurizer PORVs for any Mode 1,2, or 3 transients. This change would allow for the PORV automatic function to be credited for the Spurious SI at Power transient only. This does not represent a significant reduction in the margin of safety. This change would allow for the conservative acceptance criteria for the current UFSAR design analysis to be met. The l PORVs are reliable and are maintained in a manner consistent with their proposed safety related function to mitigate the Spurious SI at Power transient. This proposed change would not result in a significant increase in risk or consequences, and therefore, does not involve a significant reduction in the margin of safety.

Based upon the above evaluation, Comed has concluded that the proposed changes involve no

! significant hazards consideration.

4 Attachmem C - Significant Hazards Consideration L - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

ATTACHMENT D ENVIRONMENTAL ASSESSMENT I

Comed ha evaluated this proposed operating license amendment request against the criteria for identification oflicensing and regulatory actions requiring environmental assessment u accordance with 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) and as such, has determined that no irreversible consequences exist in accordance e ith 10 CFR 50.92(b). This determination is based on the fact tha this change is being prcposed as an amendment to a license issued pursuant to 10 CFR 50 that changes a requirement with , !spect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or that changes an inspection or a surveillance:

requirement, and the amendment meets the following specific criteria:

(i) the amendment involves no significant hazards consideration.

As demonstrated in Attachment C, this proposed amendment does not involve any significant hazards consideration.

(ii) there is no significant change in the types or significant increase in the amounts of any effluent that may be released offsite.

The proposed amendment will ensure that all safety analysis accident assumptions are met for the Spurious SI at Power transient. As indicated in Attachment C, there will be no change in the types or increase in the amounts of any effluents released offsite.

(iii) there is no significant increase in individual or cumulative occupational radiation

[ exposure.

The proposed changes will not result in significant changes in the operation or configuration of the facility. There will be no change in the level of controls or methodology used for processing of radioactive effluents or handling of solid radioactive waste, nor will the proposal result in any change in the normal radiation levels within the plant. Therefore, there will be no increase in individual or cumulative occupational radiation exposure resulting from this change.

F

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ML20248C551

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