2CAN109603, Application for Amend to License NPF-6,changing Channel Functional Testing Frequency for Most of Reactor Protection Sys (RPS) & ESFAS Instrumentation from Monthly to Every Four Months
| ML20128P522 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 10/07/1996 |
| From: | Hutchinson C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20128P527 | List: |
| References | |
| 2CAN109603, NUDOCS 9610170287 | |
| Download: ML20128P522 (13) | |
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Tet 5008%4888 C. Randy Hutchinson vce Newn Operatus ANO October 7,1996 2CAN109603 U. S. Nuclear Regulatory Commission Document Control Desk Mail Station PI-137 Washington, DC 20555 f
Subject:
Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF-6 Plant Protection System Surveillance Test Interval Extension To 123 Days Gentlemen:
Attached for your review and approval is a proposed amendment to Arkansas Nuclear One Unit 2 (ANO-2) Technical Specifications (TS). The proposed amendment changes the channel functional testing frequency for most of the Reactor Protection System (RPS) and Engineered Safety Feature Actuation System (ESFAS)instmmentation from monthly to every four months. The basis for this change comes from CEN-327 and CEN-327 Supplement 1, "RPS/ESFAS Extended Test Interval Evalu Son" and CE NPSD-576, "RPS/ESFAS Extended Test Interval Evaluation for 120 Day Staggered Testing" and ANO calculation 92-E-0084-01, " Plant Protection System Bistable Drift Analysis". Based on a setpoint drift analysis, it has been determined that the instrumentation drift at the requested surveillance intervals will not cause setpoint values to exceed the specified allowable values.
The proposed amendment will also allow the use of Cycle Independent Shape Annealing Matrix (CISAM) methodology in the Core Protection Calculators (CPCs). The use of the CISAM methodology will eliminate approximately two to three hours of critical path work during startup following a refueling outage. This change is a Combustion Engineering Owners Group (CEOG) initiative with Palo Verde Nuclear Generating Station (PVNGS) as the lead plant for this change.
This amendment request is expected to result in a savings of approximately 2.6 million dollars for the remaining life of the plant. Because of the significant savings, this submittal is being
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considered as a Cost Beneficial Licensing Action request.
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1 The proposed change has been evaluated in accordance with 10 CFR 50.91(a)(1) using g
criteria in 10 CFR 50.92(c) and it has been determined that this change involves no significant hazards considerations. The bases for these determinations are included in the attached submittal.
9610170287 961007 PDR ADOCK 05000368 P
. U. S. NRC Octqber 7,1996 2CAN109603 Page 2 Entergy Operations requests that the effective date for this change be within 30 days of issuance. Although this request is neither exigent nor emergency, your prompt review is requested prior to the next ANO-2 refueling outage (2R12) which is currently scheduled to begin April 11,1997.
Very tmly
- urs, CR rde Attachments To the best of my knowledge and belief, the statements contained in this submittal are true.
SUBSCRIBED AND SWORN TO before me, a Notary Public in and for bba County and the State of Arkansas, this 9 day of Ocfch
,1996.(j M
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U. S. NRC October 7,1996 2CAN109603 Page 3 cc:
Mr. Leonard J. Callan Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London,Af 1847 Mr. George Kalman NRR Project Manager Region IV/ANO-1 & 2 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Bernard Bevill Acting Director, Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street Little Rock, AR 72205
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ATTACHMENT IQ 2CAN109603 PROPOSED TECHNICAL SPECIFICATION AND RESPECTIVE SAFETY ANALYSES IN THE MATTER OF AMENDING LICENSE No. NPF-6 ENTERGY OPERATIONS. INC.
ARKANSAS NUCLEAR ONE. UNIT TWO DOCKET No. 50-368 J
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Attachment to 2CAN109603 Page 1 of 9 DESCRIPTION OF PROPOSED CHANGES The following changes were made to Table 4.3-1:
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- 1. The monthly (M) Channel Functional testing requirement was changed to triannual (TA) for all Functional Units except for the Reactor Trip Breakers.
The TA testing requirement is modified by Note 10 requiring the Channel Functional testing to be performed on a staggered test basis. The bases for this Technical Specification (TS) was also modified to incorporate these changes.
- 2. The weekly Core Protection Calculator (CPC) addressable constant Channel Check requirement was removed. Note 9 was modified to require the addressable constant verification to be performed as part of the Channel Functional test.
- 3. Note 5 was modified to allow a " verification" of the shape annealing matrix elements used in the CPCs. This change will allow the use of Cycle Independent Shape Annealing Matrix (CISAM)in the CPCs.
The following changes were made to TS Table 4.3-2: The Channel Functional testing requirements were changed from monthly (M) to triannual (TA).
The TA testing requirement is modified by Note 2 requiring the Channel Functional testing to be performed on a staggered test basis. The Note 1 requirement to manually test the actuation logic for the functional units was also changed from 31 to 123 days to reflect the TA frequency. The bases for this TS was also modified to incorporate these changes.
The following administrative changes to the TS were made:
- 1. Table 1.2 was modified by adding a new surveillance frequency notation of triannual (TA) with a frequency of"At least once per 123 days." This change was needed to support the frequency changes associated with TS 3/4.3.1 and 3/4.3.2.
- 2. Action 2 on Table 3.3-1 and Action 10 on Table 3.3-3 was modified to reference the QA Manual Operations.
Specification 6.5.1.7.n was removed from the TS and this
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requirement was relocated to the QA Manual Operations.
- 3. The follow'mg changes were made to Table 3.3-3 Functional Unit 6.a: Changed the Total No. Of Channels requirement from "2 sets of 2 per train" to "2 sets of 2."
Changed the Channels To Trip requhement from "I set of 2 per train" to "2 sets of 2."
Changed the Minimum Channels Operable requirement from "2 sets of 2 per train" to "2 sets of 2."
- 4. The following changes were made to Table 3.3-3 Functional Unit 8.a: Changed the manual trip " buttons" to manual trip " switches."
Changed the Channels To Trip requirement from "1 set of 2 per S/G" to "2 sets of 2 per S/G."
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- 5. Added Note (a) to Table 4.3-2, Functional Unit 6.a, to clarify that these manual trip j
buttons are the local manual buttons on the Auxiliary Relay Cabinets (ARCS).
i Functional Unit 8.a was also modified from manual trip " buttons" to manual trip l
" switches."
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- 6. Minor formatting changes were made to Table 4.3-1.
BACKGROUND FOR THE SURVEILLANCE FREOUENCY EXTENSION l
Errors in the performance of Reactor Protection System (RPS) and Engineering Safety Features Actuation System (ESFAS) surveillance testing has caused many inadvertent reactor trips and ESFAS actuations challenging safety systems throughout the nuclear industry. The current testing frequency adversely impacts equipment life and unit availability. Increasing the surveillance test interval (STI) minimizes the opportunity for inadvertent ESFAS actuations and reactor trips during surveillance testing. Currently, RPS and ESFAS instmmentation channel functional tests are performed monthly.
Combustion Engineering (CE) issued Supplement I to CEN-327, "RPS/ESFAS Extended Test Interval Evaluation" in 1989. This supplement presented changes in RPS reliability that resulted from extending the test intervals from monthly to quarterly for all RPS trip parameters and recommended a quarterly test interval with sequential testing. CEN-327 Supplement 1.re-evaluated the nineteen RPS trip parameters that were in the original CEN-327. The results of the re-analysis demonstrated that the surveillance test intervals could be increased to quarterly with no significant increase in RPS unavailability.
The analysis results presented in CEN-327 and CEN-327 Supplement I demonstrates that the surveillance test intervals (STI) for RPS and ESFAS components can be increased without increasing public risk. The overall impact is a slight decrease in core damage frequency for the quarterly test interval. Extending the test interval does not change the trip per test frequency, but it does reduce the trip per year frequency.
The SER titled "RPS/ESFAS Extended Test Interval Evaluation" was issued by the NRC in November 1989. The NRC found that CEN-327 and its Supplement were acceptable for justifying the extensions in STI for the RPS and ESFAS from monthly to quarterly. The NRC agreed that STI for the RPS and the ESFAS could be extended for all CE plants (except Maine Yankee) to the requested interval contingent on the licensee in each case confirming that instrument drift occurring over the proposed STI would not cause the setpoint values to exceed those assumed in the safety analysis and specified in the TS. The NRC stated that licensees must confirm that they have reviewed instrument drift information for each channel involved and have determined that drift occurring in that channel over the period of extended STI would not cause the setpoint value to exceed the allowable value as calculated for that channel by the licensees methodology. Each licensee should have onsite records of the as-found and as-left values showing actual calculations and supporting data for planned future staff audits. The records should consist of monthly data over a period of the last 2 to 3 years with the current plant specific setpoint methodology used to derive the safety margins.
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i In June 1989 the Combustion Engineering Owners Grour(CEOG) contracted CE to evaluate the impact of extending the STI from the monthly sequential testing to testing each channel every four months (triannual) on a staggered testing basis. This resulted in the issuance of CE NPSD-576, "RPS/ESFAS Extended Test Intenal Evaluation for 120 Day Staggered Testing" in April,1990.
l The information contained in CE NPSD-576 is derived from a re-evaluation of the RPS and ESFAS fault tree models developed for and presented in CEN-327. CE NPSD-576 compares its results with those presented in CEN-327 and its supplement. The system unavailabilities
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are evaluated for the RPS on a plant-by-plant, trip parameter-by-trip parameter basis, and for l
the ESFAS on a plant-by-plant, signal-by-signal basis. In each case, for the ANO-2 design, i
the percent change in unavailabilities that results from extending the STI from monthly sequential testing to the triannual staggered testing is less than the unavailabilities for the extended surveillance intenal addressed in CEN-327 and its supplement. This is because the dominant contributors to plant unavailability are common cause failures. These failures would l
be detected sooner by the testing of one channel per month (staggered testing) than by testing all channels every three months (sequential testing).
The RPS unavailabilities for the triannual staggered testing should be acceptable as they are lower than the RPS unavailabilities for a ninety day test interval with sequential testing which have been found to be acceptable by the NRC.
CE has performed the required setpoint drift analysis with an ANO review and approval of the analysis. ANO Calculation 92-E-0084-01, " Plant Protection System Bistable Drift Analysis" was issued in June 1993. The calculation analyzed the effect on instrument uncertainties of extending the Plant Protection System (PPS) Functional STI from monthly to triannual. It was determined via rt #v of the PPS channels that the only components requiring analysis were the RPS and ES:.u bistables and the variable setpoint cards. The input to the analysis was three years (1989-1992) of as-found and as-left PPS functional test data. The results demonstrated that the observed changes in instrument uncertainties for the extended STI do not exceed the current monthly setpoint assumptions. ANO has reviewed the instrument uncertainty information for each channel invc!ved and has determined that the drift occurring in that channel over the triannual period would not cause the setpoint value to exceed the allowable value. It is, therefore, unnecessary to change any setpoints to accommodate the proposed extended STI.
BACKGROUND FOR CYCLE INDEPENDENT SHAPE ANNEALING MATRIX The Core Protection Calculators (CPCs) rely upon the excore detector signals to trip the reactor to ensure the specified acceptable fuel design limits on minimum departure from nucleate boiling ratio and peak linear heat rate are not violated in the event of an anticipated operational occurrence. To do this, es :h CPC channel synthesizes the excore core average axial power shape from three levels of axcore detector signals. It is desired that the excore detectors read only their particular level af the core. However, they are far enough away from
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Page 4 of 9 the core to be exposed by flux from all heights in the core. The excore detector signals are subsequently adjusted within the CPCs by a set of channel dependent shape annealing constants to adjust for this flux overlap. Although the excore signals are also used for average core power indication, the Shape Annealing Matrix (SAM) elements primary role is in the determination of the axial power shape in the core.
Technical Specification (TS) Table 43-1 Note 5 requires a determination of the SAM constants from the incore measurements after each refueling and before exceeding 70%
power. The current method for the determination of the cycle specific SAM constants requires recording the incore and excore signal data at regular intervals during the initial power ascension following refueling. The incore data is subsequently processed through a computer code to determine the relative power at the core periphery. An automated data reduction code is then used to verify the data, calculate the SAM constants, and determine whether the measured SAM meets a set of review and acceptance criteria to justify its implementation in the CPC channels. However, since the cycle specific SAM is only measured once during the reload startup, it has been observed to be less accurate as the cycle progresses and the power shape evolves from a flattened cosine to a saddle shape.
The Combustion Engineering Owners Group (CEOG) contracted Combustion Engineering (CE) to review the methodology used in the generation of these constants to determine if any improvements could be made. A review of the data from past cycle SAM elements found that they would have been acceptable for other cycles, even in other units. This review concluded that the SAM elements are not reload dependent. The use of Cycle Independent Shape Annealing Matrix (CISAM) elements should be more representative of the entire cycle than the beginning of cycle SAM elements that are currently in use.
The CISAM elements will be based on measured data from one or more previous cycles. This data will typically be from middle of cycle measurements. The measured data will be used to determine CISAM elements that produce the best results for the entire cycle. The CISAM will result in better fidelity of the axial power shapes in the latter parts of the fuel cycle than that obtainable with the SAM from our current method. The CISAM will be verified for each cycle during the initial power ascension following refueling, as required by the proposed changes to TS > Table 4.3-1 Note 5, and monitored throughout the cycle for proper performance.
The CISAM performance will be monitored throughout the cycle on a frequency of ap;;roximately every 90 Effective Full Power Days (EFPD).
The CISAM elements will be validated during startup testing by monitoring the same parameters used for the cycle specific SAM elements. The cycle specific acceptance criteria will be expanded to include additional CISAM acceptance criteria.
If the CISAM is determined to be ne longer valid, a cycle-specific SAM will be calculated and used in the i
CPCs until the circumstances allow for the remeasurement or reanalysis of the CISAM.
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.D_lSCUSSION OF PROPOSED CHANGES The following proposed changes were made to Table 4.3-1:
- 1. The monthly (M) Channel Functional Testing requirement was changed to triannual (TA) for all functional units except for the reactor trip breakers. The TA surveillance frequency is defined in Table 1.2 as "At least once per 123 days." The TA testing requirement is modified by ' Note 10 requiring the Channel Functional testing to be performed on a staggered test basis. The Bases for this Specification was also modified to reflect this change. These changes are consistent with the changes proposed by CEN-327, its Supplement, and CE NPSD-576 as discussed in the background section.
- 2. The weekly Core Protection Calculator (CPC) addressable constant Channel Check requirement was removed. Note 9 was modified to require the addressable constant verification to be performed as part of the Channel Functional test. Requiring the addressable constant verification to be performed as part of the CPC channel functional test will allow detection of potential errors in these constants prior to restoring the channel to operable status and allowing the error to go undetected until the next surveillance period. With the exception of the addressable constants associated with the excore instrument calibrations, the bulk of the addressable constant changes are associated with core reloads. Since these constants are infrequently changed, and the periodic verification of these constants is prudent, the frequency of TA is appropriate.-
The inclusion of the addressable constant check as part of the channel functional test is 4
consistent with NUREG-1432, " Standard Technical Specifications Combustion Engineering Plants" (ISTS). ANO-2 has previously committed to implementation of the ISTS.
- 3. Note 5 was modified to allow a " verification" of the shape annealing matrix elements used in the CPCs. This change will allow the use of Cycle Independent Shape Annealing
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Matrix (CISAM) in the CPCs as discussed in the background section.
The monthly (M) Channel Functional testing tequirement on Table 4.3-2 was changed to TA and modified by Note 2 requiring the testing to be performed on a staggered test basis. The TA surveillance frequency is defined in Table 1.2 as "At least once per 123 days." The Note I requirement to manually test the actuation logic for the functional units was changed from 31 to 123 days to reflect the TA frequency. The bases for this TS was also modified to reflect these changes.
These changes are consistent with those proposed by CEN-327, its Supplement, and CE NPSD-576 as discussed in the background section.
The following administrative changes to the TS were made:
1.
Table 1.2 was modified by adding a new surveillance frequency notation of triannual (TA) with a frequency of"At least once per 123 days." The triannual term is derived from the frequency of every 4 months or three times a year. The number of days was derived from adding up the total number of days from the longest four sequential l
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calendar months. The change to this table was needed to support the frequency changes associated with TS 3/4.3.1 and 3/4.3.2.
2.
Action 2 on Table 3.3-1 and Action 10 on Table 3.3-3 were modified to reference the QA Manual Operations.
Specification 6.5.1.7.n was removed from the TS by Amendment 160, which relocated this requirement to the QA Manual Operations.
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Minor formatting changes were made to Table 4.3-1 to make the data in the Channel Functional tests column more closely match the Channel Calibration column by placing one requirement per line for human factors considerations.
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The proposed changes to Table 3.3-3, functional unit 6.a were made to more accuiately reflect the design of the Recirculation Actuation System (RAS). The changes listed below for this table are not due to a change in the plant design or operation, but simply a correction to the table. The RAS does not have remote manual trip buttons like all the other functional units on this table. This design feature appears to have been implemented to reduce the' probability of an inadvertent manual RAS due to its safety consequences. This difference is described in Note (c) for functional unit 6.a. As stated in the note, the manual trip buttons for RAS are located in the Auxiliary Relay Cabinets (ARCS). There are two ARCS, with a set of 2 manual i
trip buttons per ARC, for a total of four manual trip buttons for RAS.
The simultaneous operation of both buttons on an ARC will result in the actuation of a 1
single train of RAS. The operation of all four manual trip buttons in the ARCS is required to initiate a full RAS actuation. The changes to functional unit 6.a are i
described below.
a.
In the Total No. Of Channels column, for all the other manual trip functional units on this table, the number of channels listed is the total number of manual trip buttons that are installed. For RAS, the "2 sets of 2" is accurate because there is a set of two buttons installed in each of the two ARCS for a total of four buttons.
b.
In the Channels To Trip column, for all the previous manual trip functional units on this table, the number of channels listed in this column is the number of buttons required to be operated to initiate a full actuation of the functional unit. For RAS, the simultaneous operation of both buttons on an ARC will result in the actuation of a single train of RAS, but a full actuation will not occur until all four buttons on the ARCS are actuated. Therefore, for a full RAS actuation, it requires operation of"2 sets of 2" manual trip buttons.
c.
In the Minimum Channels Operable column, for all the previous manual trip functional units on this table, the number of channels listed in this column is the total number of buttons installed. The total number of RAS buttons installed is "2 sets of 2" or four buttons.
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The proposed changes to Table 3.3-3, functional unit 8.a are proposed to correct the designation of manual trip buttons to manual trip switches and to consistently reflect the number of switches required to be operated to get a full actuation. These changes are not due to a modification to the plant design or operation, but simply corrections
.to this table to make it reflect the as-built configuration of this system.
The Emergency Feedwater Actuation System (EFAS) has four remote manual trip switches a
per steam generator (S/G). All four switches are required to be operated to mac.ually initiate a full L5AS actuation for that S/G. In the Channels To Trip column, for all the functional units (including RAS with the proposed change described above), the number of channels listed in the column, are the number of buttons or switches required to get a full actuation of the function. The number of trip switches that are
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required to be operated, to get a full actuation on EFAS, is "2 sets of 2 per S/G."
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Note (a) was added to Table 4.3-2 Functional Unit 6.s, to indicsie the manual trip buttons are the local buttons on the Auxiliary Relay Cabinets (ARCS). This note was copied from Table 3.3-3 Note (c) for consistency. Functional unit 8.a was also modified to correct the designation of manual trip " buttons" to manual trip " switches."
i DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION The proposed changes included in this amendment request are broken down into the following i
categories; RPS/ESFAS extended testing interval from monthly to triannual, changing the Core Protection Calculator (CPC) addressable constant surveillance requirement from weekly to triannual with the channel calibration, allowing the use of the Cycle Independent Shape Annealing Matrix (CISAM) elements, and various administrative changes.
i An evaluation of the proposed change has been performed in accordance with 10 CFR 50.91(a)(1) regarding no significant hazards considerations using the s.andards in 10 CFR 4
50.92(c). A discussion of these standards as they relate to this amendment request follows:
Criterion 1 - Does Not Involve a Significant Increase in the Probability or i
Consequences of an Accident Previously Evaluated.
The proposed changes included in this amendment request are being made to surveillance intervals, allowances to use CISAM elements and various administrative changes. These changes do not alter the functional characteristics of any plant component and do not allow l
any new modes of operation of any component. These changes do not involve a significant increase in the probability of any event initiator to occur. Therefore, this amendment request does not involve a significant increase in the probability of any accident previously evaluated.
I Increasing the surveillance interval for the RPS and ESFAS instrumentation has two principal effects with opposing impacts on risk. The first impact is a slight increase in core damage frequency that results from the increased unavailability of the instrumentation in question from the extended testing interval. The unavailability of the tested instrumentation components is translated to result in a failure of the reactor to trip, an anticipated transient without a scram, 1
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or a failure of the appropriate engineered safety feature to actuate when required. The opposing impact on risk is the corresponding reduction in core damage frequency that would i
result due to the reduced exposure of the plant to test induced transients.
Representative fault tree models were developed for ANO-2 and the corresponding core damage frequency increases and decreases were quantified in CEN-327 and CEN-327 Supplement 1. The NRC staff found that changes in the RPS unavailabilities that result from extending the surveillance test interval (STI) from 30 days to 90 days were not considered to be significant. Estimates of the reduction in scram frequency from the reduction in test induced scrams and the corresponding reduction in core damage frequency were found acceptable. Sequential testing intervals of 90 days were found to result in a net reduction in risk.
CE NPSD-576 employed the same methodology used in CEN-327 and its supplement to evaluate the impact of extending the surveillance intervals from monthly sequential testing to every four months (triannual) on a staggered test basis. The corresponding changes in RPS and ESFAS unavailabilities are quantified in CE NPSD-576 and are shown to be less than their counterparts in CEN-327 and its supplement. Thus, triannual staggered testing should be acceptable as it results in lower RPS and ESFAS unavailabilities than for a 90 day test interval with sequential testing which has been found to be acceptable to the NRC.
The TS amendment request provides the option to use cycle independent shape annealing matrix (CISAM) elements. The CISAM elements will be validated during startup testing and will be required to meet additional acceptance criteria as well as that used for the cycle specific shape annealing matrix (SAM) elements. If the CISAM is determined to be no longer valid, a cycle specific SAM will be calcula:ed and used in the CPCs. Therefore, the CPCs will operate as designed and this change will not affect the consequences of any accident previously evaluated.
l The CPC addressable constant surveillance requirements and the various administrative changes affected by this TS change do not affect the consequences of any accident previously evaluated.
Therefore, these changes do not involve a significant increase in the probability or consequences of any accident previously evaluated.
Criterion 2 - Does Not Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated.
This amendment request does not involve any changes in equipment and will not alter the manner in which the plant will be operated. Therefore, these changes do not create the possibility of a new or different kind of accident from any previously evaluated.
Attachment to 2CAN109603 Page 9 of 9 Criterion 3 - Does Not Involve a Significant Reduction in the Margin of Safety.
The RPS/ESFAS extended testing interval yields no significant reduction in the margin to safety. The instrument drift occurring over the proposed STI will not cause the setpoint values to exceed those assumed in the safety analysis and specified in the TS. There are no changes to equipment or plant operations that will result from this change.
The implementation of these proposed changes is expected to result in an overall improvement in safety due to the fact that reduced testing will result in fewer inadvertent trips, less frequent actuations of EFAS components, and less frequent distraction of the operations personnel.
The CPC addressable constant surveillance interval extension included in this amendment request is consistent with the methodology found in NUREG-1432, " Standard Technical Specifications Combustion Engineering Plants" (ISTS). Requiring the addressable constant verification to be performed as part of the CPC channel functional test should detect an error in these constants prior to restoring the channel to operable status instead of allowing the error to go undetected until the next surveillance period. Although the surveillance interval is extended by this TS change, this change does n_giinvolve a significant reduction in the margin ofsafety.
The CPC CISAM elements and the various administrative changes included in this TS change do not involve a significant reduction in the margin of safety.
Therefore, these changes do nel involve a significant reduction in the margin of safety.
l Therefore, based upon the reasoning presented above and the previous discussion of the j
l amendment request, Entergy Operations has determined that the requested change does not involve a significant hazards consideration.
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