L-MT-05-072, License Amendment Request: Monticello Nuclear Generating Plant Conversion of Current Technical Specifications (CTS) to Improved Technical Specifications (ITS)
| ML051960175 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 06/29/2005 |
| From: | Thomas J. Palmisano Nuclear Management Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-MT-05-072 | |
| Download: ML051960175 (14) | |
Text
-4 PI' N IJ o~ Monticello Nuclear Generating Plant Committed to Nuclear ExceMlv Operated by Nuclear Management Company, LLC June 29, 2005 L-MT-05-072 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Monticello Nuclear Generating Plant Docket 50-263 License No. DPR-22 License Amendment Request: Conversion of Current Technical Specifications (CTS) to Improved Technical Specifications (ITS)
Pursuant to 10 CFR 50.90, the Nuclear Management Company, LLC (NMC) proposes to amend the Monticello Nuclear Generating Plant licensing basis and Technical Specifications. NMC proposes to revise the CTS to the ITS consistent with Improved Standard Technical Specifications (ISTS) as described in NUREG-1433, "Standard Technical Specifications General Electric Plants BWR/4," Revision 3, and certain generic changes to the NUREG. The guidance of NEI 96-06, "Improved Technical Specifications Conversion Guidance," dated August 1996, and Nuclear Regulatory Commission (NRC) Administrative Letter 96-04, "Efficient Adoption of Improved Standard Technical Specifications," dated October 9,1996, were used in preparing this submittal.
The detailed descriptions and justifications to support the proposed changes are provided in the volumes attached to this letter (Attachment 1). NMC has evaluated this proposed change in accordance with 10 CFR 50.91 (a)(1) using the criteria of 10 CFR 50.92(c), and has determined that this change does not involve a significant hazards consideration. In addition, NMC has determined that the proposed license amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(b), and no environmental impact statement or environmental assessment need be prepared in connection with the proposed license amendment. The determination of no significant hazards consideration and environmental assessment are also included in Attachment 1.
2807 West County Road 75 . Monticello, Minnesota 55362-9637 Telephone: 763.295.5151 . Fax: 763.295.1454
Document Control Desk Page 2 The following enclosures are also included to assist the NRC in the review of this submittal:
Enclosure 1, "Contents of the Monticello Nuclear Generating Plant Improved Technical Specifications (ITS) Submittal," describes the organization and content of the submittal, including each of the volumes in Attachment 1.
Enclosure 2, uBeyond Scope Changes," provides a list and description of the changes included in the ITS submittal that are beyond the scope of the ISTS as described in NUREG 1433, Revision 3, and also beyond the scope of the CTS.
Enclosure 3, Disposition of Generic Changes to NUREG-1433, Revision 3," lists the NRC approved changes to NUREG-1433, Revision 3, as of April 1,2005, and summarizes the disposition of each of these changes in the Monticello Nuclear Generating Plant license amendment request. The enclosure also lists other generic changes to NUREG-1433, Revision 3, being included in this license amendment request, which are currently under review by the NRC.
Enclosure 4, "Disposition of Existing License Amendment Requests," provides the disposition of other, currently docketed license amendment requests, as they relate to this license amendment request.
NMC requests approval of the proposed license amendment before February 28, 2006, with an implementation period of at least 180 days, to support implementation of the ITS by the end of August 2006. After approval of the proposed license amendment, NMC will notify the NRC when ITS implementation actions are completed.
This letter makes no new commitments or changes to any existing commitments.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on June 29, 2005 Thomas J. Palmisano Site Vice President, Monticello Nuclear Generating Plant Nuclear Management Company, LLC
Document Control Desk Page 3 Enclosures (4)
Attachment:
ITS Submittal, Volumes 1 through 18 cc (w/o enclosures and attachment):
Administrator, Region Ill, USNRC, Project Manager, Monticello, USNRC Resident Inspector, Monticello, USNRC Minnesota Department of Commerce
ENCLOSURE I CONTENTS OF THE MONTICELLO NUCLEAR GENERATING PLANT (MNGP)
IMPROVED TECHNICAL SPECIFICATIONS (ITS) SUBMITTAL The submittal for the conversion of the current Technical Specifications (CTS) to the ITS for MNGP consists of the submittal letter with four enclosures and one attachment that includes the following eighteen volumes:
Volume Title 1 Application of Selection Criteria to the Monticello Nuclear Generating Plant Technical Specifications 2 Generic Determination of No Significant Hazards Considerations and Environmental Assessment 3 ITS Chapter 1.0, Use and Application 4 ITS Chapter 2.0, Safety Limits 5 ITS Section 3.0, Limiting Condition for Operation (LCO)
Applicability and Surveillance Requirement (SR) Applicability 6 ITS Section 3.1, Reactivity Control Systems 7 ITS Section 3.2, Power Distribution Limits 8 ITS Section 3.3, Instrumentation 9 ITS Section 3.4, Reactor Coolant System 10 ITS Section 3.5, Emergency Core Cooling Systems (ECCS) 11 ITS Section 3.6, Containment Systems 12 ITS Section 3.7, Plant Systems 13 ITS Section 3.8, Electrical Power Systems 14 ITS Section 3.9, Refueling Operations 15 ITS Section 3.10, Special Operations 16 ITS .Chapter 4.0, Design Features 17 ITS Chapter 5.0, Administrative Controls 18 CTS Markup Pages in CTS Order Volumes I and 18 are provided to assist the Nuclear Regulatory Commission (NRC) in the review and approval of Volumes 2 through 17. Below is a brief description of the content of each of the volumes in this submittal.
Volume 1 Volume 1 provides details concerning the application of the selection criteria to the individual MNGP CTS. Each CTS Specification is evaluated, and a determination is made as to whether or not the CTS Specification meets the criteria in 10 CFR 50.36(c)(2)(ii) for retention in the proposed ITS.-
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ENCLOSURE 1 Volume 2 This volume contains the majority of the evaluations required by 10 CFR 50.91(a),
which support a finding of No Significant Hazards Consideration (NSHC). Based on the inherent similarities in the NSHC evaluations, generic evaluations for a finding of NSHC have been written for the following categories of CTS changes:
Administrative Changes More Restrictive Changes Relocated Specifications Removed Detail Changes Less Restrictive Changes - Category 1 - Relaxation of LCO Requirement Less Restrictive Changes - Category 2 - Relaxation of Applicability Less Restrictive Changes - Category 3 - Relaxation of Completion Time Less Restrictive Changes - Category 4 - Relaxation of Required Action Less Restrictive Changes - Category 5 - Deletion of Surveillance Requirement Less Restrictive Changes - Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria Less Restrictive Changes - Category 7 - Relaxation of Surveillance Frequency, Non-24 Month Type Change Less Restrictive Changes - Category 8 - Deletion of Reporting Requirement Less Restrictive Changes - Category 9 - Deletion of Surveillance Requirement Shutdown Performance Requirements Less Restrictive Changes - Category 10 - Changing Instrumentation Allowable Values For those less restrictive changes that do not fall into one of the generic Less Restrictive Changes categories, a specific NSHC evaluation has been performed and is provided in the applicable Chapter, Section, or Specification in Volumes 3 through 17.
In addition, Volume 2 contains an evaluation of environmental consideration in accordance with 10 CFR 51.21. It has been determined that the proposed license amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(b), and n6environmental impact statement or environmental assessment need be prepared in connection with the proposed license amendment.
Volumes 3 through 17 Volumes 3 through 17 provide the details and safety analyses to support the proposed changes. Each of these volumes corresponds to a Chapter, Section, or Specification of NUREG-1433, Revision 3. Each volume contains the required information to review the conversion to ITS, and includes the following:
- Individual ITS Specifications in ITS Chapter (Volumes 3, 4, and 16), Section (Volume 5), or Specification (Volumes 6 through 15 and 17) order;
- Relocated/Deleted CTS Specifications (if applicable); and Page 2 of 5
ENCLOSURE I
The information for each of the above three types of specifications is organized as follows:
CTS Markup and Discussion of Changes (DOCs) (applicable only to Individual ITS Specifications and Relocated/Deleted CTS Specifications)
This section contains a markup of the CTS pages, either for CTS pages associated with an Individual ITS Specification or for Relocated/Deleted CTS Specifications, and the DOCs from the CTS. CTS license amendment requests under NRC review that have been docketed as of June 29, 2005 have been incorporated in the proposed changes as described in Enclosure 4 of this submittal.
The CTS markup pages for each ITS Specification are normally in numerical order.
However, more than one CTS Specification is sometimes used in the generation of an ITS Specification. In this case, the CTS pages that are the major contributor to the ITS Specification are shown first, followed by the remaining associated CTS pages in numerical order.
The left-hand margin of the CTS markup pages (both halves of page if applicable) includes a cross-reference to the equivalent ITS requirement. The upper right-hand corner of the CTS markup pages is annotated with the ITS Specification number to which it applies. Items on the CTS markup pages that are addressed in other proposed ITS Chapters, Sections, or Specifications are annotated with a reference to the appropriate ITS Chapter, Section, or Specification.
The CTS markup pages are annotated with an alphanumeric designator to identify the differences between the CTS and the proposed ITS. The designator corresponds to a DOC, which provides the description and justification of the change. The DOCs are located directly following the associated CTS markup for each Chapter or Section (Volumes 3, 4, 5, and 16) or each Specification (Volumes 6 through 15 and 17).
Each proposed change to the CTS is classified into one of the following categories:
Designator Category A ADMINISTRATIVE CHANGES - Changes to the CTS that do not result in new requirements or change operational restrictions or flexibility. These changes are supported in aggregate by a single generic NSHC.
M MORE RESTRICTIVE CHANGES - Changes to the CTS that result in added restrictions or reduced flexibility. These changes are supported in aggregate by a single generic NSHC.
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ENCLOSURE 1 R RELOCATED SPECIFICATIONS - Changes to the CTS that relocate specifications that do not meet the selection criteria of 10 CFR 50.36(c)(2)(ii). These changes are supported in aggregate by a single generic NSHC.
LA REMOVED DETAIL CHANGES - Changes to the CTS that eliminate detail and relocate the detail to a licensee-controlled document. Typically, this involves details of system design and function, or procedural detail on methods of conducting a Surveillance Requirement. These changes are supported in aggregate by a single generic NSHC. In addition, the generic type of removed detail change is identified in italics at the beginning of the DOC.
L LESS RESTRICTIVE CHANGES - Changes to the CTS that result in reduced restrictions or added flexibility. These changes are supported either in aggregate by a generic NSHC that addresses a particular category of less restrictive change, or by a specific NSHC if the change does not fall into one of the fourteen categories of less restrictive changes. If the less restrictive change is covered by a generic NSHC, the category of the change is identified in italics at the beginning of the DOC.
The DOCs are numbered sequentially within each letter designator for each ITS Chapter, Section, or Specification.
The CTS Bases pages are replaced in their entirety by the proposed MNGP ITS Bases, and markup pages are not provided inthe ITS submittal.
ISTS Markup and Justification for Deviations (JFDs) (applicable only to Individual ITS Specifications and ISTS Specifications not adopted in the MNGP ITS)
This section contains a markup of the NUREG-1433, Revision 3, ISTS pages, either for ISTS pages associated with an Individual ITS Specification or ISTS Specifications not adopted in the MNGP ITS, and JFDs from the ISTS. The ISTS pages are annotated with a numeric designator to identify the differences between the ISTS and the proposed ITS. The designator corresponds to a JFD, which provides the justification for the difference. The JFDs are located directly following the associated ISTS markup for each Chapter or Section (Volumes 3, 4, 5, and 16) or each Specification (Volumes 6 through 15 and 17). The ISTS markup pages are also annotated to show the incorporation of NRC-approved generic changes (Technical Specification Task Force (TSTF) change travelers) that are applicable to the MNGP ITS.
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ENCLOSURE I The left-hand margin of the ISTS markup pages includes a cross-reference to the equivalent CTS requirement.
ISTS Bases Markup and JFDs (applicable only to Individual ITS Specifications and ISTS Specifications not adopted in the MNGP ITS)
This section contains a markup of the NUREG-1433, Revision 3, ISTS Bases pages, either for ISTS Bases pages associated with an Individual ITS Specification or ISTS Specifications not adopted in the MNGP, and JFDs from the ISTS Bases. The ISTS Bases pages are annotated with a numeric designator to identify the differences between the ISTS Bases and the proposed ITS Bases. The designator corresponds to a JFD, which provides the justification for the difference. The JFDs are located directly following the associated ISTS Bases markup for each Chapter or Section (Volumes 3, 4, 5, and 16) or each Specification (Volumes 6 through 15 and 17). The ISTS Bases markup pages are also annotated to show the incorporation of NRC-approved generic changes (TSTF change travelers) that are applicable to the Monticello Nuclear Generating Plant ITS Bases. The volumes for ITS Chapters 1.0, 4.0, and 5.0 do not include this section, because NUREG-1433, Revision 3, does not include any Bases for these Chapters.
Determination of NSHC (applicable only to Individual ITS Specifications and Relocated/Deleted CTS Specifications)
This section contains the determination in accordance with 10 CFR 50.91 (a)(1) using the criteria of 10 CFR 50.92(c) to support a finding of NSHC. For those changes covered by a generic NSHC, those generic NSHCs are located inVolume 2. For those less restrictive changes that do not fall into one of the generic less restrictive categories, a specific NSHC evaluation has been performed. Each evaluation is annotated to correspond to the DOC discussed in the NSHC. For those ITS Chapters, Sections, or Specifications for which the less restrictive DOCs all fall into a generic category, a statement that there are no specific NSHCs is provided.
Volume 18 Volume 18 contain copies (from Volumes 3 through 17) of the MNGP CTS markup pages that have been annotated to show the differences between the CTS and the proposed ITS. This volume is organized in CTS page order, and have been prepared to facilitate NRC review efforts. They also demonstrates that all CTS requirements have been appropriately dispositioned. In some instances, the same CTS page is used in different ITS Chapters, Sections, or Specifications. Consequently, the CTS markup pages that are included in more than one ITS Chapter, Section, or Specification will appear in the order in which the CTS markup pages appear in Volumes 3 through 17.
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ENCLOSURE2 BEYOND SCOPE CHANGES Beyond Scope Changes are those changes included in the Improved Technical Specifications (ITS) conversion submittal that are beyond the scope of the Improved Standard Technical Specifications (ISTS) as described in NUREG-1433, Revision 3, and also beyond the scope of the Monticello Nuclear Generating Plant (MNGP) current Technical Specifications (CTS). The following is a list of the discussions of changes (DOCs) in Attachment 1 that are Beyond Scope Changes in the MNGP ITS conversion submittal.
- 1) The following Allowable Value changes are the result of applying the current setpoint methodology for MNGP:
a) ITS 3.3.1.1, L.12: CTS 3.1.A refers to the "setpoints" of the RPS Instrumentation Functions in CTS Table 3.1.1 and CTS Table 3.1.1 specifies the "Limiting Trip Settings" for the RPS Instrumentation Functions. The Limiting Trip Setting of CTS Table 3.1.1 Trip Functions 3.a, 4.a, and 4.c have been modified to reflect new less restrictive Allowable Values as indicated for ITS Table 3.3.1.1-1 Functions 1.a and 2.a.
b) ITS 3.3.4.1, DOC L.4: CTS Table 3.2.5 specifies the "Trip Setting" for the ATWS-RPT High Reactor Dome Pressure Function. The Trip Setting of CTS Table 3.2.5 Function 1 has been modified to reflect the new less restrictive Allowable Value as indicated in ITS SR 3.3.4.1.5.b.
c) ITS 3.3.5.1, DOC*M.8: CTS Table 3.2.2 specifies the "Trip Setting" for the ECCS instrumentation Functions. The Trip Settings of CTS Table 3.2.2 Function C.3 has been modified to reflect new more restrictive Allowable Values as indicated for ITS Table 3.3.5.1-1 Functions 4.c, 4.d, 5.c, and 5.d.
d) ITS 3.3.5.1, DOC L.5: CTS Table 3.2.2 and Table 3.2.8 specify the "Trip Setting" for the ECCS instrumentation Functions. The Trip Settings of CTS Table 3.2.2 Functions A.1.b.i and A.2 and Table 3.2.8 Function C.1 have been modified to reflect new less restrictive Allowable Values as indicated for ITS Table 3.3.5.1-1 Functions 1.c, 1.d, 2.c, 2.d, and 3.d. In addition, the Allowable Value for ITS Table 3.3.5.1-1 Function 3.d only specifies a single Allowable Value, which is applicable for both one tank and two tank operations.
e) ITS 3.3.5.2, DOC L.3: CTS Table 3.2.8 specifies the "Trip Setting" for the Condensate Storage Tank Level - Low for two tank and one tank operations.
The Trip Settings of CTS Table 3.2.8 Function C.1 have been modified to reflect a new less restrictive Allowable Value as indicated for ITS Table 3.3.5.2-1 Function 3. In addition, the Allowable Value for this Function Page 1 of 3
ENCLOSURE 2 only specifies a single Allowable Value, which is applicable for both one tank and two tank operations.
f) ITS 3.3.6.1, DOC M.9: CTS Table 3.2.1 specifies the "Trip Settings" for the primary containment isolation instrumentation. The "Trip Settings" of CTS Table 3.2.1 Functions 3.d, 4.a, 4.b, 4.c, and 5.b have been modified to reflect new more restrictive Allowable Values as indicated in ITS Table 3.3.6.1-1 Functions 3.a, 3.b, 3.c, 4.c, and 5.a.
g) ITS 3.3.6.1, DOC L.9: CTS Table 3.2.1 specifies the "Trip Settings" for the primary containment isolation instrumentation. The "Trip Settings" of CTS Table 3.2.1 Functions 1.b, 1.d, 5.a, 5.c, and 6.a have been modified to reflect new less restrictive Allowable Values as indicated in ITS Table 3.3.6.1-1 Functions 1.b, 1.c, 4.a, 4.b, and 6.a.
h) ITS 3.3.8.1, DOC M.3: CTS Table 3.2.6 specifies the "Trip Setting" for the LOP Instrumentation. The Trip Settings of CTS Table 3.2.6 Function 1 have been modified to reflect new more restrictive Allowable Values as indicated for ITS Table 3.3.8.1-1 Functions 2.a and 2.b.
- 2) ITS 3.3.1.1, DOC L.14: CTS Table 4.1.1 requires a weekly functional test of the Manual Scram Function. ITS Table 3.3.1.1-1 Function 11 and ITS SR 3.3.1.1.5 requires the performance of the same test at a 31 day Frequency. This changes the CTS by extending the Manual Scram functional test Frequency from 7 days to 31 days.
- 3) ITS 3.3.2.1, DOC L.5: CTS 3.2.C.2.b states that the Rod Block Monitor (RBM) bypass time delay must be less than or equal to 2.0 seconds. ITS 3.3.2.1 does not require the RBM bypass time delay to be OPERABLE. This changes the CTS by deleting the RBM bypass time delay requirements.
- 4) ITS 3.3.3.1, DOC L.2: CTS 4.14 does not provide a delayed entry into associated Conditions and Required Actions if a PAM channel is inoperable solely for performance of required Surveillances. ITS Surveillance Requirements Note 2 has been added to allow delayed entry into associated Conditions and Required Actions for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> if a PAM channel is placed in an inoperable status solely for performance of required Surveillances provided the associated Function maintains capability. This changes the CTS by providing a delay time to enter Conditions and Required Actions for a PAM channel placed in an inoperable status solely for performance of required Surveillances.
- 5) ITS 3.3.8.2, DOC M.3: CTS 4.1.C.2 requires an instrument calibration of each RPS power monitoring channel every "Operating Cycle." ITS SR 3.3.8.2.2 requires the performance of a CHANNEL CALIBRATION of the overvoltage, undervoltage, and underfrequency setpoints every 184 days. This changes the Page 2 of 3
ENCLOSURE 2 CTS increasing the frequency of performing a CHANNEL CALIBRATION of the overvoltage, undervoltage, and underfrequency setpoints.
- 6) ITS 3.4.1, DOC M.A: CTS 4.5.F.1 provides a cross reference to the Surveillance Requirements in CTS 4.6.G. However, these Surveillances are jet pump Surveillances and do not cover stability monitoring issues. ITS SR 3.4.1.2 requires verification that either operation is inthe Normal Region of the power to flow map every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or operation is in the Stability Buffer Region of the power to flow map and the power distribution controls specified in the COLR are in effect every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This changes the CTS by deleting the cross references to the Surveillance requirements in CTS 4.6.G and adds a new Surveillance Requirement.
- 7) ITS 5.5, DOC L.4: CTS 6.8.B includes the Primary Coolant Sources Outside Containment program requirements. The Combustible Gas Control System is included in this program. ITS 5.5.2 includes the same program requirements for the Primary Coolant Sources Outside Containment Program, except the Combustible Gas Control System is not included in the program. This changes the CTS by deleting the program requirement for the Combustible Gas Control System in the Primary Coolant Sources Outside Containment Program.
- 8) ITS 5.5, DOC L.5: CTS 6.8.B.2 specifies that the integrated leak test requirements for each system outside containment that could contain highly radioactive fluids during a serious transient or accident must be performed at a refueling cycle interval or less. CTS 6.8.B also states that CTS 4.0.B is applicable (i.e., a 25% grace period is allowed). ITS 5.5.2.b specifies that the same test must be performed at least once per 24 months and ITS 5.5.2 states that the provisions of ITS SR 3.0.2 are applicable. This changes the CTS by extending the Frequency of the Surveillance from 18 months (i.e., the current MNGP frequency for this test, based on the previous refueling outage interval) to 24 months (i.e., a maximum of 30 months accounting for the allowable grace period specified in ITS SR 3.0.2).
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ENCLOSURE 3 DISPOSITION OF GENERIC CHANGES TO NUREG-1433, REVISION 3 The following Nuclear Regulatory Commission (NRC)-approved (as of April 1, 2005)
Technical Specification Task Force (TSTF) changes are adopted in whole or in part in the Monticello Nuclear Generating Plant (MNGP) Improved Technical Specifications (ITS) submittal:.
TSTF Affected ITS 369, Rev. 1 1.1, 3.3.3.1, 5.5, 5.6 460, Rev. 0 3.1.4 The following proposed TSTF changes have been included in the MNGP ITS submittal:
TSTF Affected ITS 455, Rev. 0 3.3.1.2 458, Rev. 0 3.6.2.1 464, Rev. 0 3.3.2.1 Page 1 of 1
II ENCLOSURE 4 DISPOSITION OF EXISTING LICENSE AMENDMENT REQUESTS Affected ITS Submittal Date Description of Change Sections/Specifications Affected CTS Pages Disposition 4/29/04 Nuclear Management ITS: 3.1.1, 3.1.3, 3.1.4, 59, 59a, 83a,166,167,169, Proposed changes and Company, LLC (NMC) to 3.1.5, 3.1.6, 3.1.8, 170,207, 229u, 229v, 229w are already reflected 4/12/05 Nuclear Regulatory 3.3.1.2, 3.3.6.2, in this ITS submittal.
Commission (NRC) Letter L- 3.6.1.3, 3.6.3.1, MT-04-023, "License 3.6.4.1, 3.6.4.2, Amendment Request: 3.6.4.3, 3.7.4, 3.7.5, Selective Scope Application of 3.7.8, 3.9.5, 5.5 an Alternative Source Term Methodology for Re-evaluation CTS: 3.10.D of the Fuel Handling Accident (TAC No. MC3299) and NMC to NRC Letter L-MT-05-013, "Additional Technical Specification Changes for the Monticello Nuclear Generating Plant Regarding Application of Alternative Source Term (AST)
Methodology to Re-Evaluate the Fuel-Handling Accident (TAC No. MC3299)"
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ENCLOSURE 4 Affected ITS Submittal Date Description of Change Sections/Specifications Affected CTS Pages Disposition 6/30/04 NMC to NRC Letter L-MT ITS: 1.0, 3.0, 3.3.2.1, 4, 25a, 49, 52, 60a, 60b, 61, Proposed changes 036, "License Amendment 3.3.4.1, 3.3.5.1, 62,63,102,105,127,129, are already reflected Request To Support 24-Month 3.3.5.2, 3.3.6.1, 131,132,156,167,168, 169, in this ITS submittal.
Fuel Cycles" (TAC MC3692) 3.3.6.2, 3.3.6.3, 203, 229w, 229x 3.3.7.1, 3.3.8.1, 3.4.3, 3.4.5, 3.5.1, 3.5.2, 3.5.3, 3.6.1.1, 3.6.1.5, 3.6.2.1, 3.6.2.2, 3.6.4.1, 3.6.4.2, 3.6.4.3, 3.7.4, 3.8.4, 3.8.6, 3.8.7, 3.10.1, 5.5 CTS: 3/4.6.H1-Page 2 of 2