ML17156A147

Safety Evaluation Supporting Amend 36 to License NPF-14

ML17156A147
Person / Time
Site:	Susquehanna
Issue date:	04/12/1985
From:	Office of Nuclear Reactor Regulation
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ML17156A145	List: ML17156A144 ML17156A147
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NUDOCS 8504250510
Download: ML17156A147 (14)

Text

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 O'R lg 585 SAFETY EVALUATION AMENDMENT NO.

TO NPF-14 SUSQUEHANNA STEAM ELECTRIC STATION UNIT 1 DOCKET NO. 50-387 Introduction The licensee in their letters dated May 18, 1984 September 7, 1984, September 20, 1984, March 11, 1985, March 13, 1984, and April 4, 1985 proposed changes to the Technical Specifications (TS) of the operating license for Susquehanna Steam Electric Station, Unit 1.

These changes will update the Unit 1 TS to reflect the Unit 2 TS as appropriate; additionally this amendment changes the required isolation times on the containment purge valves and removes the 505 blocking requirement.

Evaluation r '>

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age/Item 1-2/Definition 1.7 and 3/4 3-4/Footnote*:

The-licensee's proposed change to the definition of CORE ALTERATION has been used in older plant TS. 'It allows for the deletion of several footnotes and tends to simplify the TS without changing. the substance.

This change is acceptable.

2-4/Function Unit:

This change corrects a typographical error in the Drywell Pressure

- High setpoint and is therefore acceptable.

3/4 1-1/4.1. l.c, '3/4 1-3/3. 1.3.1.a.l.c:

The amount of time allowed to determine the shutdown margin has been increased from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for the case of a stuck rod.

It is not practical to determine the shutdown margin in 1

hour since core calculations must be performed by. General Electric.

In the event that a scram occurs in the presence of the stuck rod and another rod fails to insert, hot shutdown is assured.

Cold shutdown could be achieved for the next 18 or more hours due to the presence of xenon in the core.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is adequate time to insert the failed rod or to operate the standby liquid control system..

This change is, therefore, acceptable.

I 3/4 1-4/3.1.3.1.b.3, 3/4 1-4/Insert A, 3/4 1-5/4.1.3.1.4.b:

A statement, 3.1.3.1.b.3, has been added to assert that the provisions of Specifications 3.0.4 are not applicable.

Specification 3.0.4 would prohibit entry into Operational Condition 1 or 2 unless Specification 3.1.3.1 were satisfied without reliance on the action statements.

However, analysis of the limiting

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eactivity insertion event, the rod drop accident, has been performed under e assumption of up to eight inoperable rods.

Further, other specifications regarding shutdown margin and rod pattern controls must be met.

We thus con-clude that this change is acceptable.

85042505i0 8504i2 PDR ADOCK 05000387 p

PDR

Additional requirements, Specification 3.1.3.l.d and e have been inserted to

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provide requirements to be met by the scram discharge valves.

This change is being'ade to correct'an oversight in the Specification and is acceptable.

3/4 1-6/New action b, and Footnote*, 3/4 1-8/New action b, 3/4 1-9, l-ll, 1-13/New action c:

In each of these TS the statement that "The requirements of Specification 3.0.4 are not applicable" has been added.

For the same reason stated above for page 1-2 this change is acceptable.

3/4 1-10/4.1.3.5.b.l.b:

The value of the control rod scram accumulator alarm setpoint on the accumulator pressure detector has been altered to permit any value greater than 940 psig.

This change is more conservative since the higher values give an earlier warning of trouble and is, therefore, acceptable.

3/4 3-7/all changes:

The. changes to this. page. were reviewed and found to be acceptable.

The changes reviewed were editorial in nature as they provide consistency within the TS to clarify original information that was awkward and subject to misinterpretation.

Additionally, these changes corrected some typographical errors.

3/4 3-8/Footnote g:

The specifi'cation currently reads "Verify measured core

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flow to be greater than or equal to established core flow at the existing pump speed."

The licensee has proposed to change "pump speed" to "loop flow."

This footnote applies to a surveillance requirement for the flow-biased Simu-lated Thermal Power Trip (STPT).

The logic for this system compares indicated core flow and neutron flux with prescribed setpoint values and 'generates a

scram signal when required.

The indicated core flow input to the STPT is based on measurements of recirculation loop flow which are adjusted by appropriate factors to indicate core flow.

The adjustment factors are based upon core flow/loop relationships determined during the startup test program and verified by this surveillance..

The current surveillance requires that core flow be compared with recirculation pump speed.

Since pump speed is related to loop flow, and loop flow to core flow, the APRM core flow/loop flow adjustment factors can be verified in this way.

The licensee has

proposed, however, the more direct verification of the APRM adjustment factors by comparison of loop flow with core flow.

We conclude that the use of a more direct measurement is a safety enhancement and is, there-fore, acceptable.

3/4 3-11 thru 3/4 3-26/all changes:

The changes on these pages have been reviewed along with the pertinent descriptions and justifications provided in the licensee's submittal and the applicable information in the FSAR.

These TS changes can be placed in one of the following categories:

to correct or clarify original information; to reflect the as built design of the plant or to provide sup-porting setpoint, response time and surveillance requirement information.

The

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NRC staff finds these changes acceptable.

3/4 3-28, 3/4 3-31, 3/4 3-34/Function 2C1 and 2C2:

This change adds a safety-related function to the table enhancing safe operation.

Additionally, the recirculation discharge valve closure which is essential to supporting LPCI injection as assumed in the FSAR analysis has been added.

This change is an improvement in the TS and, therefore, acceptable.

3/4 3-32/Function 5cb:

This change corrects an error in the TS, and is consistent with the Unit 2 TS.

The staff finds this change acceptable as it is a more restrictive requirement.

3/4 3-54/Function 3d, Footnote** and 3/4 3-74/Footnote***:

These changes are in response to recommendations provided by the staff and represent more conservative values.

The NRC staff therefore finds these changes acceptable.

3/4 3-55/Table 4.3.6-1:

The NRC staff finds the changes to the CHANNEL CHECK and CHANNEL FUNCTIONAL TEST to be acceptable but finds "the proposed changes to the CHANNEL CALIBRATION surveillance intervals to be unacceptable for those that are less conservative than the present requirement.

Therefore, the staff denies the requested changes to the channel calibration serveillance intervals which are less cqnservative and finds all others acceptable.

3/4 3-59/ACTION 71:

This additional control allows a portable monitor to replace an inoperable criticality monitor rather than performing daily surveys during fuel movements.

This more continuous protection not only enhances safe operation but is consistent with the basis which calls for continuous monitoring and alarming at a defined setpoint.

This changes is acceptable to the NRC staff.

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, 3/4 3-63/Function 4a:

The CHANNEL CALIBRATION requirement was deleted as it is an inappropriate requirement for this instrumentation.

The licensee has stated that a

CHANNEL FUNCTIONAL TEST is performed to verify the instrument performance against a known test tape.

After having reviewed additional infor-mation on these particular Response-Spectrum Analyzer Recorders the staff agrees that the calibration of this instrument is inappropriate and finds this change acceptable.

3/4 3-70 thru 3/4 3-73/all changes:

These changes were made in response to NRC Generic.Letter No. 83-36,,"NUREG-0737 Technical Specifications."

The staff has reviewed these changes along with the information provided in the licensee's submittal and they were found to be acceptable.

3/4 3-75/3.3.7.7a and b:

The change in this TS is made to reflect the as-built system and is conservative with respect to the current TS and is, therefore, acceptable.

3/4 3-78 and 3/4 3-79/Table 3.3.7.9-1:

The changes to this table were proposed in an effort to provide consistency between the Unit 1 and Unit 2 TS.

These changes more accurately reflect the as-built plant and are consistent with the Fire Protection Review Report.

This change also provides information additional to that in the present TS and is, therefore, acceptable.

3/4 3-82/Footnote*:

This change adds information necessary to complete the

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listing of required interlocks and reflects the as built plant.

Since this dditional information is appropriate the NRC staff finds this change acceptable.

3/4 3-87 and 3/4 3-89/all changes:

These changes were reviewed along with the justification given in the licensee's submittal and found to be acceptable as they are consistent with the more recently issued Unit 2 TS.

3/4 3-94/3.3.8:

Since only one turbine overspeed protection mechanism is

required, the staff has replaced the wording "at least one" with "one", this change is an administrative clarification and acceptable to the staff.

3/4 4-5/4.4.2:

This change is a clarification providing design setpoint infor-mation that ensures proper 'operation of the safety/relief valve acoustic monitors per manufacturer's recommendations and is acceptable to the NRC staff.

3/4 4-6/all changes and 3/4 4-8/4.4.3.2.1.b:

The design of this system is being improved to allow flow rate monitoring of the drywell floor drain sump and these TS changes support the system modification.

The NRC staff finds this change acceptable.

3/4 4-7/Action c:

This change reflects the as-built design capability and

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is acceptable to the staff.

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3/4 4-8/4.4.3.2.1.c:

This additional requirement ensures the verification of compliance with the associated LCO 3.4.3.2.c; presently the surveillance requirements only require verification of the unidentified portion of total leakage.

This is an additional requirement to the TS which the NRC staff finds acceptable.

3/4 5-3 Action g; and 3/4 7-7 Actions a, b:

The licensee has proposed the addition of a new action statement for the condition when the ECCS or RCIC keep fill instrumentation is INOPERABLE.

The current specification would require expedited plant shutdown in this circumstance.

The proposed action requires local monitoring of the pressure in the keep fill lines rather than plant shutdown.

The keep fill instrumentation provides no signals for safety system actuation or safety system interlocks.

Its purpose is to alarm the operator in the event that low pressure exists in the keep fill lines.

Low pressure can be an indication of voids in the discharge lines, which in turn can result in water hammer on system initiation.

Since the keep fill instrumentation provides only an alarm function, the same function can be accomplished'by local, periodic monitoring. 'he licensee's proposal is,, therefore, acceptable.

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3/4 5-5 Footnote**:

The licensee has proposed adding a new footnote for clarification.

Its purpose is to ensure that the solenoids associated with each ADS valve are tested.

The wording of the current specification does not explicitly require th'at the solenoids for each ADS valve'e tested.

The licensee's proposal is, therefore, a safety enhancement in that it clarifies the required surveillance.

This is acceptable to,the staff.

3/4'-5/Insert A:

The licensee in his submittal proposed a new surveillance requirement to test the LOCA/false LOCA logic in support of two unit operation.

The staff finds the licensee's proposal unacceptable due to the conceivable time lapse between tests.

The NRC staff understands that PPSL has this require-ment under review for improvement.

Until such time, the staff recognizes that the Unit 2 TS cover this surveillance requirement and encourages the licensee to submit a new proposal for both the Unit 1 and Unit 2 TS at the appropriate time.

This request is,.therefore, denied.

3/4 6-4/i and 3/4 6-10/4.6.1.7:

These changes are clarifications and improve-ments to the TS and, therefore, acceptable to the NRC staff.

3/4. 6-11/Footnote*:

The licensee has proposed to exclude the usage time for the 2-inch bypass line for pressure control from the limit of 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per 365 days.

The 90 hour0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> limit evolved from concerns relating to the accident pressure loads on the Stand-by Gas Treatment System (SGTS).

Operation of the 2-inch bypass line for containment pressure control requires the opening of the 24-inch inboard valve while the 24-inch outboard valve remains closed.

The NRC staff finds this change acceptable as long as the outboard valve is verified to be closed during containment pressure control.

The licensee in a phone conversation verified that PPKL has a mechanism to verify that the outboard valve is closed during this process,"'ith this in mind, the staff approves this change as any possible pressure pulse through the 2-inch line would be less than the SGTS design capability.

3.4 6-11/3.6.1.8 and 4.6.1.8.1:

This change was submitted in the licensee September 7, 1984 submittal.

The proposed changes involve the purge system isolation valves.

This TS change calls for removal of the 50% blocking requirement that was imposed on the containment purge isolation valves for which operability from the full open position had not been previously demon-strated.

The NRC staff, in Supplement No.

6 to the Safety Evaluation Report (SER), found the licensee's demonstration of operability of the subject valves to be acceptable without any blocking requirement, therefore this change is acceptable.

3/4 6-12/ACTION b2:

The current action statement has been revised to correct an inconsistency'n the TS.

The NRC staff finds this change to be appropriate and acceptable.

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3/4 6-13/ACTIONS c and d:

This change allows more flexibility as the revised statement requires that a minimum of six suppression pool locations must be monitored with one temperature detector at each location.

Upon review the NRC staff has determined that this change is acceptable as it poses no additional safety implications.

3/4 6-15/3.6.2.2.a and 3.4 6-16/3.6.2.3.a:

These changes reflect the as-built design that only one RHR pump is required to support a loop of suppression pool spray.

These changes are consistent with the approved FSAR analysis and are acceptable to the NRC staff.

3/4 6-17/new ACTION a.4,:

The licensee's proposed action statement would allow changes in OPERATIONAL CONDITIONS with inoperable containment isolation valves, if the valves continue to perform.their intended safety function (i.e., isolating pr imary containment).

The staff finds -this acceptable based on the assumption that containment isolation is accomplished within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from the time of discovery of an inoperable primary containment isolation valve.

The staff is concerned that the new action statement might be misinterpreted to allow 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to isolating the affected penetration because of the redundant reference to "within 4 'hours" in ACTION a.

as. well as Action a.4.

With this clarification the staff finds this TS change acceptable.

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3/4 6-19 and 3/4 6-28/Table 3.6.3-1:

The changes requested in the May 18, 1984 submittal are a result of PP&L efforts to correct this table based on operational experience.

These changes are administrative in nature and are acceptable to the NRC staff as they correct the TS.

Additionally, in the licensee's submittal of September 7, 1984, a change to Page 3/4 6-20 was requested.

This change involves the maximum closure time for the containment isolation valves in the purge and vent system to require all of them to close within 15 seconds.

In reviewing the vent/purge system for operating plants (TMI Task Action Plan Item II.E.4.2, Multi-plant Action Item B-24) the staff developed the requirement of fifteen seconds.

Since the licensee's request is within the allowable time for qualified containment purge valves, this change is acceptable.

3.4 6-32/4.6.5.2b:

The TS as written would force a two-unit shutdown in order to perform surveillances on the common isolation dampers.

The licensee has requested that the words "during shutdown or refueling" be deleted.

The NRC staff finds this change acceptable as the requirement can be complied with by entering an LCO to perform the surveillance.

This does not impose a safety problem as the action statement requirements were designed to allow systems to be out of service for allowable time intervals.

In addition, performance of this surveillance at power poses no real safety problems.

3/4 6-33/Insert A:

This change reflects two unit operation and the revised three zone basis for the Reactor Building HVAC.

As a result each damper is applicable to both units and has been added to Table 3.6.5.2-1.

Based on the licensee's justification the NRC staff finds'his change acceptable.

3/4 7-1/APPLICABILITY: Footnote** has been added to clarify requirements.

The new footnote allows the licensee to comply with the intended meaning as interpreted by the staff without relying upon similar interpretation by the licensee's staff.

This change for clarification is appropriate as well as acceptable.

3/4 7-2/ACTION a3:

This action statement has been revised to insert the word "otherwise."

Without the insertion of this word, the loss of one ESW pump would put the operator into action a3, since a loop is defined as consisting of two pumps and a flow path.

This'as not the intent.

The revised a3 allows action statement al to be followed.

This change is acceptable to the NRC staff.

3/4 7-2/4.7.1.2.b:

This statement has been revised in order to avoid a forced two unit shutdown since the ESW system is common to both units.

The NRC staff finds this change acceptable.

3/4 7-2/4.7.1.2.c:

The licensee has requested the addition of a new surveil-lance requirement to ensure the reliability of the subject safety-related valves and associated logic.

This change enhances safe operation and is, therefore, acceptable to-the NRC. staff.

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3/4 7-9 through 7-30/Snubbers:

The licensee'has requested changes to TS Section 3/4.7.4, snubbers."

First the licensee has requested the elimination of Table 3.7.4-1, "Safety Related Mechanical Snubbers" which is a tabular listing of all safety-related mechanical snubbers in SSES Unit 1.

The staff finds this change acceptable as the elimination of this tabular listing agrees with the present staff policy.

In addition to the above change, the licensee

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proposed a revision to the Unit 1 TS which would place the inspection schedules of snubbers on a system basis rather than a plant or unit basis.

This change is unacceptable as it conflicts with present staff policy and it therefore is denied.

The intent of the visual inspection is to survey all snubbers in a plant and to locate those which may suffer from an identified failure mode which is not system specific.

If the failure,mode can be narrowed to a specific design, model or type of snubber, then only those snubbers must be inspected.

This selection must be made from the entire unit or plant population of 'snubbers, not just from the system in which the valid failure mode was identified.

The staff recognizes that this denial causes Units 1 and 2 to be different.

The staff believes that since not only SSES Unit 2 has this system oriented TS for snubbers, but several other licenses issued in the Unit 2 time frame have an identical TS, the staff believes that this problem should be handled on a generic basis when the new policy and industry standard is complete.

At this time, the staff has concluded that in the interim period the Unit 2 TS pose no safety implications which wou'id necessitate early action.

3/4 7-36/3.7.6.2 and 3/4 7-38/3.7.6.3:

These changes reflect the as-built plant and two unit operation.

The NRC staff finds this change acceptable.

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3/4 7-43/3.7.7:

The licensee requested the addition of a requirement to en-sure that in sampling 10 percent of the population that the same 10 percent sample is not inspected'very 18 months.

The NRC staff recommends this requirement and finds it prudent.

3/4 8-4/d:

The words "during shutdown" have been removed in order to avoid unnecessarily shutting down Unit 1 and the possibility of unnecessarily shutting down both Units 1 and 2.

For the tests for which it is necessary to be shutdown in order to perform the surveillances the licensee is governed by the requirements of'he TS to have certain equipment operable in order to remain at power.

The staff does not normally,. nor in this case does the staff feel it necessary to, prescribe the operational condition necessary to perform a

surveillance.

When a test renders certain equipment, inoperable the licensee's operational condition is governed by the operability of the equipment 'already pre'scribed as necessary in the TS.

Therefore, the NRC staff feels that these additional words "during shutdown" do not add to the safety of operation but restricts unnecessarily the licensee by forcing a shutdown for the listed surveil-lances.

The staff finds this change acceptable.

. 3/4 8-4/d.6:

This surveillance requirement has been deleted in response to NRC Generic Letter 83-30 and, therefore, acceptable.

3/4 8-6/12:

This surveillance requirement has been deleted as a result of staff reevaluation of the intent of this requirement.

After investigating the basis of this requirement, the staff believes that the same level of safety can be achieved without unnecessary wear on the diesels.

The original intent of

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this 5 start requirement on the diesels was developed as.a method of verifying the diesel generator air accumulator capacity was large enough to support diesel starting with sufficient air capacity remaining after a diesel start.

The staff intended that this provided an additional conservatism.

At this time the staff finds that if the same level of safety can be achieved without over burdensome starting of the diesels, that this is a more prudent approach so as not to increase premature diesel wear.

The licensee in response to the staff has provided adequate justification for the removal of this require-ment. along with the assurance that it is PP8L's good maintenance practice that the diesel generator air start compressors and receivers are inspected and maintained as part of our Preventative Naintenance Program.

This Program schedules periodic preventative maintenance based on manufacturer's recommendations.

Preventative Maintenance work activities are performed in accordance with plant procedures.

In addition, should any significant degradation in the diesel generator air starting system be discovered, PP&L, per good practice, will initiate steps to investigate the problem and provide proper corrective action.

Such action may include recording air receiver pressure before and after certain required starts and trending the information in order to more closely monitor the system.

Based on this justification, the NRC staff finds this change acceptable.

3/4 8-6/e:

This change from 13 seconds to 10 seconds corrects a typographical error.

The staff agrees that this correction is appropriate and, therefore.,

acceptable.

3/4 8-8/Table 4.8.1.1.2-2:

The Emergency Diesel Generators are shared standby emergency power sources for Units 1 and Z.

The load sequencer (loading timer) is a part of the standby supplying systems and impacts both units.

As a result, the Unit 2 loading timers have been added to the current table of Unit 1 timers in order to ensure that the activities for the shutdown will not impact the other operating unit.

The change to have separate unit associated loading timers

.enhances safety during two unit operation.

Other changes have corrected typo-graphical errors and put the equipment timers in sequential order by time settings.

The staff has evaluated the licensee's request and justification and finds them acceptable.

- 3/4 8-11/4.8.2.1.a.2:

A requirement to check circuit breaker alignment to the battery chargers is proposed to verify OPERABILITY at least once per 7 days.

This change to the surveillance requirements enhances safe operation of the plant and is, therefore, acceptable.

3/4 8-12/d and 3/4 8-13e:

The subject dc supply systems are not shared between the two units; therefore, removal of the words "during shutdown" does not address a problem that would force a two unit shutdown, but instead addresses the problem of a single unit shutdown.

As stated in the justification for

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3/4 8-4/d, the staff does not find it necessary to prescribe the operational condition for which a surveillance must be performed as the operability of the equipment prescribed as necessary by the TS governs whether or not the unit can remain at power, which in turn governs the condition for which the surveillance must be performed.

3/4 8-17/3.8.3. l.a and 3/4 8-19/3.8.3.2.a:

This change provides a reference to the swing bus automatic transfer switch in the LCO providing additional controls over safety-related equipment and is, therefore, acceptable to the NRC staff.

3/4 8-18/ACTION c and 3/4 8-18/4.8.3.1.2:

These changes provide the appropriate action statement and surveillance requirement necessary to support the change on 3.4 8-17/3.8.3.1.a.

3/4 8-23/2b:

This change provides an option to functionally testing a repre-sentative sample of each type of fuse by instead replacing 100% of all required fuses.

The NRC staff previously reviewed this option and found it to be acceptable; this determination still holds true..

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8-28/ACTION b:

ACTION b proposes an addition to the Limiting Condition for Operation for MOV thermal overload protection to clarify the current TS.

The current TS has given credit to administrative action to continuously bypass the thermal overload within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

The action statement forces administrative act'ion to put the bypass in effect, and if this action cannot be done, the appropriate system action statements must be followed.

The licensee has pro-posed a change to add ACTION b which allows changes of OPERATIONAL CONDITIONS while. the administrative action is in effect.

This may include an exemption to Specification 3.0.4.

The staff finds this change acceptable.

3/4 8-33/4.8.4.3.a:

The information provided in the licensee's May 18, 1984 submittal was inadequate in addressing this change; as a result, several conference calls took place resulting in an additional submittal dated March 11, 1985 as supplemented by a March 13, 1985 submittal.

Having reviewed this additional information the staff has determined that SURVEILLANCE REQUIREMENT 4.8.4.3 for the specific SSES plant design should be performed while the plant is shutdown.

At SSES the risk of the plant suffering a full scram as a

result of performing this surveillance at power does not justify performing this test while not in cold shutdown.

In addition, forcing the unit to shutdown for the performance of this test every six months is also not justified.

As a result, the NRC staff finds the 'ticensee's proposed wording "By performance of a CHANNEL FUNCTIONAL TEST each time the plant is in COLD SHUTDOWN for a period of more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, unless performed within the previous 6 months" to be acceptable.

This wording was originally proposed by the NRC staff for the SSES Unit 2 TS when this plant specific problem was first discovered for Unit 2 during the 'Unit 2 licensing process.

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3/4 9-3, 3/4 9-4 and 3/4 9-7/all changes:

The footnote addressing-movement of incore instruments is removed along with the reference to it in the specification.

This change is acceptable as previously addressed in this evaluation; The operability requirement on count rate for the Source Range Monitor (SRM)

Channel has been reduced to 0.7 counts per second.

.This change has been previously approved for other plants and is acceptable.

The minimum count rate for the SRM channels is established in order to provide assurance that these channels are monitoring the neutron flux level of the core.

The accompanying requirement (in the footnote) that the signal-to-noise ratio be ~ 2.0 provides that assurance for the lower count rate.

3/4 9-8/4.9.6.1.b:

The licensee, has proposed to insert the words "greater than or equal to" in front of the words "8 feet."

The staff finds this to be a clarification which provides consistency within the TS, and is, therefore, acceptable.

3/4 10-1/3.10.1:

The change requests that, the hydrogen-oxygen analyzer dis-

'ussed in Specification 3.3.7.5 not be required OPERABLE during the low power physics tests which are discussed in Specification 3.'0. 1.

The hydrogen-oxygen analyzer is part of the accident monitoring equipment system and is intended to sample the drywell atmosphere following an accident.

The low power physics tests discussed in Specification 3.10. 1 are performed at less than 1X rated thermal power and with a reactor coolant temperature of less than 200'F.

The likelihood of a severe accident is greatly reduced under these conditions.

We conclude, therefore, that the hydrogen-oxygen analyzer makes no significant contribution to safety during these tests.

The licensee's request is acceptable.

3/4 11 and 3/4 12/all changes:

The staff has reviewed these'hanges and found them to be consistent with the Unit 2 TS as issued, as well as being presently acceptable to the NRC staff.

5-1/5.2.3:

This change updates the TS to reflect two unit operation making the TS correct.

This change is appropriate and acceptable to the staff.

Environmental Consideration 4

This amendment'involves a change.in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20.

The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that'ay be released offsite, and that there is no significant increase in indi-vidual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that this amendment involve no signi-

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ficant hazards consideration and there'as been no public comment on such findings.

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

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

Conclusion We have concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed

manner, and (2) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

Dated:

APR I3 1985