ML18029A321

Proposed Tech Specs Re Administrative Changes Involving Clarification of Requirements & Correction of Typos

ML18029A321
Person / Time
Site:	Browns Ferry
Issue date:	12/21/1984
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML18029A320	List: ML18029A319 ML18029A321
References
NUDOCS 8501020294
Download: ML18029A321 (34)

Text

ENCLOSURE 1

PROPOSED TECHNICAL SPECIFICATION REVISIONS BROWNS FERRY NUCLEAR PLANT (TVA BFNP TS 206) 8501020294 841221 PDR ADOCK 05000259 P

PDR

N

UNIT 1

PROPOSED SPECIFICATIONS

Vacuum Relief The purpose of thc vacuum relief valves i.. t>r equalize tl'>> l>rc::n>>rc between thc drywall and suppression chamber. and reactor building so that thc structural integrity of the containment is maintained'.

'i'hc vacuum relic!'ystem from the prcssure suppression chamber to reactor building consists of two l00< vacuum relief breakers (2 parallel sct" nf 2 valves in series).

Operation of either system will maintain the prcssure differential less than 2 psig; the cxtcrnal desipn prcssure.

Onc reactor building vacuum breaker may be out of service for repairs for a period of seven days. If repairs cannot be completed within seven

days, the reactor coo)nnt system is brought to a condition where Vacuum relief is no longer required' h>hcn a drywcll-suppression chamber vacuum breaker valve i" cxcrcised

'throuph an npcning-closinr. cycle the position indicatinp, lights in the control ror m arc dc"ipned to function ns specified below:

~>>

Initial and Final Check - On (Fully closed)

Condition Grccn - On Red

- Off Opening Cycle Check - Off Green - Off

'cd

- On (Cracked open)

(~ 80o Open)

(

3" Open)

\\

Closing Cycle Check

>> On (Fully Closed)

Green - On

(< 8,0 Oper,)

Red

- Off 3C Open)

The val rc position indicating lights consist of one check light, nn the check light panel which confirms full closure, one green liglit next to th>:

hl>n<l switch which confirms 80 of full opening and

<>nc re '," nC ful) closure).

Fach light. is on'a sepnratc switch,'f the check light circuit in nl>arable when the valve is exercise>l l>y its air opcrntnr thoro exists n

confirmation that the valve will fully close. If thc red lipht circuit ia

operable, there exists a confirmation that the valve will at least "nearly close" (within 3 of full closure).

Thc Green lipht circuit confirms the valve will fully open. If none of thc lights chan(c indication durinp thc cycle, the air operator must be inoperable or the valve disc is stuck.

For this case, a check light on and rcd lipht off confirms the di c ir, in a near'y closed position even if one of thc indications is in error.

Althouph the valve may be inoperable for full closur'e,.it doe's not consti-tute a safety threat.

If the red light circuit alone i" inoperable, the valve shall still be considered fully operablc.

If the preen and red or the preen light'ircuit a]ong id inoperable thc valve shall bc sonsidcrcd inoperabl<< for 27)

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'll"'I.; "rrtlrri'>;i l"C!R 0!'1".Irh'r')lrH::

llURVl I )s)s/NCE R) Ql)I)r)WllH'l'S

mechanical vacUUrfi pu,".rps ne,capahlc of being r.'.".amati cally isolated and s'-i@i."I on n n')lr,r>>r,l ol'ir:h rr. "oflctlvityIn thc sten;..

! r":;.s ':hcnevcr the main stea.-,.

I:..'.Utiorr valve're open.

'!:" the limit" of 3.8.C.1 are, nc;= mct, thc vacuum purmps shag:3.

br l U i)nted.

)).

Misec):.Ur>caus Radioactive lisle. 1 '.s Sources l.

So':."cc Lenka e Test E~.c'>."sealed source containirg ra. oactlve material in exec.s of those quantities of !>yprod-materiaI listed in 10 Cl R 30.71 Hcheclule 8 and nll other sou."ces, including alpha emittcrs> in excess of O.l microcurie, shall be free of

> 0.005 microcurie of'emnv-ab'.c contamination.

Each ser.'ed source with removable coats:.".ination in excess of th above limit shall be i."." diately uithdrnun fro-..i Usr. nnrl (a) eit) er dccon-tn:: I n.l.erl and (bi dispo cd af in nccor>)rulce with Corrsmi ssion regulations.

At least once during each operating cycle verify automatic securing and isolation of, the mechanical vucuIIm

})Urhps, D.

Miscellaneous Radioactive Materials Sources 1.

Surveillance Rc uirements Tests for leakage nnd/or contamination shall be pel formed by thc licensee or by other persons specifically authorized by the Commission or an crgreement State, as follows:

a.

Each scaled

source, except stnrtup sources subJect to core flux, containing radioactive material, other thnn Hydrogen 3, with a half<<

life greater than thirty days arid in any form ot)lcr than gas shall be tested for leakage nnd/or contamir>ation at intervals not to exceed six months.

The leakage test shall be capable of detecting thc presence of 0.005 microcurie of radioactive material on the test sample.

b.

The periodic leak test required does not apply to scaled sources that are stored and not being used.

Thc source..

excepted from this test shall bc tcstecl f'r leakage prior to any use or transfer to another User unless they have been leak tested within six months prior to the date pg use or transfer.=,

Xn the absence of a certification from n tran.feror indicating that a test hns been male within six months prio~ to the transfer, isenled sources shall not be put into Use rrnr.i:) tc ter).

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S nrtu

> sorlrccs ah~%i bc lc..k t'estcd prior to nnd following any repair or maintenance nnd before. being subJected to core flux.

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3.8.C/O.S.C Meehan cal Vacuum Pum The purpose of isolating the mechanical vacuum pump lines is to limit the release of activity from the main condenser.

During an

accident, fission products would be transported from the reactor through the main steam lines to the condenser The fission product radioactivity would be sensed by the main steam line radioactivity monitors which initiate isolation.

O.S.A and Q.S.B BASES The surveillance requirements given under Specification 0 S.A, and Q.S.B provide assurance that liquid. and gaseous wastes are properly controlled and monitored during any release of radioactive materials in the liquid and gaseous efiluents These surveillance requirements provide the data for the licensee and the Commission to evaluate the station's performance relative.to radioactive wastes released to the environment.

Reports on the quantities of radioactive materials released in effluents shall he furnished to the Commission on the basis of Section 6 of these technical specifications.

On the basis of such reports and any additional information the Commission may obtain from the licensee or others, the commission may from time to time retxuire the 1$.censee to take such actions as the Commission deems appropri'ate.

3.8.D and 4.8.D BASES The ob)ective of this specification is to assure that leakage from byproduct,

source, and special nuclear radioactive material sources does not exceed allowable limits 291

1, 1g

6 ~ 0 A

XHISTRATZVK CONTROLS

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Detailed written procedures, including applicable check-off lists covering items listed belo~ shall be prepared, approved and adhered tc.

l.

Norma 1 star tup, oper ation and shutdcwn of the reactor and of all oyytemo and components involving nuclear oaf ety of the facility.

2.

Refueling operationo.

3.

Acti.one to be taken to correct specific and foreseen potential malfunctions of systems or components, including responseo to alarms, suspected primary system leake and abnormal reactivity change o.

4.

Emergency conditions involv'g potential or actual release of Radioactivity.

5.

Preventive or corrective maintenance operat'ons which could have an effect on the safety of the reactor.

6.

Surveillance and testing requirements.

7.

Radiation control procedures.

8.

Radi ol~icol Emergency Plan implc~enting proc edu e 9 ~

9.

Plant security program implementing procedures.

i 0.

Fire protection and prevention procedu" eo.

ll.

Procedures limiting shift overtime similar to the June 15, 1982 NRC Commission Policy Statement.

B, ttritten procedures pertaining to thooe items listed above shall be reviewed by PORC and approved by the plant superintendent prior to imple~entation.

Tempora"y changes to a procedureo which do no" change the intent of the approved procedure may be made by a member of the plant staf f knowledgeable in the area affected by the procedure except that temporary changes to those items listed above except item 5 require the adcitional apprcv al of a

member of thi plant st. '

who holds a

Sen':

Reactor Op rator license on the unit a

ec;ed.

Such chang eo o.

~a 1 e chic'"hen c a..d subsecuen rev'wed by FDRC and approved by t,.e p'..

superint enden 338

UNIT 2 PROPOSED SPECIFICATIONS

I

Vacuum R lief sr

'ihe purpose of the vacuum relief valves io to c<)ualizc t)ie pressuic between the drywell and suppression chamber and reactor

~uilding qo that the structural'integrity of the containment is maintained.

The'vacuum relief system from the pre'ssurc suppression chamber to reactor building consists of two 100/> vacuum relief breakers (2 parallel sets of 2 valves in series):

,,Operation of either system will maintain the pressure differential less than 2 psig; the external design pressure, One reactor

)>uildin<> vacuun breaker may be out of.,ervicc for repair., for a period of sever: days.

r.

repairs cannot be completed within ocven days, the reactor coolant sys em is brought to a condition where vacuum relief is no longer required.

t"'f

)'hen a drywell-suppr'ession cha..ber vacuum breaker valve is exercised through an opening-closing cycle the position indicating lights in t,hc control room are designed to function as specified below:

XniLial and Final, Check 0>>

(Ful ly closeR)

Condition Green On Hcd Off'pening Cycle Closinf; Cycle Check Off Green - Off i)ed

- On Check - On Green - On Hcd

- Off (Cracked opc>>)

(> 80 Open)

(> 3 Open)

(Fully Closed)

(( 80o Open)

( 3 Open)

The vaIvc position indicat'ing lii;hts consist of cne check light on the

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check light p..nel which confirms full closure, ore green light next to the han<l switch which confir.os 80 of fiillopenir.g and one red iight nexl, to tli<~ ha!id owitrh whirh cnnfirmo "ne<<r closure" (within 3" of full

<<iooiirc).

1 ach,l it;ht l o or> a scp irutc owi Lch.

1 f t hc c)icck light <<i rcui L

'is oper ib)e when t)ic v ilv<. lo <xci ciocd hy its <<ir operator there exist o <<

<<.>>>firn!atio>> tl<<it. t)u; v<ilvc will f'ul ly close.

1 f L)i<

re<) lit",)it cii cul.l.

l!'pcrablc, there exist.o a confirriaLiori that t)ic valve vill <<L least, "nc;irly close" (within 3 of full closure).

Tlic green Light, circuit cor.firms thc valve will fully open. If none of the lights chiingc indication during t,he cycle, the air operator must be inoperable or the valve disc is stuck.

For this case, a c)reck light on and rcd light of 'onfirms the disc is in a nearly close<) position even if one of thc indications is in error.

Althniih the valve may be inoperable for full Llosurc, it doc: not const,i-tut<

a safety threat..

If the re<i light circuit alone is inoperable, the valve shall still be considered fully operable.

If the preen arid re<1 or the green light circuit; along i inoperable the valve shall be sonsidcrcd inoperable for

>1I'!'I':: s'0lluI's:>I I"0II 0I'I"lrh'I'Irrll llUltVll l>1>ANCI) 83 Ql)llllNI>)I'I".3

.s>cir:.

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Vacuum

)Umbras

.: echenical vacuur> pumps be capable of being s u'..>meti eel)y isolr>ted and s'

sc s"'n rL nir nsrt of'is;h r.iso:.ctivit,y in thc stca:.

!'"",.". vhcncvcr the main stesj.-,.

1:,'.ation va)ves are open.

1." thc limits of 3.8.C.1 are h

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no; met, thc vacuum pur.ps shall

! s'>lated.

D.

9i ccl '.'ns ou RediorLcti ye Matc. i el s Sources 1,

So::.cc Leaksr c Test Eac'a scaled source containirg radioactive material in excess of those quantities of byprod<<

u"- materiel listed in 10 Cr R 30.71 Schedule B and all other sou."ccs, including alpha emi ters, in excess of 0.1 microcurie, shall be free of' 0,005 microcurie of remov-ab' contamination.

Each seclcd source vith removable consta'..-.ination in excess of th above limit shall be diately vithdra~m from u.,c nnd (a) either dccon-trc.".in:-.les) ansi (br di"po cd of in accors)arrce vith Commission regulat,iona.

C.

Mechanical Vacuum Pum s

At least once during each operating cycle verify automatic securing and iso)ation of the mechanical vacuum l)usslps

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D.

Miscellancou'adioactive Materials Sources 1.

Surveillance Rc uirements Tests I'or leakage

'and/or corrtsmination shel'L be performed by the licensee or by other persons specifical)y authorised by the Commission or an agre'ement State, as fo)1ovs:

a.".

Each seal.cd

source, except startup sources sub)ect to core flux, containing radioactive material, other than Hydrogen 3, vith a half-life greater than thirty days and in any form other than gas shall be testerl for leakage and/or contamination at intervals not to exceed six months.

The leakage test shall be capable of detecting the presence of 0.005 microcurie of radioactive material on the test

~sample

b.

The periodic leak test required does not apply to sealed sources that are stored and not being used.

The sources excepted from t.his t,est shall bc tested for leakage prior to any use or transfer to another user unless they have been leak t.sated vithin six months prior to the date cf use or transfer.

Xn the absence of a certification from a tran"..fernr indicating that a hest has been made vithin six months prio~ to thc transfer, sealed sources shall,not bc put into uso unr:i1 tested.

28C>

c. Startu~ sources sh~ll bc 1cak tested prior to and follovinl: any repair or maintcnarlec and before being "subJected to core flux.

C.

3' C/4 '

C Mechanical Vacuum um The purpose of isolating the mechanical vacuum pump lines is to limit the release of activity from the main condenser.

During an

accident, fission products would be transported from the reactor through the mai.n steam lines to the condenser The fission product radioactivity would be sensed by the main steam line radioactivity monitors which initiate isolation 4

8 ~ A a d 4 8.B BASES The survei.llance requirements given under Specification 4 8.A, and 4.8.B provide assurance that liquid, and gaseous wastes are properly controlled and monitored during any release of radioactive materials in the liquid and gaseous effluents.

These surveillance requi.rements provide the data for the licensee and the Commission to evaluate the station~s performance relative to radioactive wastes released to the envi.ronment.

Reports on the quantiti.es of radioactive materials released in effluents shall be furnished to the Commission on the basis of Section 6 of these technical specificati.ons.

On the basis of such reports and any additional information the Commission may obtain from the licensee or others, the Commission may from time to time require the li.censee to take such actions as t4e Commission deems appropri'ate.

3.8. D and 4. 8. D BASES The objective of this specificati.on is to assure that leakage from byproduct,

source, and special nuclear radioactive material sources does not exceed aU.owable limits 291

Detail ed Mritten procedures, including applicable ch<ak-off lists covering items listed belo~ shall be prepar<:d, approved and adhered tc.

Poikil otartup, operation and shu d~n of the r< <actor and of

<i ill oy.<turns and exnponents involving nuclear oaf ety of the f<<cility.

2.

Refueling operations.

Actions to be taken to cor-oct specific and foreseen potential malf unc~Aons of systems or components, including reoponseo to alarms, suspected primary system leaks and abnormal reactivity changeo.

4 ~

5.

Emergency conditiono involv'ng potential or aetna'elease o f Radioactivit,y.

Preventive o" corrective maintenance opera mons vhich could have a~ effect on the safety of the reactor.

6.

Surveillance and testing requirements.

7.

Radiation control procedureo.

8 ~

Radi olocical Nergency Plan implencnting proc edu e s 9.

plant security program implementing procedures.

ip.

Fire protection and prevention procedures.

11.

Procedures limiting shift overtime similar to the June 15, 1982 NRC Commission Policy Statement.

written procedureo pertaining to those items listed above shall be reviewed by PORC and approved by the plant superintendent prior to imple~entation.

Temporary changeo to a procedureo Dich do not cha~e the intent of the approved procedure t:ay be made by a

membe of the plant staff knowledgeable in t'h e area af ectec.

by the procedu "4 except that tezpora. I changes to t.".ooe items lie ed <<bove except i tm 5

r<gu 'e

'. he <addit 'na1 apprcv al 0

6 mt'h<'r o'h<

p'n t o '.",'Jno ho c 0 Sen'.

Re~cwr Ow razor 1'cense on the urzt a~f ~c" ed.

such changes s.".al "e

chic. ~ant ~c and sumac~~encl y rev'eved by PORC and approved by the p'..

aupe intend~mt.

338

UNIT 3 PROPOSED SPECIFICATIONS

t '

LIMITINGCONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3 ~ 8 RADIOACTIVE MAT ALS 4.8 OACTXVE HATER S

the stack or radwaste monitor, the reactors shall be in the hot shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the stack and 10 days for the radwaste vent s If these requirements are not satisfied for the reactor and turbine building

vents, the affected reactor shall be in hot shutdown condition within 10 days.

cuum le automatically isolated and secured on a signal of high radioactivity in the steam lines whenever the main steam isolation valves are open.

! C.

Mec a ica V

u m~.

1.

The mechanical va pumps= shall be capab of being Ce.

e anc V

u P

At least once during each operating cycle verify automatic securing and isolation of the mechanical vacuum pumps.

2.

If the limits of 3.8.C.1 are not met, the vacuum pumps sha11 be isolated.

Hl I

3 8.C/4.8.C Mechanical Vacuum Pum The purpose of isolating the mechanical vacuum pump lines is to limi.t the release of activity from the main condenser.

During an accident, fission products would be transported from the reactor through the main steam lines to the condenser The fission product radioactivity would be sensed by the main steam line radioactivity monitors whi.ch initiate isolation.

4.8.A a d 4.8.B BASES The surveillance requirements gi.ven under Specification 4 8 A and

- 4.8.B provide assurance that. liquid. and gaseous wastes are properly controlled and monitored during any release of radioactive materials in the liquid and gaseous effluents.

These surveillance requirements provide the data for the licensee and the Commission to evaluate the station~s performance relative to radioactive wastes released to the environment..

Reports on the quantities of radioactive materials released in effluents shall be furnished to the Commission on the basis of Section 6 of these technical specifications.

On the basis of.such reports and any additional information the Commission may obtain from the licensee or others, the Commissi.on may from time to time require

~

the licensee to take such actions as the Commission deems appropriate.

3 B.D aad A.S.D BASES The objective of this specifi.cation is to assure that leakage fxom byproduct,

source, and special nuclear radioactive materi.al sources does not exceed allowable limits

Lj

6. 3 Pror<<duri o Detailed Mritten procedures, including applicable ch~k-off lists covering items listed belo~ shall be prepared,,

approved and adhered tc.

1.

Normal nta rtup, operation and shut.dmn of the react, or and of all oy;>temn and components involv'ng nuclear saf ety of the facillty.

2.

Re fueling operationo.

34 Actions to be taken to -correct specif ic and foreseen potential malfunctions of systems or component,s, including response o to al arms, suspected primary system leaks and abnormal reactivity changes.

5.

Emergency condi tiono involv'g poten ia l or ac ua'elease of Radioactivity.

Preventive o" correct.ive maintenance operations Mhich could have an effect on the safety of the reactor.

6 Surveillance and testing requi rcmento.

7.

Radiation control procedures.

8-Radar olmi ca 1 Emergency Plan impl~~cnting procedure s.

Plant security program implementing p ocedures.

)0.

Fire protection and prevention procedureo.

11.

Procedures limiting shift overtime similar to the June 15, 1982 NRC Commission Policy Statement.

B.

written procedureo per aining to thooe items l'oted above shall be revie~ed by PORC and approved by the plant superintendent prior to impl<<mentation.

Temporary chances to a procedureo which do no change. the ~~ntert of the approved pro"edure may be made by a, me%e of the plant otaf f knowledgeable in the area af fectec.

by the prew.<<u=e except. that temporar c changes ta t.",one items lint<<d above except 1 ttsl 5 'r&juire t ~ le addi lena l apprcval of a

mgmb<ir o'. th>> plant nt"'f i~ho holds a

Sen'r reactor Ops:ator 1 'ense or. the ur t a "oc;ed Such changes o..al

'"e doc. ~ertec and suosecuent Yev ev& b}'

SIC anc hp)> ovec b}'a ~ e supe.'int one i.nt.

368

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ENCLOSURE 2 DESCRIPTION AND JUSTIFICATION OF CHANGES (TVA BFNP TS 2()6) 1.

Units 1 and 2 - page 271 Descri tion The proposed change is to the Bases section which describes the position on the drywell-suppression chamber vacuum breaker valves closing cycle.

Presently the indication is "Closing Cycle - Green - On

( C 30 Open)."

It is proposed to change this to read "Closing Cycle - Green - On

( (80 Open)."

Justification This proposed change is only to correct a typographical error in the units 1 and 2 specifications.

This bases section in unit 3 specification reads "Closing Cycle - Green - On ($80o Open)." Therefore, this change will make the units 1 and 2 specifications consistent with unit 3.

This proposed change will not affect operations, safety margins, accident

analysis, or overall plant safety.

2.

Pages 286 and 291 - Units 1 and 2

Pages 307 and 315 Unit 3 Descri tion The proposed amendment is being made to change "pump" to <<pumps" in Section 3.8.C.

This section refers to a mechanical vacuum pump when, in fact, there is more than one pump.

The section is being changed to clarify that fact.

Also, Section 3.8.C/4.8.C bases are being revised to reflect the correct number of pumps.

Justification This proposed change is being made to have the technical specifications be consistent with the plant's configuration.

There are two mechanical vacuum pumps in a parallel configuration.

Each pump and line can be individually isolated.

Both lines are isolated on a main steam line high radiation signal.

P>'~C A

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3.

Pages 338 - Units 1 and 2

Page 368 - Unit 3.

Descri tion The proposed change is the addition to the technical specification Administrative Controls section of a reference to the fact that there are written procedures covering shift overtime limitation at Browns Ferry.

Justification NRC letter from D. B. Vassallo to H. G. Parris dated July 27,

1980, TVA was requested to submit proposed technical specifications regarding limits on shift overtime in accordance with the guidelines of the revised Commission Policy Statement, reference NRC Generic Letter No. 82-12 dated June 15, 1982.

This proposed change to the technical-specifications is being made in response to that July 27, 1984 letter.

This proposed specification will provide assurance that written procedures on limiting shift overtime shall be prepared,

approved, and adhered to.

W

ENCLOSURE 3 PROPOSED NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION (TVA BFNP TS 205) 1.

Descri tion of Amendment Re uirement The proposed amendment would correct a typing error on vacuum relief

valves, page 271 of units 1 and 2.

The statement saying "Closing Cycle-Green - On ((30 Open)" should be "Closing Cycle - Green - On (<80 Open)." This change makes the technical specifications consistent with the unit 3 technical specifications.

Basis for Pro osed No Si nificant Hazards Consideration Determination The Commission has provided examples of license changes which are likely to involve no significant hazards consideration (48 FR 14870).

One of the examples of actions likely to involve no significant hazards considerations is

"(i) a purely administrative change to the technical specifications.

For

example, a change to achieve consistency through the technical specifications, correction of an error, or a change in nomenclature."

Because this proposed change is only to correct an error in the typing of the technical specifications it is clearly encompassed by example (i).

2.

Descri tion of Amendment Re uirement The proposed amendment is being made to change "pump" to "pumps" in Section 3.8.C.

This section refers to a mechanical vacuum pump when, in fact, there is more than one pump.

The section is being changed to clarify that fact.

Also, Section 3.8.C/4.8.C bases are being revised to reflect the corrected number of pumps.

Basis for Pro osed No Si nificant Hazards Consideration Determination The Commission has provided guidance concerning the application of the standards by providing examples of actions that are not likely to involve significant hazards considerations (48 FR 14870).

One example of actions not likely to involve significant hazards considerations is a purely administrative change to technical specifictions:

for example, a change to achieve'onsistency throughout the technical specifications, correction of an error, or a change in nomenclature.

The proposed amendment is being made to clarify, in SectS. on 3.8.C, that there is more than one mechanical vacuum pump.

There are two pumps situated in parallel with an isolation valve at each pump suction.

Only one pump is used at a time.

The Bases for this section is also being revised to reflect the actual plant configuration. It, therefore, is encompassed by the example.

Since this proposed amendment is encompassed by an example of action not likely to involve significant hazards considerations, TVA proposes to determine that the proposed amendment does not involve a significant hazards consideration.

8

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3.

Descri tion of Amendment Re uirement The proposed amendment would modify the technical specification to include a requirement for written procedures to limit overtime of personnel performing safety-related functions.

Basis for Pro osed No Si nificant Hazards Consideration Determination The Commission has pr ovided examples of license changes which are likely to involve no significant hazards consideration (48 FR 14870).

One of the examples of actions likely to involve no significant hazards considerations is "a change that constitutes an additional limitation, r estriction, or control not presently included in the TS:

for example, a more stringent sur veillance requirement."

This change involves the addition of a new requirement to have written procedures for limiting shift overtime similar to the June 15, 1982 NRC Commission Policy Statement.

Because this change adds an additional control not presently included in the technical specifications, it is clearly encompassed by the above example of an action not likely to involve a significant hazards consideration.