ML20043D211

Application for Amend to License NPF-39,consisting of Tech Spec Change Request 90-05-1,deleting Ref to Water Temp at Suction of RHR Pump for Suppression Pool Water Temp Indication at Remote Shutdown Panel

ML20043D211
Person / Time
Site:	Limerick
Issue date:	06/01/1990
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20043D215	List: ML20043D211 ML20043D221
References
NUDOCS 9006070263
Download: ML20043D211 (3)

Text

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TSCR 90-05-1 PHILADELPHIA ELECTRIC COMPANY-NUCLEAR GROUP HEADQUARTERS i 3 955 65 CHESTERBROOK BLVD.

, WAYNE. PA 19087 5691 j (as s) sao sooo June 1, 1990 t Docket No. 50-352 =

u License No. NPF-39

-U.S. Nuclear Regulatory Commission

' Attn: Document Control Desk i Washington, DC 20555

SUBJECT:

- Limerick Generating Station, Unit 1 ,

Technical Specifications Change Request '

i

Dear Sir:

i Philadelphia Electric Company hereby submits Technical ,

Specifications Change Request No. 90-05-1, in accordance with-10 CFR 50.90, freguesting an' amendment to the Technical Specifications (TS) (Appendix A) t

, of Operating License No. NPF-39. Information supporting this Change-

• h Request is contained in Attachment 1 to this letter, and the proposed f replacement pages are contained in Attachment 2.

, , This submittal requests a change to TS Table 3.3.7.4-1 to delete

-the, reference to the water temperature at the suction of the 'A' Residual Heat Removal pump for the suppression pool water temperature indication at the Remote Shutdown Panel (RSP). This proposed change reflects a proposed modification to replace.the existing suppression pool water temperature indication at the RSP with direct temperature indication of the suppression -

L , pool water. This submittal.also requests a change to TS Table 3.8.4.1-1 to i l, add new primary containment penetration conductor overcurrent protective h devices. This proposed change reflects a proposed modification to provide for the control of emergency power to the Reactor-Core Isolation Cooling System steam supply line inboard containment isolation valve (HV-49-1F007) from the RSP. These modifications are proposed to be performed during the L .next-(third) refueling outage for LGS, Unit 1, currently scheduled to begin in-September 1990, based-on commitments in Licensee Event Report Nos. 1 002, " Unavailability of the Reactor Core Isolation Cooling System Due to Insufficient Protection of Various Control and Power Cables from Postulated ,

I Fire Damage," Rev. 01, dated March 31, 1989, and 1-89-023, " Lack of l 900607o263 900601 .

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' fDR ADOCK 05000352 g PDC

, ' ' c; ' UlS. Nuclear. Regulatory Commission

_ lune 1, 1990

-Document Control Desk. Page 2

-Protected Suppression Pool: Level and Temperature Indication in the' Event of

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a Fire," dated May.5, 1989.

We request the changes proposed herein be' effective within 90 days of the start of-the third refueling outage for LGS.-Unit 1, currently

+i scheduled to begin on Septeinber 8. -1990.

If you have any questions regarding this matter, please contact us.

Very truly yours, G. A. Hunger, Jr.

Manager Licensing Section Nuclear Engineerir,, and Services Department Attachments

cc: -T.'T. Martin, Administrator, Region 1. USNRC T. J. Kenny, USNRC Senior Resident Inspector, LGS T. M. Gerusky, Director, PA Bureau of Radiological Protection

.:CONMONWEALTHOFLPENNSYLVANIA't'

s$ -

COUNTY OF'CHESTER  :

D. R. Helwig, being first-duly sworn, deposes and says:

That he is Vice President of Philadelphia Electric Company;

'the Applicant herein; that he has read the foregoing Application for.-

AM ndment of Facility Operating License No.=NPF-39 to reflect a

. modification to provide'for direct suppression pool water temperature indication at the Remote Shutdown Panel (RSP).and a modification to provide for the control of emergency power to the

-Reactor Core Isolation: Cooling System steam supply line inboard -

containment isolation valve from the RSP, and knows the contents thereof; and the statements and. matters set forth therein are true

and correct-to the best of his knowledge, information and belief.

Vice President Subscribed and sworn to AX before me this / day

of a Q 1990, bitduu o /) Y'}')j, -. .

Notarv Public NoTARAL SEAL cATHERtHE A. MENDE2. Notxy Public

' Tredyenn Twp., Chester Ccunty My Commiasson Exches Sect. 4.1993

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ATTACHMENT 1-LIMERICK GENERATING STATION Unit 1 Docket No. 50-352 License No. NPF-39 TECHNICAL SPECIFICATIONS CHANGE REQUEST

" Direct Suppression Pool-Water Temperature Indication at the Remote Shutdown Panel and Primary Containment Penetration Conductor Overcurrent Protective Devices" Supporting Information for. Changes - 10 pages a

- _ _ . - _____-__- - _ _ . _ ___._____________.-____m_ - -.___ ..__s.=-.____..____-__ . _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . - _ _ _ _ .

1 L' Docket Hos. 50-352 l

'k t S.^ License Nos. NPF-39 Philadelphia Electric Company-(PECo), License under Facility Operating License NPF-39 for Limerick Generating Station (LGS), Unit 1, hereby requests that the Technical Specifications (TS) contained in Appendix A of the Operating License.be amended as proposed herein. There are two proposed TS changes. The-first proposed TS change reflects a proposed modification to replace the existing suppression pool water temperature indication (actually the water temperature at the suction of the 'A' Residual Heat Removal pump) at the Remote Shutdown Panel (RSP) with direct temperature indication of the suppression pool water. The second: proposed TS change reflects a proposed modification to provide for the control of emergency power to the Reactor Core Isolation Cooling (RCIC) System steam supply line inboard containment isolation valve from the RSP. These modifications are proposed to be performed during the next (third) refueling outage for LGS, Unit 1, currently scheduled to begin in September 1990, based on commitments in Licensee Event-Report (LER) Nos. 1-89-002,

" Unavailability of the Reactor Core Isolation Cooling System Due to insufficient Protection of Various Control and Power Cables from Postulated Fire Damage," Rev. 01, dated March 31, 1989, and 1-89-023. " Lack of Protected Suppression Pool Level and Temperature Indication in the Event of a Fire," dated May 5, 1989. For plants licensed after January 1, 1a71 (such as LGS, Unit 1), the requirements of 10 CFR 50.48 and 10 CFk x ,

Appendix R are invoked by the Standard Review Plan (NUREG-0800), Section 9'.5.1, dated July 1981 and its associated attachment, Branch Technical Position (BTP) CMEB 9.5-1. -The proposed changes are Indicated by a vertical bar in the margin of pages 3/4 3-77 and 3/4 8-24 for LGS, Unit 1, and are contained in Attachment 2.

We request the changes proposed herein be effective within 90 days of the start of tne third refueling outage for LGS, Unit 1, currently scheduled to begin on September 8, 1990.

This Change Request provides a discussion and description of each proposed TS change, a safety assessment of each proposed TS change, information supporting a finding of No Significant Hazards Consideration for each proposed TS change, and information supporting an Environmental Assessment.

I. Proposed TS Change No. 1 Discussion and Description of Change The remote shutdown system instrumentation and controls located on the RSP were designed in accordance with General Design Criterion (GDC) 19 of 10 CFR 50, Appendix A to ensure that sufficient capability is available to permit shutdown and maintenance of Hot Shutdown of the unit from locations outside of the main control room (MCR) in the event MCR habitability is lost. The remote shutdown system instrumentation and controls are also j

• Docket Nos, 50-352

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License Nos. NPF-39 used to satisfy the alternative shutdown requirements of BiP CMEB 9.5-1 for I shutdown from outside of the MCR in the event of a fire. TS Table 3.3.7.4-1, " Remote Shutdown System Instrumentation and Controls," TS page 3/4 3-77, currently indicates that the suppression pool water temperature indication at the RSP is actually indication of the water temperature at the suction of the 'A' Residual Heat Removal (RHR) pump (i.e., when the RHR pump is aligned for suppression pool cooling).

In LER No. 1-89-023 for LGS, Unit 1. dated May 5, 1989, we reported that this indication of suppression pool water temperature may be lost in the event of a fire for which shutdown from the RSP is required since the '

'A' RHR pump suction water temperature indicator, Il-51-104A, is powered from a non-Class 1E electrical power source and its associated cabling is not protected from fire damage. in LER 1-89-023, we committed to perform a -

modification during the third refueling outage to provide suppression pool water temperature indication at the RSP which would be available to support 140 shutdown of the plant from outside the MCR in the event of a fire.

This proposed modification will replace the 'A' RHR pump suction water tGaperature indication at the RSP with direct temperature indication of 4 the suppression pool water using spare resistance temperature detector (RTD) elements from the existing Suppression Pool Temperature Monitoring Splem(SPTMS), SPTMS provides suppression pool water temperature indir ation in the MCR only. This proposed modification will provide suppression pool water temperature indication which is pocred from a Class li electrical power source and for which the associated cabling is protected from fire damage.

Once this proposed modification is complete, the TS reference

"(Actually RHR Pump 'A' Suction Temperature)" for the suppression pool wcter temperature indication on TS Table 3.3.7.4-1 will no longer be valid.

Therefore, a change is proposed to TS page 3/4 3-77 to delete thic reference such that TS Table 3.3.7.4-1 will specify "Suppressica Chamber Water Temparature" only (see Attachment 2).

-Safety Assessment s

The proposed TS change is based on a proposed modification to replace the existing suppression pool water temperature indication at the RSP (actually the water temperature at the suction of the 'A' RHR pump) with direct temperature indication of the suppression pool water. This proposed modification will ensure suppression pool water temperature is available to support safe shutdown of the plant from outside the MCR in the event of a

, fire. This proposed modification will provide assured suppression pool water temperature monitoring capability which will continue to satisfy GDC 19 of 10 CFR 50. Appendix A, since it will provide direct indication of suppression pool water temperature at the RSP instead of the 'A' RHR pump suction water temperature, and it will also provide the operator with the

Docket Nos. 50-352 License Nos. NPF-39 ability to select between two temperature elements on opposite sides of the suppression pool to give a better profile of the suppression pool water temperature.

This proposed modification does not add any new interfaces with i systems that are not related to suppression pool temperature monitoring.

The design temperature monitoring capability of SPTMS is unaffected by the proposed modification. There is no impact on RHR system operation and the

'A' RHR pump suction water temperature indication is still available in the '

MCR.

_The new temperature instrumentation loop will provide increased reliability since its design conforms to applicable criteria for physical separation, redundancy, and divisionalization. This new temperature instrumentatation loop will be powered from an electrical Division 1. Class lE source.

Information Supporting a finding of No Significant Hazards Consideration We have conclu...d that the proposed change to the LGS Unit 1 TS, which reflects the replacement of the existing 'A' RHR pump suction water temperature indication at the RSP with direct suppression pool water temperature indication, does not constitute a Significant Hazards Consideration. In support of this determination, an evaluation of each of the three standards set forth in 10 CfR 50.92 is provided below.

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

The proposed TS change reflects a proposed modification to replace the existing suppressior pool u ter temperature indication at the RSP (i.e., the water temperature at the suction of the 'A' RHR pump) with direct temperature indication of the suppression pool water. This proposed modification will ensure the availability of suppression pool water temperature indication at the RSP to support safe shutdown of the plant from outside the MCR in the event the MCR becomes uninhabitable for any reason, including fire.

This proposed modification will use two spare RTO elements from SPTMS, Sufficient spare RTD elements are still available such that the design operation of SPTMS is unaffected by the proposed modification. The new temperature instrumentation loop will be powered from an electrical Division 1. Class IE source. The increased loading on this power source will be negligible, and therefore, will have no effect on

l. the ability of this Class IE source to perform its intended function.

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Docket Nos. 50-352

'.** License Nos. NPF-39 ,

This proposed modification will not use any instrumentation with accuracies or response characteristics that are different than the existing temperature instrumentation. This proposed modification will meet applicable construction standards, design, and material requirements. The new temperature instrumentation loop will provide increased reliability since its design conforms to applicable criteria for physical separation, redundancy, and divisional 12ation. The new temperature instrumentation loop components will be environmentally qualified, qualified to Seismic Category I and Class IE, and energized from onsite emergency _ power supplies in the event offsite power is lost. This proposed modification does not introduce any new failure

. mode and does not alter any assumptions previously made in evaluating >

the radiological consequences of an accident. The proposed change ~

does w t affect limiting safety system settings or operating parameters, and does not modify or add any initiating parameters that would cause a significant increase in the probability or consequences of an accident previously evaluated.

2) The proposed change does not create the possibility of a new or '

different kind of accident from any accident previously evaluated.

The proposed TS change reflects a proposed modification to replace the existing suppression pool water temperature indication at the RSP.

This proposed modification does not delete or modify remote shutdown system protection features, downgrade any support system performance necessary et reliable operation of equipment, reduce system ,

redundancy or independence, or impose more severe testing requirements. This proposed modification has no impact on the operation of the RHR systn or SPTMS. This proposed modification does not change or add any components in the remote shutdown system which could fail in a different mode than was previously evaluated. The proposed change does not involve any change-to setpoints or operating parameters nor does it involve any potential initiating event that would create the possibility of a new or different kind of accident from any accident previously evaluated.

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(3) The proposed change does not involve a significant reduction in a margin of safety.

The proposed TS change reflects a proposed modification to replace the  ;

existing suppression pool water temperature indication of the RSP.

This proposed modification will use two spare RTO elements from SPTMS.

Sufficient spare RTD elements will still be available in case of failure of the primary elements such that the operation of SPTMS will not be affected. Additionally, the reliability of the suppression pool water temperature indication at ihe RSP will be improved since the new temperature loop will be pon 4 from a Class 1E source, its i

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Docket Nos. 50-352~

License Nos. NPF-39  !

I associated cabling will be protected from fire damage, and the i proposed modification will provide the operator _with the ability to ,

select between two RTD elements on opposite sides of the suppression pool to give a better profile of suppressinn pool water temperature, rather than having only the single 'A' RHI simp suction water temperature indication. This proposed moc Ication will not alter the intended function of the systems involved, but will enture that  :

suppression pool water temperature indicat'on is available at the RSP to support safe shutdown of the plant from outside the MCR in tho -

event the MCR becomes uninhabitable for any reason, including fire. ,

This proposed modification will not alter any limiting conditions for operation or surveillance requirements related to suppression pool water temperature. Therefore, the proposed change does not involve a ,

significant reduction in a margin of safety. .

II. Proposed TS Change __No. 2 '

T)iscussion and Description of Change The RCIC system is used to support certain methods of safe shutdown of the plant in the event of a fire, in LER No. 1-89-002 Rev. No. 1, for LGS, Unit 1, dated March 31, 1989, we reported that a fire in certain areas of the plant could result in the unavailability of the RCIC system due to fire. damage to control and power cables associated with the RCIC system steam supply line inboard containment isolation valve HV-49-1F007. This valve is controlled from the RSP in support of safe shutdown from outside the MCR in the event of a fire. Although the RSP is powered by electrical '

Division 1 AC power, the HV-49-10007 valve is powered from electricai  ;

Division 3 AC power, and will automatically close upon receipt of a Division 3 isolation signal. However, Division 3 control and power cables were not protected in those ilre areas for which the RCIC system is used to support safe shutdown of the plant in the event of a fire. Fire-induced damage to the Division 3 control cables could produce a false isolation signal which would cause the HV-49-1F007 valve to close. Fire-induced damage to the Division 3 power cables, from the same fire, could cause a l- loss of power required to reopen the valve. If, in the event of a fire. ,

l the valve closes and power is lost before the valve can be reopened, the ,

l RCIC system would be rendered inoperabic. In LER 1-89-002, we committed to perform a modification during the third refueling outage which would provide the capability, through a manual transfer switch located at the l RSP,_to power valve HV-49-lF007 from an emergency (Division 1) power source. This emergency power source would be available in the event of a fire to provide the ability to reopen the valve. As part of the proposed modification, this emergency source will be powered through a normally l locked open, instantaneous magnetic circuit breaker mounted in an electrical Division 1 motor control center (MCC). Also, a second, normally closed, thermomagnetic circuit breaker will be added as a back-up breaker to provide the redundant protection specified by Regulatory Guide 1.63,

• Docket Nos. 50-352 o ".5 License Nos. NPF-39 l

" Electric Penetration Assemblies in Containment Structures for Nuclear Power Plants," for electrical cables and wiring that penetrate the primary i containment. This second circuit breaker is also required to assure disconnection from the Division 1 power bus for any faulted load condition.

As a result of this proposed modification, a change is proposed to TS Table 3.8.4.1-1, " Primary Containment Penetration Conductor Overcurrent Protective Devices," TS page 3/4 8-24, to add the primary and backup i circuit breakers for the Division 1 emergency power supply to the RCIC system steam supply inboard containment isolation valve, HV-49-1f007, to this table.

Both breakers are identified by a single circuit breaker i number, 52-21331, since both breakers are located in the same MCC cubicle '

(See Attachment 2). 15 Table 3.8.4.1-1 currently lists the primary and back-up breakers (circuit breaker no. 52-22313) for the normal Division 3  ;

power supply to the HV-49-If007 valve. j Safety Assessment l The proposed 1S change reflects a proposed modification to provide the operator the ability at the RSP to manually transfer from the normal Division 3 power supply to the RCIC system steam supply line inboard 1 containment isolation valve. HV-49-1f007, to an emergency Division 1 power supply. This action may be required to reopen the valve in the event the valve closes and the normal Division 3 power supply is lost as the result of fire-induced damage caused by a fire in certain areas of the plant.

This proposed modification will provide the operators the ability to restore the RCIC system to service in the event the RCIC system is rendered inoperable for the reasons described previously as a result of a fire, and to provide for safe shutdown of the plant in accordance with the safe shutdown methods described in the fire Protection Evaluation Report (FPER) for LGS.

The manual transfer switch box at the RSP will be locked closed. The position of the transfer switch will be indicated on a MCR panel, and will I

I cause an alarm in the MCR when placed in the emergency position. The electrical Division 1 instantaneous breaker (the primary breaker) will be i locked open. The keys to these locks will be under administrative control I

so that control of the manual transfer switch and the Division 1 primary breaker will be limited to, aside from testing and maintenance, procedure-

, directed operator discretion only in the event of a fire with concurrent l- loss of electrical Division 3 AC power.

l. The design of this proposed modification is such that physical independence of electrical systems and application of the single failure criterion will be maintained, with U2 exception that when the manual transfer switch is placed in the emergency position, normal Division 3 power and control cabling for the valve will become energized from an p

Docket Nos. 50-352 License N:s. NPF-39 i elect'rical Division 1 power source. Because of this, the following restrictions will be established for testing the operation of HV-49-1F007 ,

and the manual transfer switch.

1) Testing shall be limited to those times the plant is in operating conditions 4 (Cold Shutdown) or 5 (Refueling) as defined by TS. *

2) Operation of HV-49-1F007 shall be tested from its normal power '

source (Division 3)priortotestingfromtheemergency. power source (Division 1). This will ensure the electrical integrity ,

of the penetration assembly conductors for this valve prior to testing the valve from the electrical Division 1 source.

3) Testing of the emergency function (using Division 1 power) shall be controlled from the RSP with the RSP transfer switch in the emergency position. This limits the interconnection of Division 3 circuits with Division 1 power to the MCC, the RSP, and ,

interconnecting wiring. Control complex (i.e., the MCR, cable i spreading room, and auxiliary equipment room) wiring and circuits will not be involved. -

In addition, the following requirements on operation of the manual transfer switch will be included in all applicable procedures.

1) Division 3 power shall always be removed from the manual transfer switch before Division 1 power is connected by opening one of the two circuit breakers in Division 3.

2) Except for testing, the RCIC manual transfer switch shall be used or.ly in case of a fire that disrupts electrical Division 3 AC power to the valve and valve HV-49-1F007 is failed closed as determined by the operator.

3) Removing an erroneous Division 3 isolation signal requires use of transfer switches on the RSP, and subsequent RCIC system control from the RSP.

4) The Division 1 primary breaker shnuld be locked open and the manual transfer switch should be returned to the " Normal" position immediately after the isolation valve is confirmed to be open..

These restrictions will limit the time that the electrical Division 1 power source is exposed to the electrical Division 3 wiring loads. They will '

also provide additional assurance that the two power divisions will not become interconnected.

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• Docket Nns, 50-352

.- License Nos. NPT-39 Information Supporting a finding of No SignlTicant Hazards Consideration We have concluded that the proposed change to the LGS Unit 1 TS, which reflects a proposed modification to provide for transfer at the RSP to an emergency power source for the RCIC system steam supply line inboard containment isolation valve. HV-49-1f007, in the event of a fire, does not constitute a Significant Hazards Consideration, in support of this determination, an evaluation of each of the three standards set forth in 10 CFR 50.92 is provided below.

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

This proposed TS change reflects a modification which can only affect operation of the RCIC system steam supply line inboard containment isolation valve, its normal electrical power source (Division 3) and its emergency electrical power source (Division 1). All components are Class 1E, environmentally and seismically qualified, and installed in accordance with Class 1E and seismic requirements.

During normal operation, separation will be maintained between Division 1 and Division 3 electrical equipment by two locked open devices, a breaker in the Division 1 MCC and the breaker connected to the emergency Division 1 power source in the transfer switch; therefore, operation of the Division 1 and Division 3 electrical equipment is unaffected. The inboard and outboard isolation valves are normally open, thus, only the reactor vessel isolation function can be affected. Since the door to the terminal box containing the manual transfer switch will be locked closed with the transfer switch in the " normal" position, the probability of failure of the valve to close when required is unaffected. With the transfer switch in either position, Division 1 and Division 3 electrical equipment and the electrical containment penetration for the power supply to the HV-49-lf007 valve will be protected by two redundant breakers.

Administrative procedures will ensure that the amount of time Division 3 cabling is exposed to Division 1 power is kept at an absolute minimum. Procedures will also limit the interconnection of Division 3 circuits with Division 1 power to the valve, the MCC, the RSP, and interconnecting wiring. Wiring and circuits in the control complex will not be involved. The proposed modification does not affect the capability of the RCIC system or the RSP to perform their intended functions.

Additionally, the proposed modification does not increase the i

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, , Docket Nos. 50-352

.- License N:s. NPF-39  ;

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probable consequences of a fire as previously evaluated.  ;

Therefore, the proposed change does not cause a significant increase in the probability or consequer.ces of any accident '

previously evaluated.

2) The proposed change does not create the possibility of a new or  ;

different kind of accident from any accident previously l evaluated. i The proposed TS change reflects a modification which maintains the design functions, the separation criteria, divisional power I requirements, seismic requirements, and environmental '

qualification requirements of the RCIC system and the RSP except for the brief time of power transfer during a fire event or testing of the transfer switch when separation and divisional power requirements are not met. During the brief time when these requirements are not met, the protection discussed previously will be provided to ensure that a fault in the Division 3 circuitry will not affect the Division 1 power supply, and energization of the valve's Division 3 control circuitry from a Division 1 source in control panels is limited to the RSP. Thus, the normal plant operation will remain within the envelope of analyzed conditions, and the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated. .

3) The proposed chance does not involve a sianificant reduction in a margin of safety.

4 This proposed TS change reflects a proposed modification to provide the ability at the RSP to transfer to an emergency power source for the HV-49-If007 valve in the event the normal power source for this valve is lost as a result of a fire. The proposed modification does not affect any limiting safety system settings or other setpoints, or instrument accuracy and drift requirements. The proposed modification maintains the seismic requirements and environmental qualification requirements for ,

the RCIC system and the RSP, and the intent of the separation ^

criteria and electrical divisional power requirements. The design function of the RCIC system and the RSP will not be affected by the proposed modification. Therefore, the proposed change does not involve a significant reduction in a margin of safety, t

Docket Nos, 50-352 i f'.

License Nos. NPF-39 Information Supportino an Environmental Assessment An environmental assessment is not required for the changes proposed ,

by this Change Request because the requested changes conform to the criteria for " actions eligible for categorical exclusion" as specified in 10 CFR 51.22(c)(9). The requested changes will have no impact on the environment. The requested changes do not involve a significant hazards consideration as discussed in the preceding sections. The requested ,

changes do not involve a significant change in the types or significant increase in the amounts of any effluents that may be released offsite. In addition, the proposed changes do not involve a significant increase in individual or cumulative occupational radiation exposure. '

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Conclusion 1

The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes to the TS and have concluded that they do not involve an unreviewed safety question, or a significant hazards consideration, and will not endanger the health and safety of the public, t

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