ML20087E028

Proposed Tech Specs Reducing Minimum Operable Containment Radiation High Signal Channels

ML20087E028
Person / Time
Site:	Fort Calhoun
Issue date:	08/04/1995
From:	OMAHA PUBLIC POWER DISTRICT
To:
Shared Package
ML20087E021	List: LIC-95-0151, Forwards Application for Amend to License DPR-40,proposing Changes to Ts,To Reduce Minimum Operable Containment Radiation High Signal Channels ML20087E024 ML20087E028
References
NUDOCS 9508110289
Download: ML20087E028 (14)

Text

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

O

.- DEMNITIONS PROTECTIVE SYSTEMS (Continued)

Eneineered Safety Featum Imriem The system which utilizes relay contact outputs from individualinstrument chaaaata to provide a dual channel signal to Ladapaadaatly initiate the actuation of the engirw.4 safety feature equipment. Two logic subsystems, termed A and B, are provided; each subsystem is composed of four channels wired to provide indapaadaat safety feature initiation signals on a 2-ousof-4 basis.

Degree of Redundancy The difference between the number of operable channels and the number of channeln widch when tripped will cause an automatic system trip.

INSTRUMENTATION SURVEIT T ANCE Channel Chack A qualitative determination of acceptable operability by observation of channel behavior during l normal plant operation. This determination shall where feasible, include comparison of the channel with other independent channels measuring the same variable.

Channel Functional Test Injection of a simulated signal into the channel to verify that it is operable, including any alamt and/or trip initiating action.

Channel Calibration Adjustment of channel output such that it responds, with acceptable range and accuracy, to known values of the parameter which the channel measures. Calibration shall encompasseet entire channel, including equipment action, alarms, interlocks or trip, and shall be deemed to include the channel functional test.

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4 Amendment No. 86rk 9508110289 950804 PDR ADOCK 05000285 P PDR

t . 2.0 LIMrrING CONDmONS FOR OPERATION .

.( 2.15: rnstrumentation and control Sv=**ms (Continued)

-(5) In the event that any of the following Emergency Auxiliary Feedwater Panet instrumentation or control circuits become inopssble, either restore the inoperable component (s) to operable status within 'seven-days, or be-in hot shutdown within the next twelve hours. 'Ihis specification is applicable in Modes 1 and 2.

1 Steam Generator Level, Wide Range (AI-179)

Steam Generator Level, Narrow Range (AI-179)

Steam Generator Pressure (AI-179)

Pressurizer Pressure (AI-179)

Basia During plant operation, the complete instrumentation systems will normally be in service. Reactor safety is provided by the reactor protection. system, which -

automatically initiates appropriate action to prevent exceeding established limits. l Safety is not compromised, however, by continuing operating with certain instrumentation channels out of service since provisions were made for this in the plant design. This specification outlines limiting conditions for operation nea**=y -

to preserve the effectiveness of the reactor control and protection system when any one or more of the channels are out of service.

All reactor protection and almost all engineered safety feature channels are supplied-with sufficient redundancy to provide the capability for channel test'at power, except l

for backup channels such as derived circuits in engineered safeguards control system.

a When one of the four channels is taken out of service for maintenance, the protective ,

.I system logic can be changed to a two-out-of-three coincidence for a reactor trip by bypassing the removed channel. If the bypass is not effected, the out-of-service' channel (Power Removed) assumes a tripped condition (except high rate-of-change of power, high power level and high pressurizer pressure),m which results in a one-out-of-three channel logic. Ifin the 2 of 4 logic system of the reactor protective system one channel is bypassed and a second channel manually placed in a tripped condition,

, the resulting logic is 1 of 2. At rated power, the minimum operable high-power level channel is 3 in order to provide adequate power tilt detection. If only 2 channels are operable, the reactor power level is reduced to 70% rated power which protects the reactor from possibly exceeding design peaking factors due to undetected flux tilts and from exceeding dropped CEA peaking factors.

All engineered safety features are initiated by 2-out-of-4 logic matrices except )

containment high radiation which operates on a 1-out-of-2 basis.nThe containment radiation high signal isolates the containment pressure relief, air sample and purge system valves.

References The number of in&lled c%nels

.i

-for N Oowtmnment RadW&n %h (1) USAR, Section 7.2.7.1 Pd h **

• l l

I 2-66a Amendment No.MS -

88. " 5

~ _

l

.j I

TABLE 2-3

. L .

... Instrument Operatino Requirements for Engineered Safety Features i

Test,

. Maintenance Minimum Minimum Permissible and Operable - Degree of Bypass Inoperable ,

No. Functional Unit Channels Redundancy Condi tion Bypass '

1 Safety Injection i A Manual 1 None None N/A B High Containment Pressure A 2(a)(d) 1 During Leak (f)

B 2(a)(d) 1 Test C Pressurizer Low / Low Pressure A 2(a)(d) 1 Reactor Coolant (f) 8 2(a)(d) 1 Pressure Less Than 1700 psia )

2- Containment Spray A Manual 1 None None N/A B High Containment - 1 Pressure A 2(a)(c)(d)1. During Leak (f) ,

B 2(a)(c)(d)1 Test ,

t i'

C Pressurizer Low / Low j A

2(a)(c)(d)1 Reactor Coolant (f) ]

8 2(a)(c)(d)1. ~Than Pressure 1700 Less psia (b) 3 Recirculation  :

A Manual 1 None None -

N/A B SIRW Tank Low '

Level A 2(a),(4f$l y Nne g@

B f '

2(a)ht)(h)1 4 Emergency Off-Site Power Trip -

A Manual 3(e) None None. N/A B Emergency Bus Low Voltage (Each Bus) '

-Loss of Voltage 2(dl 1 Reactor Coolant (f)

-Degraded Voltana Temperature Less ,

2(a)(d) y  ;

Than 300 F . '

~

2-68 Amendment No. H , $$.

c- . ; '

TABLE 2-3 j (Continued) H

.I l

i If the channel becomes inoperable, that channel must be placed in the bypassed - )

condition within eight hours from time of. discovery of loss of operability.  :

If the channel is not returned to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> from time  !

of discovery of loss of operability,- one of the eight channels may continue  :

to be placed in the bypassed condition provided the Plant Review Committee' has reviewed and documented the judgment concerning prolonged operation in .  !

bypass of the defective. channel. . The channel shall be returned to operable status no later than during the next cold shutdown. If one.of.the four  ;

channels on one steam generator is in prolonged bypass and a channel on the  ;

other steam generator becomes inoperable, the second inoperable channel must.

be placed in bypass within eight hours from time of discovery of' loss ~ of-operability. If one of the inoperable channels is not returned' to operable '

status within seven days from the time of discovery of the second loss of.

operability, the unit must be placed in hot shutdown within the following .

m

?';~9 If'one" channel' becomes;' inoperable ^,"' that:' channel:must' be'placed in~the bypassed I ^ ~'~" condition with1' n eight hours from time of discovery of loss of, operabilityeg"*

The channel shall be returned to operable status ~'~'~gno later than'during ~ ~ " " , ' " ' ~"the,nent c3] dgutdgwgf ~~ "" ~~ '"" ~~'~~

k 7:l; IfTlinimum operable' channel conditions'are' reached,"both' inoperable"chtaaels

~~;'sf5hpe placed in the bypassed condition within eight' hours from time of'~'^*

discovery of loss of operability, wIf one of'the inoperable channels'11s not a returned to op'erable status within' 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> from time of discovery!of the" I

'second loss'of operabilityi a ' unit shutdown must' be initiated'(see'~^"'~

' ' ' " ' " ' ' ^ ' ^ ' ~ ~ " ' ~ ' ~ " ~ " ~ ' ' ~ " ' ' ~ ^ ' ' ~ ~ " ' ^ ' "

i Speci fication 2.15(2)) .,"^ ' ,

1 i

2-68b AmendmentNo.lJMI r

g -

(

,..+^ TABLE 2-4

, ~ INSTRUMENT OPERATING CONDITIONS FOR ISOLATION FUNCTIONS Test, M al=#- ,=ce Minimum Minimum - Permissible and Operable Degree of Bypass ",--"-'

& Functional Unit Channels Redundancy Candition Aznam 1 Containment isolation A Manual 1 None None N/A B Contaiamant High Pressure A 2**8 1 Dunng Imak (0 B 2**> 1 Test C Pressurper Low /Iew A 2* ** Reactor Coolant 1

(0 B 2"*' 1 Pressure Less Than 1700 psia *'

2 Steam Generator Isolation A Manual 1 None None N/A B Steam Generator Isolation i None None N/A' (i) Steam Generator low Pressure A 2/ Steam 1/ Steam Steam Generator (Q Gen ") Gen- Pressure less Than ,

600 psia" j B 2/ Steam 1/ Steam Gen *> Gen (ii) Contamment High Pressure A 2"*' 1 During laak (0 B 2* *' 1 Test -

3 Ventilation Isolation A Manual - 1 None None N/A B Cone====aat High T Radiation A B

[1/* .

1/*

None None If Contam=aat Relief and (O

Purge Valves Are Closed -

a A and B circuits each have 4 channels.

b Auto removal of bypass prior to exceeding 1700 psia.

c Auto rernoval of bypass prior to exceeding 600 psia.

2-69 Amendment No. SS,a?,!^!,!!2J53' f

TABLE 2 4 (Contin e Cen%nmerit er 4xiNey BuHd4

+ca'ns d

A and both actuated fby eitherVx f L r Etiating stack chan r

e If minimum operable channel conditions are reached, one inoperable channel must be placed in the tripped condition within eight hours from the time of discovery of loss of i

operability."The remaining inoperable channel may be bypassed for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> from the time of discovery of loss of operability and, if an inoperable channel is not returned to operable status within this time frame, a unit shutdown must be initiated (see Specification 2.15(2)).

f If one channel becomes inoperable, that channel must be placed in the tripped or bypassed condition within eight hours from the time of discovery ofloss of operability.

If bypassed and that channel is not returnal to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> from the time of discovery of loss of operability, that channel must be placed in the tripped ,

condition within the following eight hours. .(See Specification 2.15(1) and exception associated with mai rtumber of insTallect alnnnels -for On%inmed RadaTiou Hsf Sigas L is two -Por 'furfoses oe SpecnWedhrt 2.isQ),

-x 2-69a Amendment No. 88,:08,J5r

e~

TABLE 3-2 (Continued) ,

MINIMUM FREOUENCIES FOR CHECKS. CALIBRATIONS AND TESTING OF ENGINEERED SAFETY FEATURES. INSTRUMENTATION AND CO!TTROLS Cimonel Description Surveillance Function Frecuency Surveillance Method

4. Containment Pressure a. Calibrate R a. Known pressure applied to sensors High Signal and CPilS actuation logic verified.

h. Test Q h. Pressure switch operation simulated one circuit at a time.

l.

5. Containnent Spray a. Test Q a. . Simulation of PPLS and CPilS 2/4 l Logic logie using built-in testing system.

Both " standby power" and "no stand-by power

• circuits will be tested for A and B channels. Test will verify functioning of initiation circuits of all equipment normally operated by safety feature actu-ation signals.

h. Test R b. Complete automatic test initiated sensor operation (Item I(h) rnd 4(b)) and including all normal automatic operations.

6. Containment Radiation a. Check D a. ik,...-l .c J...g; A. .cJ r.d liigh Signal' *  : .x..d :d I;.uh uxd ;

=ify * .. . ..._; c,,.c. L. . j CHANNEL. CHECK l 1

3-8 Amendment No.132 , .16'f-

_ _ _ _ _ _ .._._-_________._____,___,____________m_ - -

_ . _ _ _ _ . . - u 2_ - _ - -

_ m'

y

. ' 7

. L, TABLE 3-2 (Continuedi s MINIMUM FREOUENCIES FOR CHECKS. CALIBRATIONS AND TESTING OF ENGINEERED SAFETY FEATURES. INSTRUMENTATION AND CONTROLS Chamiel DAscription Sunciliance Function Frequency Serveillance Method --

CHANNEL FuNCrioNAL TEST

6. (continued) b. Test Q b. De=c . c,-d :a ;c.. c ai.;;;;cd ;; '._.. .

h6 -- ree m ed n!;n! :: ::d'y ..

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C-*-- ** *

c. Calibrate R c. lectumic Calibration performed at refueling frequency. Primary calibratiim performed with exposure to radioactive sources only when required by the secondary and electronic calibration.

7. Manual Safety Injection a. Test R a. Manual initiation.

Initiation

8. Manual Containment a. Test R a. Manual initiation.

Isolation initiation

b. Check ' R h. Observe isolation valves closure.

9. Manual Initiation a. Test R s. Manual switch operation; pumps and Containment Spray valves tested seperately.

10. Automatic Load a. Test Q a. Proper operation will be verified during Sequencess safety feature actuation test of item 3(a) above.

II. Diesel Testing See Technical Specification 3.7 '

3-9 Amendment No. 54,!!!,!50 ;03-w

- - 2 . _ . - _ -_.____m_._-_______.____-___.______.m ._m m_ __

U'.S. Nuclear Regulatory Comission LIC-95-0151 1

l ATTACHMENT B i

l i

l DISCUSSION, JUSTIFICATION AND NO SIGNIFICANT HAZARDS CONSIDERATION DISCUSSION AND JUSTIFICATION:

The Omaha Public Power District (0 PPD) proposes to amend the Fort Calbaun Station (FCS) Unit No.1 Technical Specifications (TS) to revise the requirements for the Containment Radiation High Signal (CRHS) and the Safety Injection and Refueling .

Water (SIRW) Tank Low Signal (STLS) contained in TS 2.15, Tables 2-3 and 2-4. l Specification 3.1, Table 3-2 will also be revised to include administrative changes j to the CRHS surveillance methods to be consistent with the applicable surveillance l functions. The Specification 2.15 Basis is being revised to clarify that the j number of installed channels for CRHS is two. The term " SOURCE CHECK" is being  ;

deleted from the Definitions section. j Safety In.iection and Refuelina Water (SIRW) Tank Low Sianal (STLS)

The proposed change revises Table 2-3, " Instrument Operating Requirements for Engineered Safety Features" Item No. 3B (SIRW Tank Low Level A & B) reference notes l for the " Minimum Operable Channels" and " Test Maintenance and Inoperable Bypass."

It is proposed to revise the required actions for an inoperable STLS channel from placing the inoperable channel (s) in the tripped condition, if one channel becomes inoperable or upon reaching minimum operable channel conditions, to placing the inoperable channel (s) in the bypassed condition.

A Recirculation Actuation Signal (RAS) is generated upon receipt of a Containment Pressure High Signal (CPHS) or a Pressurizer Pressure Low Signal (PPLS) and an STLS. The RAS is designed to automatically realign the safety injection and containment spray systems for long-tenn operation following a Design Basis Accident (DBA) by diverting the suction of the high pressure safety injection and l containment spray pumps from the SIRW tank to the containment sump, when the l contents of the SIRW tank are nearing depletion. l The STLS, as most Engineered Safety Feature (ESF) instrumentation, is designed with two actuation circuits, A and B, with 4 sensor channels per actuation circuit. The initiation of an STLS requires that two out of the four level sensors for one channel of the actuation circuit detect a low-low level. In addition to the A and B acteation circuits, the system is designed with redundant backup relays for the opposite channel's prime relays. These backup relays provide a derived signal to the opposite actuation circuit and are designated as Al and Bl.

The current TS requirement for an inoperable STLS channel is to place the inoperable channel in the tripped or bypassed condition within eight (8) hours from the time of discovery of loss of operability. If the channel is not restored to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> from the time of discovery of loss of operability, the channel must be placed in the tripped condition within the following eight (8) hours.

I

9 The FCS ESF system relies on a 2-out-of-4 logic to initiate an ESF. The effect of placing an inoperable channel in the tripped condition satisfies one of the two required signals such that the actuation circuit would require a signal from 1 of 3 level sensors (i.e., the logic becomes 1-out-of-3). When a channel is in the bypassed condition, the actuation circuit requires a signal from 2 of 3 level sensors (i .e. , the logic becomes 2-out-of-3) .

Due to the derived signal, if a channel was in the tripped condition and a single failure occurred, (that being one channel of STLS on either A or B circuits), a premature STLS would be generated. During a DBA with a valid CPHS or PPLS, this single failure would prevent the contents of the SIRW tank from being injected into the reactor coolant system. The resulting logic of placing the SIRW tank low level channels in " bypass" rather than " trip" would not cause a premature switchover of the high pressure safety injection pumps to the containment sump and it would not prevent the switchover when needed. This scenario was discussed in an NRC memorandum from Mr. R. C. Jones to Mr. T. R. Quay dated November 22, 1994.

Because of these concerns, it is proposed that the TS be revised to require that when one channel of STLS is inoperable, the channel must be placed in BYPASS and the channel will be restored to operable status no later than the next cold shutdown. If two channels become inoperable, then both inoperable channels must ,

be placed in BYPASS within eight hours from time of discovery of loss of l operability. One channel must be restored to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or a plant shutdown must be initiated. )

Containment Radiation Hiah Sianal (CRHS) l The proposed change revises Table 2-4, " Instrument Operating Conditions for Isolation Functions" Item No. 3B, Containment High Radiation A and B, " Minimum Operable Channels" from "2" to "1". This change also revises Table 2-4, reference note (d) by correcting the verbiage regarding the two initiating channels. Table 2-4, reference note (d) states that the A and B circuits are both actuated by either one of the two initiating channels. This is being revised to state that the A and 8 trains are both actuated by either the Containment or Auxiliary Building Exhaust Stack initiating channels. The reference note (d) and the Basis section on page 2-66a is also being revised to clarify that the number of installed channels for CRHS is two.

The CRHS is designed with 2 actuation trains, A and B. The signal is generated from either the Containment Noble Gas radiation monitor or the Auxiliary Building Exhaust Stack Noble Gas ra.iietion monitor. A third noble gas radiation monitor is installed as a " swing" monitor that can be aligned to either the Auxiliary Building Stack or Containment. In addition to the A and B actuation trains, the system is designed with redundant backup relays for the opposite train's prime relays. These backup relays provide a derived signal to the opposite actuation train and are designated as Al and Bl. The derived signals, Al and B1, are not considered individual channels, thus each actuation train only has one initiating channel.

As indicated in Table 2-4, under the column for Minimum Degree of Redundancy, there is no requirement to have redundancy on the individual actuation trains.

j 2

-The CRHS is a one-out-of-two signal. This configuration was approved by the NRC in Amendment 152, ~ which deleted the requirements to have particulate and iodine ,

radiation monitors as input to the actuation trains. The proposed change is similar to the CE Standard Technical Specifications (STS) contained in NUREG-0212 (Revision 2) for the CRHS, as the STS indicates the total number of installed 4

channels for gaseous monitors is one. Redundancy is provided by maintaining ~one radiation monitor initiating channel on two independent ESF actuation trains. The ESF actuation system supervisory A and B safeguard initiation channels will not be affected by this proposed TS change. The minimum level of Engineered Safeguards performance acceptable for the DBA, termed minimum safeguards, will still be maintained in accordance with IEEE 279 - 1971, " Criteria for Protection Systems for Nuclear Power Generating Stations."

Administrative Chanaes This proposed change also revises TS 3.1, Table 3-2 " Minimum Frequencies for Checks, Calibrations and Testing of Engineered Safety Features, Instrumentation and Controls." Specifically, this administrative change revises the Containment Radiation High Signal surveillance methods for the check and test surveillance functions to " channel check" and " channel functional test", respectively, to be consistent with the applicable surveillance functions and the defined TS terminology. This proposed change to Table 3-2 is administrative in nature and

- does not affect plant equipment or operations. Also included in this administrative change is the deletion of the term " source check" from the TS Definitions section. As a result of the administrative revisions to TS 3.1, Table 3-2, " source check" will no longer be used in the FCS TS.

It is also proposed to revise the Amendment numbers listed on the bottom of page 2-66a. The initial issuance of page 2-66a was in Amendment 88. Amendments 8, 20, 25, 32, and 43 affected page 2-66 and therefore are being deleted.

3

.. 1

..- j 8 ASIS FOR NO SIGNIFICANT HAZARDS CONSIDERATION:

The proposed changes do not involve significant hazards consideration because operation of Fort Calhoun Station Unit No.1 in accordance with these changes would not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated.

The Omaha Public Power District (0 PPD) proposes to revise Technical Specification (T5,' 2.15, Table 2-3 by revising the requirement for placing the Safety Injection Refueling Water (SIRW) tank low level channel (s) in the tripped conditicn to placing them in the bypassed condition. Due to the derived signal, if a channel was in the tripped condition and a single failure occurred, (that being one channel of STLS on either A or B circuits),

a premature SIRW tank low signal (STLS) would be generated. During a design basis accident (DBA) with a valid Containment Pressure High Signal (CPHS) or Pressurizer Pressure Low Signal (PPLS), this single failure would prevent the contents of the SIRW tank from being injected into the reactor coolant system. The resulting logic of placing the SIRW tank low level channels in BYPASS rather than TRIP would not cause a premature switchover of the high pressure safety injection pumps to the containment sump and it would not prevent the switchover when needed.

OPPD also proposes to revise TS 2.15, Table 2-4, by reducing the number of l minimum operable Containment Radiation High Signal (CRHS) channels from two l

to one. This proposed change revises the requirements of TS 2.15 to coincide with changes to the TS and Offsite Dose Calculation Manual (0DCM) that were implemented by TS Amendment 152. The Engineered Safety Feature (ESF) actuation system supervisory A and B safeguard initiation channels will not be affected by this proposed TS change. The minimum level of engineered safeguards performance acceptable for the DBA, (i.e., minimum safeguards) will continue to be maintained in accordance with IEEE 279 - 1971, " Criteria ,

for Protection Systems for Nuclear Power Generating Stations."

Included in this change are administrative revisions to TS 3.1, Table 3-2, for replacing the current surveillance methods for checking and testing the CRHS instrumentation with the defined terms " CHANNEL CHECK" and " CHANNEL FUNCTIONAL TEST," respectively. These proposed revisions are administrative in nature and reflect TS-defined terminology for the instrumentation surveillance methods utilized to ensure that the CRHS instrumentation is operable. A channel check requires a qualitative determination of acceptable operability by observation of channel behavior during normal plant operation.

A channel functional test requires the injection of a simulated signal into the channel to verify that it is operable, including any alarm and/or trip initiating actions. Other proposed administrative changes include deleting i the term " SOURCE CHECK" from the TS Definitions section as source check will i no longer be used in the FCS TS and adding verbiage to the TS 2.15 Basis for l clarifying that the number of installed channels for CRHS is two.

f l Therefore, the proposed change, as described above, would not increase the i

probability or consequences of an accident previously evaluated.

4

(2) Create the possibility of a new or different kind of accident from any accident previously evaluated.

There will be no physical alterations to the plant configuration, changes to setpoint values, or changes to the implementation of setpoints or limits as a result of the proposed changes to TS 2.15, Tables 2-3 and 2-4. The proposed revisions to TS 3.1, Table 3-2 are administrative changes to make the TS more accurately reflect defined terminology and the methods utilized to ensure that the CRHS instrumentation is operable. The proposed TS revisions do not require any changes to the present methods of verifying CRHS instrumentation operability. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

(3) Involve a significant reduction in a margin of safety.

There are no changes to the equipment or plant operations as a result of the changes being made to the number of minimum operable CRHS channels. The proposed changes to the STL5 wjll require that the inoperable channel be placed in BYPASS rather than TRIP. This action would ensure that a single failure would not cause a premature safety injection switchover to the containment sump and would not prevent switchover when needed. Therefore, this proposed change does not reduce a margin of safety.

The proposed revisions to TS 3.1, Table 3-2 are adininistrative changes to make the TS more accurately reflect defined terminology and the methods utilized to ensure that the CRHS instrumentation is operable. The proposed TS revisions do not require any changes to the present methods of verifying CRHS instrumentation operability. The proposed changes to the Definitions and TS 2.15 Basis sections are administrative in nature. Therefore, these proposed changes do not involve a significant reduction in a margin of safety.

Therefore based on the above considerations, it is OPPD's position that this proposed amendment does not involve significant hazards considerations as defined by 10 CFR 50.92 and the proposed changes will not result in a condition which significantly alters the impact of the Station on the environment. Reducing the minimum operable CRHS channels from two to one, revising the CRHS surveillance methods to CHANNEL CHECK and CHANNEL FUNCTIONAL TEST, deleting the " SOURCE CHECK" definition, and changing the STLS requirement for placing the inoperable channel (s) in BYPASS rather than TRIP involve no change in the amount or type of any effluent that may be released offsite and there is no increase in individual or cumulative occupational radiation exposure. Thus, the proposed changes meet the eligibility ,

criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and pursuant to l 10 CFR 51.22(b) no environmental assessment need be prepared.

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