Text

Proposed Tech Specs 4.3.3.6 & 4.6.4.1 Re Surveillance Testing
	ML20137Y116
Person / Time
Site:	Millstone
Issue date:	04/15/1997
From:	; NORTHEAST NUCLEAR ENERGY CO.
To:	;
Shared Package
ML20137Y105	List: B16345, Application for Amend to License NPF-49,requesting Rev to Hydrogen Monitors Surveillances; ML20137Y116;
References
	NUDOCS 9704220323
	Download: ML20137Y116 (23)
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LIMITING CONDITION FOR OPERATION (Continued)

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'3 setion taken, the cause of the inoperability, and the plans and

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i schedule for restoring the channel to CPERABLE status.

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f. ' With the number of OPERABLE channels for the reactor v

. level monitor less than the minimum channels OPERABLE requirements of Table 3.3-10, either restore the inoperable chan

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down or:

Initiate an alternate method of monitoring the reactor vessel 1.

inventory; Prepare and submit a Special Report to the Comission pursuant following the event 2.

Specification 6.9.2 within 30 days outlining the action taken, the cause of the inoperability, and to

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the plans and schedule for restoring the channel (s) to OPERABL k

status; and

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,F-Restore the channel (s) to OPERABLE status at the n 3.

refueling. -

Entry into an OPERAT!0NAL MDDE is permitted while subject to thes l

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ACTION requirements.

SURVElttANCE REQUIREMENTS

{ 4.1.3.6. 13 Each accident monitoring instrumentation channel shall be demon-strated OPERABLE by performance of the CHANNEL CHECK and CHA 4.0.0.0 l

at the frequencies shown in Table 4.3-7.

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Insert 4.3.3.6 4.3.3.6.2 Each hydrogen monitor shall also be demonstrated OPERABLE by a Hydrogen Sensor Calibration and an Analog Channel Operational Test at least once per 92 days on a STAGGERED TEST BASIS.

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TABLE 4.3-7(Continued)

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ACCIDEN_flON!)f0 RIM Ilt5TIMENAT10ll_SUMEILUWICE REGUIRBERS b

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Containment Area

.High Range Radiation Monitor M

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Reactor Yessel Water Level M

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Containment ::yJ ;;;. Monitor R

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Neutron Flux n.p iti j

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CHA.EL CALIBRATI0li may consist of an electronic calibration of the channel, not inc,luding the detector,

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for range decades above 10 R/h and a one point calibration check of the detector below 10 R/h with an h

installed or. portable gamma source.

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3/4.5.4 COMBUSTIBLE SAS C NTROL i b WYDROBEN MONITORS a

LIMITING CONDITION FOR OPERATION a -

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~3.6.4.1 Two independent containment hydrogen monitors sh.all be OPERABLE.

APPLICABilfTY: MODES 1, 2. and 3.

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a.

With one hydrogen monitor inoperable, restore the inoperable monitor to OPERABLE status within 30 days or be in at least HOT STANDBY within

!F The next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at least.. HOT SHUTDOWN within the following 6

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b.

With both hydrogen monitors inoperable, restore at least one monitor j'

to CPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least H0T STANDdY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at least HOT SHUTDOWN within the l

following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

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Entry into an OPERATIONAL N0DE is permitted while subject to these i

ACTION requirements.

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SURVEILLANCE REQUIRENDfTS 1

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Insert 4.6.4.1 4.6.4.1 Each hydrogen monitor shall be demonstrated OPERABLE :

By the performance of a CHANNEL CHECK at least once per 12 a.

hours, and

b. By the performance of a Hydrogen Sensor Calibration and an ANALOG CHANNEL OPERATIONAL TEST at least once per 92 days on a STAGGERED TEST BASIS, and

c. By the performance of a CHANNEL CALIBRATION at least once each REFUELING INTERVAL.

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i INSTRUMENTATION SA$ES i;.

- REMOTE SHUTDOWN INSTRUMENTATION (Continued) instrumentation control, and power circuits and trarisfer switches necessary to eliminate effects of the fire and allow operation of instrumentation, con-t trol and pcwer circuits required to achieve and maintain a safe shutdown con-i.

dition are independent of areas where a fire could damaae systems normally 1r

- used to shut down the reactor. This capability is consistent with General j;

Design Criterion 3 and Appendix R to 10 CFR Part 50.

l 3/4.3.3.6 ACCIDENT MONITORING INSTRUMENTATION The OPERABILITY of the accident monitoring instrumentation ensures that sufficient information is available on selected plant parameters to monitor

!6 and assess these variables following an accident. The instrumentation in-

.c1Med in this specification are those instruments provided to monitor key j'

vsriables, designated as Cat 1 instruments following the guidance for classification contained in Re tory Guide 1.g7, Revision 2 *Instrumenta-tion for Light-Water-Cooled N lear Power Plants To Assess Piant and Environs Conditions During and Following an Accident."

In the event more than ~four sensors in a Reactor Vessel Level channel are inoperable repairs may only be possib's durin the next fifueling outage.

i This is bec,ause the sensors are accessible on1 after the missile shield and reactor vessel head are removed.

It is not fe sible to repair a channel except during a refueling outage when the missile shield and reactor vessel a!/

head are removed to refuel the core.

If only one channel'is inoperable, it l \\

should be restored to OPERABLE status in a refueling outage as soon as reason-ably possible.

If both channels are inoperable, at least one channel shall be 3

restored to OPERABLE status in the nearest refueling outage.

3/4.3.3.7 Deleted.

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NILLSTONE - UNIT 3 8 3/4 3-5 Amendment No. 7, 7J. 84 om g

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Insert B4.3.3.6 I

Hydrogen Monitors are provided to detect high hydrogen concentration conditions that l

represent a potential for containment breach from a hydrogen explosion. Containment l

hydrogen concentration is also important in verifying the adequacy of mitigating actions.

l The requirement to perform a hydrogen sensor calibration at least every 92 days is based l

upon vendor recommendations to maintain sensor calibration. This calibration consists of l

a two point calibration, utilizing gas containing approximately one percent hydrogen gas i

for one of the calibration points, and gas containing approximately four percent hydrogen gas for the other calibration point.

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5:ptsab2r 19, 1991 r l3 CONTAINMENT SYSTEMS l{'N BASEE i

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i The. OPERABILITY of the contair. ment isclation valves ensure' that the

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containment atmosphere will be isolated from : e outside en '.onnent in the event of a release of radioactive material to the wo =... ment atmosphere or pressurization of the containment and is consistent with the requirements of 4

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General Desigr. Criteria 54 through 57 of Appendix A to 10 CFR Part 50.

Containment isolation within the time limits specified for these isolation i_

valves designed to close automatically ensures that the release of radioactive material to the environment will be consistent with the assumptions used in the analyses for a' LOCA. FSAR Table 6.2-65 lists all containment isolation i

valves. The addition of deletion of any containment isolation valve shall be made in accordance with Section 50.59 of 10CFR50 and approved by the Plant Operation Review Comittee.

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b 3/4.6.4 COMBUST 1BLE GAS CONTROL The OPERABILITY of the equipment and systems required for the detection and control of hydrogen gas ensures that this equipment will be available to l

maintain the hydrogen concentration within containment below its flamabic

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limit during post-LOCA conditions.

Either recombiner unit or the Mechanical j

Vacuum Pumps are capable of controlling the expected hydrogen generation associated with: (1) zirconium-water reactions, (2) radiolytic decomposition

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of water, and (3) corrosion of metals within containment. These Hydrogen 1 (-

Control Systems are consistent with the recommendations of Regulatory Guide i

1.7, " Control of Combustible Gas Concentrations in Containment Following a i

LOCA," March 1971.

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l The Post-LOCA performance of the hydrogen recombiner blowers is based on a i

series of equations supplied by the blower manufactuer. These equations are

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also the basis of the acceptance criteria used in the surveillance procedure.

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j-The required performance was based on starting containment conditions before j

the LOCA of 10.5g psia (total pressure),120*F and 1005r, relative humidiy.

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The surveillance procedure shall use the following methods to verify acceptable blower flow rate:

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Definitions ar.d constants j

6 CFM = cubic feet per minute 1

l RPM = revolutions per minute j

blower RPM = 3550-

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Blower ft3/ revolution =.028 ft3'

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Standard CFM = gas volume converted to conditions of 68'F and 14.7 psia.

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MILLSTONE - UNIT 3 B 3/4 6-3 Amendment No. 25,63 es4s 1

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' Insert B4.6.4.1 i~

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i Hydrogen Monitors are provided to detect high hydrogen concemration conditions that represent a potential for containment breach from a hydrogen explosion. ' Containment i

hydrogen concentration is also important in verifying the adequacy of mitigating actions.

j The requirement to perform a hydrogen sensor calibration at least every 92 days is based j

upon vendor recommendations to maintain' sensor calibration. This calibration consists of

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a two point calibration, utilizing gas containing approximately one percent hydrogen gas

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for one of the calibration points, and gas containing approximately four percent hydrogen

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gas for the other calibration point.

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. ',s Docket No. 50-423 B16345 Millstone Nuclear Power Station Unit No. 3 Proposed Revision to Technical Specification Hydrogen Monitor Surveillances (PTSCR 3-11-96)

Retyped Paoes April 1997 i

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B16345\\ Attachment 3\\Page 1 l

i RETYPE OF PROPOSED CHANGES Refer to the attached retype of the proposed changes to !he Technical Specifications.

j The attached retype reflects the currently issued version of the Technical Specifications. Pending Technical Specification changes or Technical Specification changes issued subsequent to this submittal are not reflected in the enclosed retype.

The enclosed retype should be checked for continuity with Technical Specifications prior to issuance.

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LIMITING COM ITION FOR OPERATION (Continued) action taken, the caur-of the inoperability, and the plans and schedule for restoring t,.a channel to OPERABLE status.

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With the number of OPERABLE channels for the reactor vessel water level monitor less than the minimum channels OPERABLE requirements of Table 3.3-10, either restore the inoperable channel (s) to OPER-ABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months if repairs are feasible without shutting down or:

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Initiate an alternate method of monitoring the reactor vessel inventory; t

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2.

Prepare and submit a Special Report to the Commission pursuant j

to Specification 6.9.2 within 30 days following the event i

outlining the action taken, the cause of the inoperability, and the plans and schedule for restoring the channel (s) to OPERABLE l

status; and I

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Restore the channel (s) to OPERABLE status at the next scheduled l

refueling.

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Entry into an OPERATIONAL N00E ir permitted while subject to these j

ACTION requirements.

t SURVEILLANCE REQUIREMENTS i

4 4.3.3.6.1 Each accident monitoring instrumentation channelstrated OPERABLE by shall be demon-1 l

at the frequencies shown in Table 4.3-7.

j 4.3.3.6.2 Each hydrogen monitor shall also be demonstrated OPERABLE by a Hydrogen Sensor Calibration and an ANALOG CHANNEL OPERATIONAL TEST at least once per 92 days on a STAGGERED TEST BASIS.

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MILLSTONE - UNIT 3 3/4 3-59a Amendment No. (7, J7, 77, 0480 O

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TABLE 4.3-7 (Continued) 5 ACCIDENT NOMITORING INSTRUNENTATION SURVEILLANCE REOUIRDENTS E

E CHANNEL CHANNEL Q

INSTRUNENT CHECK CALIBRATION w

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Containment Area - High Range Radiation Monitor N

R*

17.

Reactor Vessel Water Level N

R**

18.

Containment Hydrogen Monitor S

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19.

Neutron Flux N

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CHANNEL CALIBRATION may consist of an electronic calibration of the channel, not including the detector, for range decades above 10 R/h and a one point calibration check of the detector below 10 R/h with an installed or portable gamma source.

- Electronic calibration from the ICC cabinets only.

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CONTAlletENT SYSTEMS 3/4.6.4 CONBUSTIBLE GAS CONTROL J

HYDR 0 GEN NONITORS LIMITING ColWITION FOR OPERATION I

3.6.4.I Two independent containment hydrogen monitors shall be OPERABLE.

APPLICABILITY: MODES I, 2, and 3.

ACTION:

a.

With one hydrogen monitor inoperable, restore the inoperable monitor to OPERABLE status within 30 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b.

With both hydrogen monitors inoperable, restore at least one monitor to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c.

Entry into an OPERATIONAL MODE is permitted while subject to these ACTION requirements, i

SURVEILLANCE REQUIRENENTS l

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4.6.4.I Each hydrogen monitor shall be demonstrated OPERABLE:

a.

By the performance of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , i

and b.

By the performance of a Hydrogen Sensor Calibration and an ANALOG CHANNEL OPERATIONAL TEST at least once per 92 days on a STAGGERED i

TEST BASIS, and j

c.

By the performance of a CHANNEL CALIBRATION at least once each REFUELING INTERVAL.

M.ILLSTONE - UNIT 3 3/4 6-16 Amendment No. 77, J7, Jpp, o es

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l INSTRUNENTATION 4

na m REMOTE SHUTDOWN INSTRUMENTATION (Continued) instrumentation, control, and power circuits and transfer switches necessary to eliminate effects of the fire and allow operation of instrumentation, con-trol and power circuits required to achieve and maintain a safe shutdown con-

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dition are independent of areas where a fire could damage systems normally used to shut down the reactor. This capability is consistent with General Design Criterion 3 and Appendix R to 10 CFR Part 50.

3/4.3.3.6 ACCIDENT MONITORING INSTRUMENTATION The OPERABILITY of the accident monitoring instrumentation ensures that sufficient information is availkble on selected plant parameters to monitor and assess these variables following an accident. The instrumentation in-cluded in this specification are those instruments providea to monitor key variables, designated as Category 1 instruments following the guidance for

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classification contained in Regulatory Guide 1.97, Revision 2, "Instrumenta-tion for Light-Water-Cooled Nuclear Power Plants To Assess Plant and Environs Conditions During and Following an Accident."

In the event more than four sensors in a Reactor Vessel Level channel are inoperable, repairs may only be possible during the next refueling outage.

This is because the sensors are accessible only after the missile shield and reactor vessel head are removed.

It is not feasible to repair a channel except during a refueling outage when the missile shield and reactor vessel head are removed to refuel the core.

If only one channel is inoperable, it should be restored to OPERABLE status in a refueling outage as soon as reason-ably possible.

If both channels are inoperable, at least one channel shall be restored to OPERABLE status in the nearest refueling outage.

Hydrogen Monitors are provided to detect high hydrogen concentration

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conditions that represent a potential for containment breach from a hydrogen explosion.

Containment hydrogen concentration is also important in verifying the adequacy of mitigating actions. Tiie requirement to perform a hydrogen sensor calibration at least once every 92 days is based upon vendor recommendations to maintain sensor calibration.

This calibration consists of j

a two point calibration, utilizing gas containing approximately one percent hydrogen gas for one of the calibration points, and gas containing approximately four percent hydrogen gas for the other calibration point.

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3/4.3.3.7 Deleted.

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MILLSTONE - UNIT 3 5 3/4 3-5 Amendment No. 7, 77, 77, 0489 A

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i-CONTAllBIENT SYSTENS i

BASES i

3/4.6.3 CONTAINMENT ISOLATION VALVES The OPERABILITY of the containment isolation valves ensures that the containment atmosphere will be isolated from the outside environment in the 4

event of a release of radioactive material to the containment atmosphere or pressurization of the containment and is consistent with the requirements of General Design Criteria 54 through 57 of Appendix A to 10 CFR Part 50.

1 Containment isolation within the time limits specified for these isolation i

valves designed to close automatically ensures that the release of radioactive i

material to the environment will be consistent with the assumptions used in the analyses for a LOCA.

FSAR Table 6.2-65 lists all containment isolation valves. The addition of deletion of any containment isolation valve shall be made in accordance with Section 50.59 of 10CFR50 and approved by the Plant Operation Review Committee.

3/4.6.4 COMBUSTIBLE GAS CONTROL Hydrogen Monitors are provided to detect high hydrogen concentration conditions that represent a potential for containment breach from a hydrogen l

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explosion.

Containment hydrogen concentration is also important in verifying the adequacy of mitigating actions. The requirement to perform a hydrogen i

sensor calibration at least every 92 days is based upon vendor recommendations i

i to maintain sensor calibration. This calibration consists of a two point calibration, utilizing gas containing approximately one percent hydrogen gas i

for one of the calibration points, and gas containing approximately four

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percent hydrogen gas for the other calibration point.

The OPERABILITY of the equipment and systems required for the detection j

and control of hydrogen gas ensures.that this equipment will be available to j

maintain the hydrogen concentration within containment below its flammable limit during post-LOCA conditions.

Either recombiner unit or the Mechanical Vacuum Pumps are capable of controlling the expected hydrogen generation j

associated with: (1) zirconium-water reactions, (2) radiolytic decomposition of water, and (3) corrosion of metals within containment. These Hydrogen Control Systems are consistent with the recommendations of Regulatory Guide 1.7, " Control of Combustible Gas Concentrations in Containment Following a LOCA," March 1971.

The Post-LOCA performance of the hydrogen recombiner blowers is based on a series of equations supplied by the blower manufacturer. These equations are also the basis of the. acceptance criteria used in the surveillance procedure.

The required performance was based on starting containment conditions before the LOCA of 10.59 psia (total pressure),120*F and 100%

relative humidify.

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The surveillance procedure shall use the following methods to verify l

acceptable blower flow rate:

MILLSTONE - UNIT 3 83/46-3 Amendment No. 77,77, 1

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CONTAll0ENT SYSTEMS BASES 3/4.6.4 COMBUSTIBLE GAS CONTROL (Continued) l 1.

Definitions and constants CFM = cubic feet per minute RPM = revolutions per minute l

Blower RPM - 3550 Blower ft'/ revolution

.028 ft8 l

Standard CFM = gas volume converted to conditions of 68'F cnd 14.7 psia.

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MILLSTONE - UNIT 3 5 3/4 6-3a Amendment No.

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Docket No. 50-42_3 B16345-l l

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l Millsto,ie Nuclear Power Station Unit No. 3 i

Proposed Revision to Technical Specification 0'

Hydrogen Monitor Surveillances (PTSCR 3-11-96)-

Backaround and Safety Assessment 1

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i-i; April 1997 I

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U.S. Nuclear R:gulatory Commission B16345\\ Attachment 4\\Page 1 4

Backaround NNECO in letters dated June 2,1994 and August 25,1994 requested changes to modify the channel calibration surveillance interval associated with the hydrogen monitors from once per 92 days to once a refueling interval. This change was consistent with the guidance provided in Generic Letter 93-05. The NRC in Amendment 100 approved NNECO's requested changes.

NNECO subsequently determined that the surveillance extension was not consistent with the recommendations of the equipment vendor, Whittaker Electronic Systems, formerly Exosensor, and that a refueling interval testing frequency was not appropriate for the hydrogen sensor. This proposed change will correct the testing interval of the hydrogen sensor to be consistent with vendor testing recommendations.

Safety Assessment The testing interval for performing a hydrogen sensor calibration in Surveillances 4.3.3.6 and 4.6.4.1 is changed from once a refueling interval to once per 92 days on a staggered test basis by creating a new surveillance test. This change is in accordance with vendor recommended practice for maintaining sensor calibration. The sensor test will be a two point calibration, utilizing a test gas containing approximately one percent hydrogen for one calibration point, and approximately four percent hydrogen for the second calibration point. The calibration surveillance of the hydrogen sensor is consistent with the design and operation of the hydrogen monitor system and the calibration test will not require the opening of any containment isolation valve. The current requirements to periodically perform a Channel Check, Analog Channel Operation Test and Channel Calibration of the Hydrogen Monitor System are not effected by this change.

The testing of the hydrogen monitor system is specified in Surveillances 4.3.3.6 and 4.6.4.1.

However, the surveillance interval for conducting a channel check and the requirement to perform an analog channel operational test are not consistent. This proposed change corrects this situation by changing the channel check frequency from once per 31 days to once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months on Table 4.3-7 Item 18 and adding surveillance 4.3.3.6.2 to require an analog channel operational test. These are considered administrative changes.

Surveillance 4.6.4.1 currently specifies the surveillance testing to be performed and the description of the sample gas to be used during the surveillances. To clarify the surveillance testing required, this proposed change divides the testing requirements into three groups based on the test frequency and moves the description of the sample gas from surveillance 4.6.4.1 to the bases sections for surveillances 4.6.4.1 and 4.3.3.6.

These changes improve the readability of surveillance 4.6.4.1 and the consistency of the bases for surveillances 4.3.3.6 and 4.6.4.1. The Bases for

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U.S. Nucitar Regulatory Commission j

B16345\\ Attachment 4\\Page 2 i

l surveillances 4.3.3.6 and 4.6.4.1 are also being modified to expand the description of l

surveillance testing. These proposed changes are considered administrative changes.

Based on the above, the proposed Technical Specification changes are safe.

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Docket No. 50-423 i

B16345 1

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Millstone Nuclear Power Station Unit Noc 3 Proposed Revision to Technical Specification.

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' Hydrogen Monitor Surveillances l

(PTSCR 3-11-96) l Sianificant Hazards Consideration and Environmental Consideration l

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U.S. Nuctsar Regulatory Commission j.

B16345\\ Attachment 5\\Page 1 l'

I Sionificant Hazards Consideratior]

t NNECO has reviewed the proposed changes in accordance with 10CFR 50.92 arid has I

concluded that the change does not involve a significant hazards consideration (SHC).

The bases for this conclusion is that the three criteria of 10CFR 50.92(c) are not '

i satisfied. The proposed changes do not involve a SHC because the changes would l

not:

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1 Involve a significant increase in the probability or consequence of an l

l accident previously evaluated.

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l-The proposed change to Technical Specification Surveillances 4.3.3.6 and l

4.6.4.1 to perform a hydrogen sensor calibration test once per 92 days on a j

staggered test basis is consistent with the design and operation of the hydrogen

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l monitor system. The hydrogen monitoring system is independent of the reactor coolsnt system boundary, has no effect on the probability of occurrence of a loss of coolant accident and performing surveillance testing does not significantly increase the probabi'ity of an accident previously evaluated.

The proposed change to Technical Specification -Surveillances 4.3.3.6 and 4.6.4.1 to perform a hydrogen sensor calibration test will not require the opening j

of a containment isolation valve and conducting surveillance testing does not l

significantly increase the consequence of an accident previously evaluated.

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The proposed change to Technical Specification Surveillances 4.3.3.6 and 4.6.4.1 to change the channel check frequency from once per 31 days to once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months on Table 4.3-7 Item 18, add an analog r.hannel operational test to surveillance 4.3.3.6.2 and make editorial changes to the surveillances and bases sections are considered administrative changes Administrative changes do not involve a significant increase in the probability or consequence of an j

accident previously evaluated.

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Therefore, the proposed changes do not involve a significant increase in the probability or consequence of an accident previously evaluated.

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

The proposed changes to Technical Specification Surveillances 4.3.3.6 and 4.6.4.1 to perform a hydrogen sensor calibration test do not add any new 1

equipment to the plant and do not affect the way any system important to safety is operated either in normal or under accident conditions.

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U.S. Nucl:ar Regulatory Commission B16345\\ Attachment 5\\Page 2 The proposed changes to Technical Specification Surveillances 4.3.3.6 and 4.6.4.1 to change the channel check frequency from once per 31 days to once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months on Table 4.3-7 Item 18, add an analog channel operational test to surveillance 4.3.3.6.2 and make editorial changes to the surveillances and bases sections are considered administrative changes.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3 Involve a significant reduction in a margin of safety.

The proposed changes to Technical Specification Surveillances 4.3.3.6 and 4.6.4.1 to perform a hydrogen sensor calibration test will provide assurance of expected instrument performance under accident conditions and performing surveillance testing do not involve a significarn reduction in a margin of safety.

The proposed changes to Technical Specification Surveillances 4.3.3.6 and 4.6.4.1 to change the channel check frequency from once per 31 days to once por 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months on Table 4.3-7 Item 18, add an analog channel operational test to surveillance 4.3.3.6.2 and make editorial changes to the surveillances and baser sections are considered administrative changes. Administrative changes do not Wolve a significant reduction in a margin of safety.

Therefore, the proposed chages do not invn!ve a significant reduction in a margin of safety.

In conclusion, based on the information provided, it is determined that the proposed j

changes do not involve an SHC.

Environmental Considerations NNECO has reviewed the proposed license amendment against the criteria of 10CFR 51.22 for environmental considerations. The proposed changes do not involve a SHC, do not significantly increase the type and amounts of effluents that may be released off site, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, NNECO concludes that the proposed changes meet the criteria delineated in 10CFR 51.22(c)(9) for categorical exclusion from the i

requirements of an environmentalimpact statement l

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ML20137Y116

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