ML20138G154
| ML20138G154 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/28/1997 |
| From: | NORTHEAST NUCLEAR ENERGY CO. |
| To: | |
| Shared Package | |
| ML20138G152 | List: |
| References | |
| NUDOCS 9705060187 | |
| Download: ML20138G154 (18) | |
Text
.
March 11, 1991 I
REACTIVITY CONTROL SYSTEMS CHARGING PUMP - SHUTDOWJ LIMITING CONDITION FOR OPERATION J
3.1.2.3 One charging pump in the boron injection flow path required by Specification 3.1.2.1 shall be OPERABLE and capable of being powered from an OPERABLE emergency power source.
APPLICABILITY: MODES 5 and 6.
ACTION:
With no charging pump OPERABLE or capable of being powered from an OPERABLE emergency power source, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.
4 SURVEILLANCE RE001ha ENTS J
o rA c H ug) 4.1.2.3.1 The above required charging pump shall be demonstrated OPERABLE by verifying, on recirculation flow, that a(differ:r.ti:1
- r:::;r)across the pump of greater than or equal to O'!! p:tf is developed w1en tested pursuant to Specification 4.0.5.
Qg 4.1.2.3.2 All charging pumps, excluding the above required OPERABLE pump, shall be demonstrated inoperable at least once per 31 days, except when the reactor vessel head is removed, by verifying that the motor circuit breakers are sr. cured in the open position i
9705060187 970428 PDR ADOCK 05000423 p
PDR MILLSTONE - UNIT 3 3/4 1-15 Amendment No. 50,60 0007
~
March 11. 1991 REA'CTIVITY CONTROL SYSTEMS CHARGING PUMPS - OPERATING LIMITING CONDITION FL6 OPERATION 3.1.2.4 At least two* charging pumps shall be OPERABLE.
APPLICABILITY: MODES 1, 2, 3, and 4.
i gIJgN:
With only one charging pump OPERABLE, restore at least two charging pumps to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY and borated to a SHUTDOWN MARGIN equivalent to at least the limit as shown in Figure 3.1-4 at 200*F within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; restore at least two charging pumps to OPERABLE status within the next 7 days or be in COLD SHUTDDWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
SURVEILLANCE REOUIREMENTS TOTAL HKA9) 4.1.2.4.1 At least two charging pumps shallobe demonstrated _0PERABLE by verifying, on recirculation flow, that a fi'";r;;;;;; pr;;;.z; across each pump of greater than or equal to(j411 ;;ij)is developed when tested pursuant to Specification 4.0.5.
gg 4.1.2.4,2 All charging pumps, except the above allowed OPERABLE pump, shall be demonstrated inoperable at least once per 31 days whenever the temperature of one or more of the' Reactor Coolant System (RCS) cold legs is less than or equal to 350'F by verifying that the motor circuit breakers are secured in the open position.
- A maximum of one centrifugal charging pump shall be OPERABLE whenever the temperature of one or more of the RCS cold legs is less than or equal to 350*F.
i i
MILLSTONE - UNIT 3 3/4 1-16 Amendment No. 60 ocer m-
December 28,1995 EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIRENENTS (Continued) 2)
A visual inspection of the containment sump and verifying that the subsystem suction inlets are not restricted by debris and that the sump components (trash racks, screens, etc.) show no evidence of structural distress or abnormal corrosion.
e.
At least once each REFUELING INTERVAL by:
l I)
Verifying that each automatic valve in the flow path actuates to its correct pocition on a Safety Injection actuation test signal, and 2)
Verifying that each of the following pumps start automatically upon receipt of a Safety Inje: tion actuation test signal:
I a)
Centrifugal charging pump, l
b)
Safety Injection pump, and c)
RHR pump.
3)
Verifying that the Residual Heat Removal pumps stop automatically upon receipt of a low-Low RWST Level test signal.
os r rnu n en o]
f.
By verifying that each f the following pumps develops the indicated differential pressure n recirculation flow when tested pursuant to Specification 4.0.5:
1)
Centrifugal charging pump 1(2411 p;if, 2)
Safety Injection pump 2(1340peij, 3)
RHR pump 1 165 psid, and 4)
Containment recirculation pump 2 130 psid.
g.
By verifying the corre-t position of each electrical and/or mechanical position stop for the following ECCS throttle valves:
1)
Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> following completion of each valve stroking operation or maintenance on the valve when the ECCS subsystems are required to be OPERABLE, and 2)
At least once each REFUELING INTERVAL.
l ECCS Throttle Valves Valve Number Valve Number 3SIH*V6 351H*V25 3SIH*V7 3SIH*V27 MILLSTONE - UNIT 3 3/4 5-5 Amendment No. 77,124 esos
. _ _ -_-.-~ -.
Dec:mber 28,1995
..EMERRENCY CORE COOLING SYSTEMS i
SURVEILLANCE REQUIRENENTS (Continued)
(
ECCS Throttle Valves t
Valve Number Valve Number 351H*V8 3SIH*V107 3SIH*V9 3SIH*V108 3SIH*V21 3S!H*V109 l
3SIH*V23 3SIH*V111 h.
By performing a
flow balance test following completion subsystem l of modifications to the ECCS subsystems that alter the 1
flow characteristics and verifying that:
1)
For centrifugal charging pump lines, with a single pump running:
a)
The sum of the injection line flow rates, exclu the highest flow rate, is greater than or equal to and
- gpm, g g,3g-b)
The total pump flow rate is less than or equal to 560 gpm.
2)
For Safety injection pump lines, with a single pump running:
a)
The sum of the injection line flow rates, excg the highest flow rate, is greater than or equal to,
- gpm, and 423 4 b)
The al pump flow rate is less than er acual to@ C a
gpm re pep rd 000 sym for O.; S ;gd.
LQJf 3)
Fcr RHR pump lines, with a single pump running, the sum of the injection line flow rates is greater than or equal to 3976 gpm.
i MILLSTONE - UNIT 3 3/4 5-6 Amer.dment No. JP,124 esos
.?
i Docket No. 50-423 B16406 1
I l
t e
I e
E i
t 1
l f
Millstone Nuclear Power Station Unit No. 3 l
Proposed Revision to Technical Specification l_
Centrifuaal Charaina Pumo and Safety Iniection Pump Surveillances PTSCR 3-13-96 Retvoed Paaes l
l l
i P
i l.
l l
i I
I f
a i
i i;
i l
April 1997 l
i
U:S. Nuclear Regulatory Commission 816406\\ Attachment 3\\Page 1 RETYPE OF PROPOSED REVISION Refer to the attached retype of the proposed revision to the Technical Specifications.
The attached retype reflects the currently issued version of the Technical i
Specifications. Pending Technical Specification revisions or Technical Specification revisions 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.
i l
. _ _ _. _ _ _. _.. _ _.. _ ___._ _.._..~ _ _... __. _ __._..-__ _ _ _ _.. _. _ _ _
REAC1IVITY_ CONTROL SYSTEMS CHARGIM PLBIP - $HUTD0WN LIMITING COMITION FOR OPERATION i
j 3.1.2.3 One charging pump in the boron injection flow path required by Specification 3.1.2.1 shall be OPERA 8LE and capable of being powered from an OPERABLE emergency power source.
l l
APPLICA8ILITY: NODES 5 and 6.
ACTION:
l With no charging pump OPERABLE or capable of being powered from an OPERABLE emergency power source, suspend all operations involving CORE ALTERATIONS or
{
positive reactivity changes.
l SURVEILLANCE REQUIREMENTS i
4.1.2.3.1 The above required charging pump shall be demonstrated OPERABLE by j
verifying, on recirculation flow, that a total head across the pump of greater i
than or equal to 5676 feet is developed when tested pursuant to Specification 4.0.5.
j l
4.1.2.3.2 All charging pumps, excluding the above required OPERABLE pump, shall be demonstrated inoperable at least once per 31 days, except when the reactor *sessel head is removed, by verifying that the motor circuit breakers are secured in the open position.
1 b
NILLSTONE - UNIT 3 3/4 1-15 Amendment No. pp, pp, essa
REACTIVITY CONTROL SYSTEMS CHARGING PUNPS - OPERATING LIMITING CONDITION FOR OPERATION 3.1.2.4 At least two' charging pumps shall be OPERABLE.
APPLICABILITY: MODES 1, 2, 3, and 4.
ACTION:
With only one charging pump OPERABLE, restore at least two charging pumps to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY and borated to a SHUTDOWN MARGIN equivalent to at least the limit as shown in Figure 3.1-4 at 200*F within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; restore at least two charging pumps to OPERABLE status within the next 7 days or be in COLD SHUTDDWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
SURVEILLANCE REQUIREMENTS 4.1.2.4.1 At least two charging pumps shall be demonstrated OPERABLE by verifying, on recirculation flow, that a total head across each pump of greater than or equal to 5676 ft is developed when tested pursuant to Specification 4.0.5.
4.1.2.4.2 All charging pumps, except the above allowed OPERABLE pump, shall be demonstrated inoperable at least once per 31 days whenever the temperature of one or more of the Reactor Coolant System (RCS) cold legs is less than or equal to 350*F by verifying that the motor circuit breakers are secured in the open position.
'A maximum of one centrifugal charging pump shall be OPERABLE whenever the temperature of one or more of the RCS cold legs is less than or equal to 350*F.
MILLSTONE - UNIT 3 3/4 1-16 Amendment No. pp, 0482
EMERGENCY CORE C0OLING SYSTEMS SURV'EILLANCEREQUIRENENTS(Continued)
~
2)
A visual inspection of the containment sump and verifying that the subsystem suction inlets are not restricted by debris and that the sump components (trash racks, screens, etc.) show no evidence of structural distress or abnormal corrosion.
e.
At least once each REFUELING INTERVAL by:
I)
Verifying that each automatic valve in the flow path actuates to its correct position on a Safety Injection actuation test signal, and 2)
Verifying that each of the following pumps start automatically upon receipt of a Safety Injection actuation test signal:
a)
Centrifugal charging pump, b)
Safety Injection pump, and c)
RHR pump.
3)
Verifying that the Residual Heat Removal pumps stop automatically upon receipt of a Low-Low RWST Level test signal.
f.
By verifying that each of the following pumps develops the indicated differential pressure or total head on recirculation flow when l tested pursuant to Specification 4.0.5:
1)
Centrifugal charging pump 1 5676 feet, 2)
Safety Injection pump 2 3240 feet, 3)
RHR pump 2 165 psid, and 4)
Containment recirculation pump 2 130 psid.
g.
By verifying the correct position of each electrical and/or mechanical position stop for the following ECCS throttle valves:
1)
Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> following completion of each valve stroking operation or maintenance on the valve when the ECCS subsystems are required to be OPERABLE, and 2)
At least once each REFUELING INTERVAL.
ECCS Throttle Valves Valve Number Valve Number 3SIH*V6 3SIH*V25 3SIH*V7 3SIH*V27 NILLSTONE - UNIT 3 3/4 5-5 Amendment No. pp, M,
om
o ENERGENCY C0RE COOLING SYSTEMS
]
SURNEILLANCEREQUIREMENTS(Continued) i i
ECCS Throttle Valves Yalve N"=her Valve Nu=her 3SIH*V8 3SIH*V107 3SIH*V9 3SIH*V108 3SIH*V21 3SIH*V109 3SIH*V23 3SIH*V111 h.
By performing a
flow balance test following completion of l
modifications to the ECCS subsystems that alter the subsystem flow characteristics and verifying that:
l 1)
For centrifugal charging pump lines, with a single pump running:
a)
The sum of the injection line flow rates, excluding the highest flow rate, is greater than or equal to 310.5 gpm, l 1
and b)
The total pump flow rate is less than or equal to 560 l
gpm.
2)
For Safety Injection pump lines, with a single pump running:
i a)-
The sum of the injection line flow rates, excluding the j
highest flow rate, is greater than or equal to 423.4 gpm, l and I
b)
The total pump flow rate is less than or equal to 675 gpm. l 3)
For RHR pump lines, with a single pump running, the sum of the injection line flow rates is greater than or equal to 3976 gpm.
l NILLSTONE - UNIT 3 3/4 5-6 Amendment No. pp, W,
oes i
i
)
Docket No. 50-423 B16406 1
Millstone Nuclear Power Station Unit No. 3 Proposed Revision to Technical Specification Centrifuaal Charaina Pump and Safety iniection Pump Surveillances PTSCR 3-13-96 Backaround and Safety Assessment l
April 1997
U:S. Nuciaar Regulatory Commission B16406\\ Attachment 4\\Page 1 Backaround Throttle valves are used in the charging and safety injection lines to limit maximum injection flow to the reactor coolant system to preclude pump run-out, balance the resistance in the lines, &nd ensure minimum injection to support design bases analyses. High velocities through the throttle valves in their current throttled position can cause valve erosion. An additional flow resistance, a restricting orifice, is being added to eight of the twelve injection lines so that the throttle valves can be opened farther. Opening the throttle will reduce the velocity through the valves so that valve erosion will not be a concem. The sizing of the restricting orifices and the associated re-throttling of the throttle valves will be in accordance with Regulatory Guide 1.82, Sumps for Emergency Core Cooling And Containment Spray Systems, in that the openings will be larger than the sump screen mesh opening size.
Safety Assessment The requirements of surveillances 4.1.2.3.1, 4.1.2.4.1 and 4.5.2.f are being modified to increase the required pump differential pressure developed during surveillance testing for the centrifugal charging pump from 2411 psid to 5676 ft. (2464 psid) and the safety injection pump from 1348 psid to 3240 ft. (1406 psid). The differential pressures and associated flows are consistent with the current Final Safety Analysis Report licensing basis analyses for Millstone Unit No. 3.
Also, the referenced units for the centrifugal charging and safety injection pumps are changed from differential pressure measured in psid to total head measured in feet in surveillances.
The requirements of surveillances 4.5.2.h are being modified to decrease the required individual centrifugal charging pump injection line flow rate sum from 339 gpm to 310.5 gpm and safety injection pump injection line flow rate sum from 442.5 gpm to 423.4 gpm.
These changes to decrease the required surveillance minimum flow rates for the centrifugal charging and safety injection pumps are consistent with the current Final S:
Analysis Report licensing basis analyses for Millstone Unit No. 3.
The requirements of surveillance 4.5.2.h are being modified to increase the required individual safety injection pump total flow rate for Pump A from 670 gpm to 675 gpm and for Pump B from 650 gpm to 675 gpm. These changes to increase the required individual safety injection pump total flow rate are consistent with the current Final Safety Analysis Report licensing basis analyses for Millstone Unit No. 3.
I l
l U.'S. Nucl:ar Regulatory Commission B16406\\ Attachment 4\\Page 2 The following table summarizes the changes.
Technical Specification Current Requirement Proposed Requirement Section 4.5.2.f.1)
Centrifugal Charging pump Centrifugal Charging pump 4.1.2.3.1 differential pressure on differential pressure on 4.1.2.4.1 recirculation flow recirculation flow 2 2411 psid
- 5676 ft (2464 psid) 4.5.2.f.2)
Safety injection pump Safety injection pump i
differential pressure on differential pressure on I
recirculation flow 31348 psid recirculation flow 2 3240 ft (1406 psid) 4.5.2.h.1)a)
Single Centrifugal Charging Single Centrifugal Charging pump flow, excluding the pump flow, excluding the highest flow rate,2 339 gpm highest flow rate,2 310.5 gpm 4.5.2.h.2)a)
Single Safety injection pump Single Safety injection pump flow, excluding the highest flow, excluding the highest flow rate,2 442.5 gpm flow rate,2 423.4 gpm 4.5.2.h.2)b)
Safety injection Pump A total Safety Injection Pump A total flow 5670 gpm flow 5675 gpm Safety injection Pump B total Safety injection Pump B total flow 5 650 gpm flow 5 675 gpm The proposed changes for minimum flows and required differential pressures are consistent with the current Final Safety Analysis Report licensing basis analyses for Millstone Unit No. 3.
The minimum flow requirements are established by the injection l
phase of a Loss of Coolant Accident (LOCA) when the pump suction source is the Refueling Water Storage Tank (RWST). The increase in the allowed Safety injection pump flow is the maximum continuous runout flow limitation from the pump vendor and is consistent with the current Final Safety Analysis Report. The maximum flow requirements are established during the recirculation phase of a LOCA when the suction source of the pumps is the recirculation spray pumps which provide a head boost to the pumps. These changes to the required flows widen the band of allowable flows. This widening of the band will provide additional flow margin.
This increase in margin between maximum and minimum flow requirements will re-establish pump performance degradation margin, which had been limited because the original design did not adequately evaluate the head boost during recirculation.
in conclusion:
The proposed Technical Specification changes are consistent with the design basis analyses and the design runout limitations of the pumps. The proposed pump minimum j
differential pressures are the calculated required surveillance values consistent with the
U:S. Nucbar Regulatory Commission B16406\\ Attachment 4\\Page 3 required minimum pump flow rates. The addition of the words "or total head" to the surveillance requirement has no effect since the definition of total head is the differential pressure across a pump. Modifying the maximum and minimum flows can not cause an accident. Also, since the minimum flows are consistent with the design basis analyses requirements, there can not be any adverse impact on the consequences of any accident. The safety injection pumps are disabled such that they can not be a potential mass addition source when the cold Overpressure Protection System is required to be operable. Therefore, the increase in Safety injection pump maximum flow can not impact the cold overpressure accident analysis.
1 The changes do not involve any changes to the way that the pumps are operated, only changes to the required surveillance criterion of the pumps. The pumps will be used post-accident the same way as they are used prior to the change. The surveillance requirements are consistent with the design basis requirements.
Therefore, the changes do not modify plant response to any accident.
The changes modify the flow requirements and the required differential pressure on recirculation. The required differential pressure on recirculation is a calculated value which is consistent with the corresponding required minimum flow. The maximum flow for the Safety injection pump does not exceed the runout limitations established by the pump vendor. Safety injection pump operation at a higher allowed maximum flow requires a larger pump Net Positive Suction Head (NPSH). The higher NPSH required is below the minimum NPSH available both during injection when the suction source is the RWST and during recirculation when the suction source is the recirculation spray pumps. The installation of the restricting orifices and the resetting of the throttle valves will result in their opening size being larger than the sump screen size. Therefore, the proposed changes cannot introduce a new failure mode.
Based on the above, the proposed Technical Specification changes are safe.
Docket No. 50-423 B16406 Millstone Nuclear Power Station Unit No. 3 Proposed Revision to Technical Specification Centrifuaal Charaina Pumo and Safety Iniection Pumo Surveillances PTSCR 3-13-96 Sionificant Hazards Consideration and Environmental Consideration i
April 1997
U.'S. Nuclear Regulatory Commission B16406\\ Attachment 5\\Page 1 SIGNIFICANT HAZARD DETERMINATION NNECO has reviewed the proposed changes in accordance with 10CFR50.92 and has concluded that the changes do not involve a significant hazards consideration (SHC).
The basis for this conclusion is that the three criteria of 10CFR50.92(c) are not satisfied. The proposed changes do not involve a SHC because the changes would not:
1.
Involve a significant increase in the probability or consequence of an accident previously evaluated.
The proposed changes to Technical Specification Surveillances 4.1.2.3.1, 4.1.2.4.1 and 4.5.2.f to increase the required discharge pressure for the centrifugal charging pumps on recirculation flow during surveillance testing from 2 2411 psid to 2 5676 ft (2464 psid) are concistent with centrifugal charging pump design requirements. The change in the referenced units from differential pressure measured in psid to total head measured in feet for the centrifugal charging pumps and safety injection pumps during surveillance testing is an administrative change.
The proposed changes to Technical Specification Surveillance 4.5.2.f to increase the required discharge pressure for the safety injection pumps on recirculation flow during surveillanco testing from 21348 psid to 2 3240 ft (1406 psid) are consistent with safety injecion pump design requirements.
The proposed changes to Surveillance 4.5.2.h: to decrease the required individual centrifugal charging pump injection line flow rate sum from 2339 gpm to 2310.5 gpm, decrease the required individual safety injection pump injection line flow rate sum from 1442.5 gpm to 2423.4 gpm, increase the required individual safety injection Pump A total flow rate from 2670 gpm to 2675 gpm, and increase the required individual safety injection Pump B total flow rate from 2650 gpm to 1675 gpm are consistent with centrifugal charging pump and safety injection pump design requirements.
The proposed changes are consistent with equipment design requirements and performing surveillance testing does not involve a significant increase in the probability of an accident previously evaluated.
The proposed changes to the surveillance testing of the centrifugal charging pumps and safety injection pumps provide the necessary assurance that the pumps will function consistent with the flows used in the accident analyses and does not nvolve a significant increase in the consequence of an accident previously evaluated.
U.*S. Nuclear Regulatory Commission B16406\\ Attachment 5\\Page 2 Therefore, the proposed changes do not involve a significant increase in the probability or consequence of an accident previously evaluated.
2.
Create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed changes to the surveillance testing of the centrifugal charging pumps and safety injection pumps do not change the operation of the centrifugal charging or safety injection systems or any of its components during normal or accident evaluations. The increase in the allowed maximum safety injection pump flow does not impact the cold overpressure accident analysis.
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 4.1.2.3.1, 4.1.2.4.1 and 4.5.2.f to increase the required discharge pressure for the centrifugal charging pumps on recirculation flow during surveillance testing from 12411 psid to 2 5676 ft (2464 psid) provides an acceptable margin between the required surveillance and design pump performance to provide assurance that the pumps will operate consistent with the assumptions of the accident analysis.
The proposed changes to Techrical Specification Surveillance 4.5.2.f to increase the required discharge pressure for the safety injection pumps on recirculation flow during surveillance testing from 21348 psid to 2 3240 ft (1406 psid) provides an acceptable margin between the required surveillance and design pump performance to provide assurance that the safety injection pumps will operate consistent with the assumptions of the accident analysis.
The proposed changes to Surveillance 4.5.2.h to decrease the required individual centrifugal charging pump injection line flow rate sum from 2339 gpm to 3310.5 gpm, decrease the required individual safety injection pump injection line flow rate sum from 3442.5 gpm to 2423.4 gpm, increase the required individual safety injection Pump A total flow rate from 2670 gpm to 2675 gpm and increase the required individual safety injection Pump B total flow rate from 1650 gpm to 2675 gpm are consistent with the assumptions of the accident analysis. The maximum allowed safety injection flow is consistent with the vendor recommendation for maximum continuos runout flow. Also, the safety injection pumps are disabled during specific normal operating modes, consistent with the assumptions of the accident analysis, to ensure that they can not be an injection source when the cold overpressure system is requ: red to be operable and thus the
U.'S. Nucl:ar R:gulatory Commission B16406\\ Attachment 5\\Page 3 increase in maximum safety injection pump flow does not affect the cold overpressure accident analysis.
The change in the referenced units in Technical Specification Surveillances 4.1.2.3.1, 4.1.2.4.1 and 4.5.2.f from differential pressure measured in psid to total head measured in feet for the centrifugal charging pumps and safety injection pumps during surveillance testing is an administrative change.
Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
In conclusion, based on the information provided, it is determined that the proposed 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 requirements of an environmentalimpact statement.