ML20215E814

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Application for Amend to License NPF-6,changing Tech Specs Re Cesec Code Verification,Spent Fuel Pool Expansion (Generic Ltr 85-19) & Correction of Miscellaneous Errors. Fee Paid
ML20215E814
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 12/12/1986
From: Tison Campbell
ARKANSAS POWER & LIGHT CO.
To: Knighton G
Office of Nuclear Reactor Regulation
Shared Package
ML20215E819 List:
References
2CAN128601, GL-85-19, NUDOCS 8612230130
Download: ML20215E814 (17)
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ARKANSAS POWER & LIGHT COMPANY l FIRST COMMERCIAL BUILDING /P.O. BOX 551/UTTLE ROCK, ARKANSAS 72203/(5011 371-7901 December 12, 1986 T. GENE CAMPBELL Vice President Nuclear Operations 2CAN128601 Mr. George W. Knighton, Director PWR Project Directorate No. 7 Division of PWR Licensing - 8 U. S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF-6 Facility Operating License Amendment Administrative Change Request

Dear Mr. Knighton:

The Arkansas Power & Light Company hereby requests an amendment of the ANO Unit 2 Operating License and associated Technical Specifications. This amendment constitutes administrative changes with respect to CESEC Code Verification, Spent Fuel Pool Expansion, Generic Letter 85-19,

" Reporting Requirements on Primary Coolant Iodine Spikes," and correction of miscellaneous errors.

Some pages submitted herewith for change may have also been submitted under separate cover (2CAN118605) for Generic Letter 83-43 changes, " Reporting Requirements of 10CFR Part 50, Sections 50.72 and 50.7', and Standard Technical Specifications." In such cases, the respectiie Generic Letter 83-43 proposed changes have been retained at an of the same pages also affected by this amendment request.

In accordance with 10CFR50.91(a)(1), AP&L has separ tely evaluated the proposed changes using the criteria in 10CFR50.92(c) and has determined that these changes involve no significant hazards consideration. The bases for these determinations are included in the enclosed submittal.

Also in accordance with 10CFR50.91(b)(1), a copy of this amendment request with enclosure has been sent to Ms. Greta Dicus, Director, Division of Radiation Control and Emergency Management, Arkansas Department of Health.

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MEMBER MiDOLE SOUTH UTILITIES SYSTEM fe-C c kJfC N#" $'lSO 90

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Mr. Ge:rge W. Knightsn D:cemb:r 12, 1986 A check in the amount.of $150.00 is included herewith as an application fee in accordance with 10CFR170.12(c).

Very truly yours, A As T. Gene Campbell TGC:RP:lw Enclosures cc: Ms. Greta Dicus, Director Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street Little Rock, AR 72205 l

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.f STATE OF ARKANSAS )

) SS COUNTY OF PULASKI )

I, T. Gene Campbell, being duly sworn, subscribe to and say that I am Vice President for Arkansas Power & Light Company; that I have full authority to execute this oath; that I have read the document numbered 2CAN128601 and know the contents thereof; and that to the best of my knowledge,.information and belief the statements in it are true.

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T. Gene Campbell SUBSCRIBED AND SWORN T0 before me, a Notary ublic in and for the County and State above named, this b day of L f TA ,

1986.

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Notary Pub c 14y Commission Expires:

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4 ENCLOSURE

-PROPOSED OPERATING LICENSE CHANGE AND PROPOSED TECHNICAL SPECIFICATION CHANGES IN THE MATTER OF AMENDING LICENSE NO. NPF-6 ARKANSAS POWER & LIGHT COMPANY ARKANSAS NUCLEAR ONE, UNIT 2 DOCKET NO. 50-368 DECEMBER 12, 1986 2CAN128601

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-ARKANSAS POWER & LIGHT COMPANY PROPOSED CHANGE NO. 1 Change Section 2.C.(3)(g) [page 6] of the Unit 2 Facility Operating License to delete a license condition as indicated on the revised copy attached to this transmittal.

DISCUSSION This proposed change is a result of AP&L meeting the requirements of the licensa condition for verification of the transient analysi_s code, CESEC-III. After submitting CESEC verification test results for Commission review and after receipt of Commission approval, this license condition is no longer required and should be deleted.

BACKGROUND The NRC accepted the CESEC-III code as an acceptable computer program for use in licensing applications for calculating FSAR Chapter 15 events.

Correspondence from Mr. James R. Miller (NRC) to Mr. John M. Griffin (AP&L),

dated March 20, 1984 (2CNA038403) provided Commission approval and the Safety Evaluation explaining that AP&L has fulfilled all of the requirements regarding the verification of the CESEC code. In the same correspondence, it was noted that the Commission now needed an application from AP&L in order to take action to delete the license condition pertaining to CESEC code verification.

DETERMINATION OF SIGNIFICANT HAZARDS Arkansas Power & Light Company has performed an analysis of the proposed change in accordance with 10CFR90.91(a)(1) regarding no significant hazards consideration, using the standards in 10CFR90.92(c).

A discussion of those standards as they relate to this amendment request follows:

Criterion 1 - Does Not Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated CESEC is a simplified thermal-hydraulic transient computer program developtd for analyzing FSAR Chapter 15 transient and accident events. CESEC-III is an upgraded revision to calculate increasingly complex hydraulic behaviors for predicting system response for PWR non-LOCA initiating events. The Commission has issued a separate Safety  ;

Evaluation concerning the acceptability of this code for providing a conservative and acceptable licensing analysis.

Since this change to the operating license does not affect 2CAN128601 1 j

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previously analyzed events or any parameters associated with plant operations,.it does not involve a significan_t increase in the probability or consequences of an accident previously evaluated.

Criterion 2 - Does Not Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated The proposed change deletes a license condition since the provisions for CESEC code verification have been met by AP&L.

Since this change is administrative and does not involve any

'new safety information which has not been considered by a previous Commission safety review, it does not create the possibility of a new or different kind of accident from any previously evaluated.

Criterion 3 - Does Not Involve a Significant Reduction in the Margin of Safety The proposed change does not involve a change in a safety limit, a limiting condition for operation, or a surveillance requirement for operating the facility. Therefore, it does not involve a significant reduction in the margin of safety.

The Commission has provided guidance concerning the application of these standards by providing examples of amendments that are considered not likely to involve significant hazards considerations. The proposed amendment most closely matches example (i): "a purely administrative change." Since the criteria to satisfy this operating license condition have been found acceptable for relief by the Commission in a prior review and Safety Evaluation, deletion of Section 2.c.(3)(g) of the ANO-Unit 2 Facility Operating License constitutes an administrative action.

PROPOSED CHANGE NO. 2 a) Change Specification 3.4.8 (pages '/4 4-18 and 3/4 4-19) of the Unit 2 Technical Specifications to delete ACTION a. in its entirety, to redesignate ACTION b. as ACTION a., and to redesignate ACTION d. as ACTION c. as well as delete the requirements for a REPORTABLE OCCURRENCE for primary coolant iodine spikes, b) Change Bases 3/4.4.8 (page B 3/4 4-5) to delete the last two sentences of the second paragraph related to the 800 hour0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> limit for coolant iodine activity.

c) Change Specification 6.9.1.5 (pages 6-15 and 6-16) to add a new 6.9.1.5.e. to require that reporting for iodine spiking is an item to be included in the Annual Report.

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9" d) Change Specification 6.9.2.g. (page 6-19) by deleting said specification since the reporting requirements are being reduced from a Special Report to inclusion in the Annual Report.

DISCUSSION This' proposed change makes conforming changes to the Technical Specifications as required by the Commission in Generic Letter No. 85-19, concerning reporting requirements on primary coolant specific activity limits.

-BACKGROUND Generic Letter No. 83-43 was issued to provide guidance on Technical Specification revisions required as a result of the implerrentation of .

10CFR50.73 and the revisions to 10CFR50.72. That generic letter discussed changing the reporting requirement from a Licensee Event Report to a Special Report for operating conditions where the specific activity limits of the reactor coolant are exceeded. Generic Letter No. 85-19 was issued, as part of the Commission's continuing program to delete unnecessary reporting requirements, specifically addressing primary coolant iodine spikes. That generic letter discussed changing the reporting requirements for iodine spiking from a Special Report to an item which is to be included in the Annual Report. Generic Letter No. 85-19 also discussed the Commission's determination that the requirement to shutdown a plant if coolant iodine activity limits are exceeded for 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12-month period can be eliminated. Requirements for monitoring iodine activity in the primary coolant are to be continued however. The proposed changes noted above are in accordance with the Standard Technical Specification as set out in Generic Letter 85-19.

DETERMINATION OF SIGNIFICANT HAZARDS Arkansas Power & Light Company has performed an analysis of the proposed change in accordance with 10CFR90.91(a)(1) regarding no significant hazards consideration, using the standards in 10CFR90.92(c).

A discussion of those standards as they relate to this amendment request follows:

Criterion 1 - Does Not Involve a Significant Increase in the Probability or Consequences of a Accident Previously Evaluated Since the change from a Special Report to inclusion in the Annual Report for iodine spiking activity affect reportability requirements only, it does not affect the intended operation of the plant or its design bases. The removal of the shutdown requirement as a result of coolant iodine activity affects only the few, non-continuous events of iodine spiking over a yearly cumulative time period.

Since the surveillance requirements for specific activity 2CAN128601 3

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c will remain unchanged and shutdown requirements will remain for exceeding the iodine activity limit in a 48-hour continuous time interval, the change will not affect the intended operation of the plant or the design bases.

Accordingly, these changes will not involve a significant

-increase in the probability or consequences of an accident previously evaluated.

Criteria 2 - Does Not Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated These conforming changes in accordance with the generic letter are administrative in nature and do not adversely affect the modes of plant operation or the operability of safety related equipment, or change the design or configuration of the plant. Therefore, the proposed changes would not create the possibility of a new or different kind of accident from any previously evaluated.

Criteria 3 - Does Not Involve a Significant Reduction in the Margin of Safety Since the proposed change regarding reportability requirements clarifies wording of the text in accordance with the generic letter and has no effect on any plant safety parameters or accident mitigation capabilities, it would not involve a significant reduction in the margin of safety.

Elimination of the shutdown requirement in the case of coolant iodine activity limits being exceeded over a cumulative time period also would not involve a significant reduction in the margin of safety since shutdown limits for iodine activity that have been retained ensure that appropriate actions would be initiated long before accumulating 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> above the iodine activity limit. In addition, 10CFR05.72(b)(1)(fi) requires the Commission to be immediately notified of fuel cladding failures that exceed excepted values or that are caused by unexcepted factors, which could lead to iodine activity above the limit.

PROPOSED CHANGE NO. 3 Change Sections 5.6.1.1 and 5.6.3 (page 5-5) of the Unit 2 Technical Specifications to revise design feature descriptions of the Spent Fuel Storage Pool to conform with changes made as a result of a prior amendment.

DISCUSSION This proposed change makes necessary revisions in the discussion of the design features as a result of the spent fuel storage expansion for Units 1 and 2. The proposed change was inadvertently omitted from the original Technical Specification change request. Since the proposed change is based 2CAN128601 4

y upon the considerations and evaluations of the original (and subsequently approved) request, it is an administrative change for clarification purposes only.

BACKGROUND AP&L proposed amendments to Facility Operating Licenses for Arkansas Nuclear One, Units 1 and 2 spent fuel storage designs in a letter from Mr. William Cavanaugh (AP&L) to Messrs. J. F. Stolz and R. A. Clark (NRC),

dated February 17, 1983 (OCAN028302). The Commission evaluated the safety considerations and approved Amendments Nos. 76 and 43 for the respective Units 1 and 2 in correspondence from Messrs. J. F. Stolz and R. A. Clark (NRC) to Mr. John M. Griffin (AP&L), dated April 15, 1983 (0CNA048314). The amendments revised the provisions in the Technical Specifications to allow modifications in the spent fuel design for ANO-1&2 which would increase the spent fuel storage capabilities for AN0-1 from 589 spaces to 968 spaces and for ANO-2 from 485 spaces to 988 spaces. This expansion was accomplished by replacing the existing spent fuel storage racks with new high density storage racks.

Revisions to several technical specifications were involved; however, the changes affecting Specifications 5.6.1.1 and 5.6.3 were not submitted at the time of the original request for ANO-2 Amendment No. 43 due to an administrative oversight. AP&L desires to correct the error in order for these specifications to properly address the current design features.

DETERMINATION OF SIGNIFICANT HAZARDS Arkansas Power & Light Company has performed an analysis of the proposed change in accordance with 10CFR90.91(a)(1) regarding no significant hazards consideration, using the standards in 10CFR90.92(c).

A discussion of those standards as they relate to this amendment request follows:

Criterion 1 - Does Not Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated The proposed change is a change in the wording for administrative purposes to conform to a previously approved amendment. Since the change is clarifying and does not involve a deviation from AP&L's and the Commission's previous safety evaluation for spent fuel storage pool expansion, it will not create the possibility of a new or different kind of accident from any previously evaluated.

Criterion 2 - Does Not Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated The proposed change will not create the possibility of a new or different kind of accident from any previously evaluated since it corrects an error of omission in a prior submittal 2CAN 28601 5 t

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and does not; introduce new systems, modes of operation, failure modes or any. plant modifications from those

-previously analyzed.

< -Criterion 3 ' Does Not' Involve a Significant Reduction in the Margin of.

Safety.

.The proposed change will not' involve a significant reduction in-the. margin of safety since the change is clarifying, based on 'a prior submittal, and has:no effect on any plant safety

parameters or. accident mitigation. capabilities.

PROPOSED CHANGE NO. 4 a) . Change-Specification 3.1.1.4 (page 3/4 1-5) to add an additional footnote for Mode-2 to note a special test exception under certain conditions per Specification 3.10.2. This was not previously g ,

referenced due to an error of omission.

b) Change' Specification 4.1.3.4.b (page 3/4 1-23) at the first line to correct " individuals" to read " individual" in order.to correct a grammatical' error in the text.

c) Change Specification 3.1.3.7 (page 3/4 1-28) to add an additional footnote for Mode 1 to note a special test exception under certain conditions per Specification 3.10.2. This was not previously referenced due to an error of omission.

d) -Change Specification 4.6.2.1.c.2 (page 3/4 6-11) at line three to correct " test ' exchanger" to read " heat exchanger" to cite the proper component and eliminate a typographical error in the text.

e) Change Specification 4.8.1.1.2.c.9 (page 3/4 8-4) at the last line to correct "4.8.1.1.2.c.4" to read "4.8.1.1.2.c.5" to be consistent with

~the text as referenced for the same specification in the Standard Technical Specifications. This is also consistent with Regulatory Guide 1.108. In order to cite the appropriate reference this is an

} administrative correction of the original submittal.

I f) Change the nomenclature of Specification 4.8.2.3.1 to "4.8.2.3" and as referenced in Specification 3.8.2.3.b (page 3/4 8-8). Since there is I no Specification 4.8.2.3.2, the notation "4.8.2.3.1" is inappropriate i and is changed for consistency with the normal designation of text j within the Technical Specifications.

i g) Change Specification 4.8.2.4.2 (page 3/4 8-10) at the second line to

[ correct "4.8.2.3.2" to read "4.8.2.3" since Specification 4.8.2.3.2

does not exist. A change is made to cite the correct reference consistent with change f) above.

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'h) ' Change Table 4.11-2,. Table Notation 1 item b.-(page 3/4 11-9) at the last

'line to correct " semiannual effluent: report" to read " Semiannual (Radioactive Effluent Release Report" to clarify and more appropriately reference =the required report consistent with the nomenclature of-

-Specification 6.9.3.

Ei) Change Specification 3/4.12.2 (page 3/4 12-8) to add a footnote that

. was inadvertently omitted from a previous amendment to clarify broad leaf vegetation sampling criteria, consistent with the same notation in the Unit 1 Technical Specifications.

j) l Change Specification 6.9.3 (page 6-19a) at the title to correct

" RADIOLOGICAL" to read "RADI0 ACTIVE" for consistency with the remaining ,

text and the Standard Technical Specifications.

k) Change the'Index (page' XVII) for consistency with the change proposed in j) above.

-1) Change Specification 6.9.4.a (page 6-21) at the tenth line to correct "or"_ to read "of" to remove a typographical error -in an earlier

' amendment.

m) Change Specification 6.10.2.e. (page 6-22) at the first line to correct

" transient of" to read " transient or" to remove a typographical error in the text.

n) Change Specification 6.13.1.b. (page 6-24) at the second line to

' correct "present" to read " preset" to remove a typographical error in an earlier amendment.

o) Change Specification'3.11.2.3 (page 3/4 11-11), Specification 3.11.'2.4-(page 3/4 11-12), and Specification 3.11.2.5 (page 3/4 11-13) to delete reference to Figure 5.1-1 and, instead, reference Figure 5.1-3 as a more appropriate reference as well'as correcting an apparent typographical error when this reference was added in Amendment No. 60.

DISCUSSION This proposed change makes several editorial, clarifying and administrative corrections to the Technical Specifications. These corrections remove i typographical errors, revise wording to cite appropriate references, and

! provide consistent terminology, i

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DETERMINATION OF SIGNIFICANT HAZARDS Arkansas Power & Light Company has performed an analysis of the proposed change in accordance with 10CFR90.91(a)(1) regarding no significant hazards consideration, using the standards in 10CFR90.92(c).

A discussion of those standards as they relate to this amendment request follows:

Criterion 1 - Does Not Involve a Significant Increase in the Probability or '

Consequences of an Accident Previously Evaluated.

The proposed changes would not increase the probability or i consequences of any accident previously evaluated since these '

editorial, clarifying and/or administrative changes do not provide any relief from the requirements of the Technical Specifications, or change the intended operation or administrative requirements of the plant or its design bases.

Criterion 2 - Does Not Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated The proposed changes would not create the possibility of a new or different kind of accident from any previously analyzed since these editorial, clarifying and/or administrative changes do not adversely affect any components or systems which contribute to the safety of the plant or the ability to properly handle potential offsite release.

Criterion 3 - Does Not Involve a Significant Reduction in a Margin of Safety The proposed changes would not involve a significant reduction in the margin of safety since these editorial changes improve the wording of the text and provide clarifying and administrative corrections but have no effect on any plant safety parameters or accident mitigation capabilities.

i The Commission has provided guidance concerning the

application of +,hese standards by providing examples. The proposed amendment is most closely encompassed by example (1)
" purely administrative changes to the Technical Specifications."

Therefore, based on the reasoning presented above and the previous discussion of the amendment request, AP&L has determined that the requested changes do not involve a significant hazards consideration.

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PROPOSED CHANGE NO. 5 Change Figure 6.2-1, Management Organization Chart (page 6-2) and Figure 6.2-2, Functional Organization for Plant Operations (page 6-3) to reflect a reorganization of certain positions within the generation .

transmission, and engineering operations of AP&L. l DISCUSSION The " Senior Vice President Energy Supply" has been redesignated as " Senior Vice President Generation, Transmission & Engineering." The position of i

" Energy Supply Services Director" is eliminated and replaced by the position '

"Vice President, Engineering." - New positions of " Generation Engineering l General Manager" and " Technical Support General Manager" report to the Vice l President, Engineering and replace the positions of " Engineering Services General Manager" and " Technical Services General Manager." The functions of the." Administrative Services General Manager" have been transferred to i another organizational area within AP&L. Both Corporate and site emergency i preparedness program functions have been transferred to Nuclear Programs.

Emergency Planning Coordinators report to the Manager, Nuclear Programs.

DETERMINATION OF SIGNIFICANT HAZARDS Arkansas Power & Light Company has performed an analysis of the proposed change in accordance with 10CFR90.91(a)(1) regarding no significant hazards consideration, using the standards in 10CFR90.92(c).

A discussion of those standards as they relate to this amendment request follows:

Criterion 1 - Does Not Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated The proposed changes would not increase the probability of consequences of any accident previously evaluated since these administrative changes do not provide any relief from the requirements of the Technical Specifications, or change the intended operation or administrative requirements of the plant or its design bases. This change does not affect or reduce the effectiveness of the ANO plant management organization.

Criterion 2 - Does Not Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated.

The proposed changes would not create the possibility of a new or different kind of accident from any previously analyzed since these administrative changes do not adversely affect any components or systems which contribute to the safety of the plant or the ability to properly handle potential offsite releases.

Criterion 3 - Does Not Involve a Significant Reduction in a Margin of Safety.

The proposed changes would not involve a significant reduction in the margin l of safety since these administrative changes involve reorganization of 2CAN128601 9

'O certain positions beyond the immediate site organization and have no effect on any plant safety parameters or accident mitigation capabilities.

PROPOSED CHANGE NO. 6 Change Specification 6.5.2.2 (page 6-8)-to allow the Safety Review Committee (SRC) to be composed of at least eight members in addition to the chairman.

DISCUSSION Currently the Technical Specifications restrict SRC membership te a chairman and eight members. The proposed change would maintain a miiiimum composition of the eight members, but would allow the Vice President, Nuclear Operations to designate additional members as deemed necessary. The effectiveness of the independent review and audit function of the SRC would not be reduced, but enhanced, as a result of any additional membership.

DETERMINATION OF SIGNIFICANT HAZARDS Arkansas Power & Light Company has performed an analysis of the proposed change in accordance with 10CFR90.91(a)(1) regarding no significant hazards consideration, using the standards in 10CFR90.92(c).

A discussion of those standards as they relate to this amendment request follows:

Criterion 1 - Does Not Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated The proposed change would not increase the probability or conse4uences of any accident previously evaluated since this administrative chalige does not provide any relief from the requirements of the Technical Specifications, or change the intended operation or administrative requirements of the plant or its design bases. This change does not reduce the effectiveness of the Safety Review Committee.

Criterion 2 - Does Not Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated The proposed change would not create the possibility of a new or'different kind of accident from any previously analyzed since this administrative change does not adversely affect any components or systems which contribute to the safety of the plant or the ability to properly handle potential offsite releases.

Criterion 3 - Does Not Involve a Significant Reduction in a Margin of Safety The proposed change would not involve a significant reduction in the margin of safety since this administrative change has no effect on any plant safety parameters or accident mitigation capabilities.

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I' .The Commission has provided guidance concerning.the~ application of the

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-standards in-10CFR90.92(c) by providing examples. _The proposed amendment is

- most closely encompassed by example (1): '_' purely administrative changes' to lthe Technical Specifications."

i; ;- 1 -Therefore, based on the reasoning presented for each proposed change and the

! ' previous discussion of each change request, AP&L has determined that all of

-the~ requested changes do not involve a significant hazards consideration.

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l PROPOSED GPERATING LICENSE CHANGE 2CAN128601 L _ . _ , . _ . _ _ _ _ _ _ _ _ . _ . , _ __ _ _ . . _ , , __ , _ _ .

3.9 Protection of Redundant Cables in the Lower South Electrical Penetration Room (2111-T) September 30,'1978

' 3.10 Protection of Safe Shutdown Cables in the Upper South Piping Penetration Room (2084-D0) September 30, 1978 3.11 . Protection of Redundant Reactor Protection System Cables (2136-I) * , **

3.12 Fire Dampers September 30, 1978 3.13 Portable Extinguisher for the Control Room (2199-J) November 15, 1978 3.14 Smoke Detectors * **

3.15 Manual Hose Stations (2055-JJ, 2084-D0, Containment, Elev. 317' of Auxiliary Building * **

3.16 Portable Smoke Exhaust Equipment December 1, 1978 3.17 Emergency Lighting December 1, 1978 3.18 Reactor Coolant Pump 011 Collection System

  • 3.19 Control of Fire Doors March 31, 1979 3.20 Administrative Control Changes December 1, 1978 (Numbers in parentheses refer to fire zone designations in the AP&L fire hazards analysis.)
  • Prior to startup following the first regularly scheduled refueling outage.
    • Technical Specifications covering these items should be proposed not later than 90 days prior to implementation.

(f) " Overpressure Mitigating System" was deleted.

(g) " Verification of Transient Analysis Code" was deleted. l

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