ML20215J945
| ML20215J945 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/14/1987 |
| From: | Standerfer F GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20215J947 | List: |
| References | |
| 4410-87-L-0041, 4410-87-L-41, NUDOCS 8705080342 | |
| Download: ML20215J945 (11) | |
Text
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GPU Nuclear Corporation NUCIMr Post Office Box 480 Route 441 South Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:
(717) 948-8461 4410-87-L-0041 Document ID 0084P April 14,1987 US Nuclear Regulatory Commission Attn: Doc' nt Control Desk Washington, DC 20555
Dear Sirs:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Recovery Operations Plan Change Request No. 38 The attached requested change to the Recovery Operations Plan is being submitted in conjunction with Technical Specification Change Request No. 53.
Per the requirements of 10 CFR 170, an application fee of $150.00 is enclosed.
Sincerely,
. R. Stander er Vice President / Director, TMI-2 FRS/RDW/eml 9
Attachments f
Enclosed: GPU Nuclear Corp. Check No. 004060 cc: Regional Administrator - Region 1, Dr. T. E. Murley (d
Director - TMI-2 Cleanup Project Directorate, Dr. W. D. Travers 005Id 8705000342 870414 i
PDR ADOCK 05000320 P
PDR GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation w
Three Mlle Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Recovery Operations Plan Change Request (ROPCR) No. 38 The Licensee requests that the attached Recovery Operations Plan be substi-tuted for the existing Recovery Operations Plan. Due to the extensive nature of Recovery OperationsJPlan Change Request No. 38, it was decided that the most efficient manner to accommodate this change was to replace the Recovery Operations Plan in its entirety. A revised copy of the index is also included as part of this change.
This Recovery Operations Plan Change Request (ROPCR) also incorporates the changes proposed in R0PCR 31 submitted via GPU Nuclear letter 4410-85-L-0110 dated June 18, 1985, R0PCR 33 submitted via GPU Nuclear letter 4410-85-L-0135 dated July 31, 1985, and R0PCR 40 submitted via GPU Nuclear letter 4410-87-L-0008 dated January 27, 1987,.
The source of each proposed change in the attached change request is identified in the margin next to each change as shown below.
o 31, R0PCR No. 31 changes o 33, R0PCR No. 33 changes o 40, R0PCR No. 40 changes The purpose of these new proposed modifications is to support the changes in the Technical Specifications proposed in Technical Specification Change Request (TSCR) No. 53. The reason and justification for each change is described in the attachment.
No Stanificant Hazards Consideration This evaluation is provided as part of TSCR 53.
Amendment Class Pursuant to the requirements of 10 CFR 170, Licensing Foes, an application fee of $150.00 is enclosed.
2
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RECOVERY OPERATIONS PLAN CHANGE REQUEST 38 This Recovery Operations Plan Change Request (ROPCR) is being submitted in conjunc-tion with Technical Specification Change Request (TSCR) 53 to support several of the changes made in TSCR S3. Also, many changes have been made to the Recovery Operations Plan which are " clean up" changes.
These changes generally involve the deletion of unnecessary material, such as sections identified as " deleted."
1.
GENERAL ADMINISTRATIVE CHANGES DESCRIPTION OF CHANGE The following pages, sections and tables have been removed from the Recovery Operations Plan:
o Section 4.1.1.2.C, " Boron Concentration" o
Sections 4.3.3.2 and 4.3.3.3, " Radiation Monitoring Instrumentation" o
Sections 4.3.3.3.1 and 4.3.3.3.2 " Seismic Instrumentation" o
Table 4.3-4 " Seismic Monitoring Instrumentation Surveillance Requirements" o
. Section 4.3.3.6, " Post Accident Instrumentation" o
Table 4.3-6, " Remote Shutdown Monitoring Instrumentation Surveillance Requirements" o
Section 4.4.3, " Safety Valves" o
Sections 4.4.9.1.1, 4.4.9.1.2, and 4.4.9.1.3, " Pressure / Temperature Limits-Reactor Coolant System" o
Sectioa 4.6.1.3.C, " Containment Airlocks" o
Section 4.6.4, " Combustible Gas Control" o
Section 4.6.4.1, " Hydrogen Analyzers" o
Section 4.6.4.3, " Hydrogen Pu ge Cleanup System" o
Section 4.7.1, "Feedwater System" o
Section 4.7.2, " Secondary Services Closed Cooling Water System" o
Section 4.7.3.1, " Nuclear Services Closed Cooling Water System" o
Section 4.7.3.2, " Decay Heat Closed Cooling Water System" o
Section 4.7.3.3, " Mini Decay Heat Removal System (MDHRS)"
o Section 4.8.1.1.3, "A.C. Sources" Also, the page numbering has been revised to provide consecutive page numbers subsequent to the deletion of pages, sections and tables.
Typographical errors have been corrected in Tables 4.3-3 and 4.7-1.
The phrase in Table 4.3-3 Note 9, "... transfer operations by the operable..."
has been corrected to "... transfer operations to the operable...". The heading on Table 4.7-1 " Fuel Hand Building" has been corrected to " Fuel Handling Building." Additionally, this R0PCR reflects changes proposed in R0PCR 40 via GPU Nuclear letter 4410-87-L-0008 dated January 27, 1987.
REASON FOR CHANGE The above listed pages, sections and tables all were identified as " deleted" and provided no useful information. Since the above listed pages, sections and tables provided no useful information they have been removed from the Recovery Operations Plan to avoid the perpetuation of unnecessary informa-tion. The pages have been renumbered to correspond to the deletion of the above listed pages, sections, and tables.
The typographical errors have been corrected to avoid the perpetuation of errors. 0084P
JUSTIFICATION FOR CHANGE The removal of the above listed pages, sections and tables and the corrections of typographical errors are all administrative changes and no technical justification is required.
2.
RECOVERY OPERATIONS PLAN SECTION 4.
0.1 DESCRIPTION
OF CHANGE
" Recovery Mode" has been changed to " Facility Mode."
REASON FOR CHANGE
" Recovery Mode" was changed to " Facility Mode" to be consistent with the change to the Technical Specifications replacing " Recovery Mode" with
" Facility Mode."
JUSTIFICATION FOR CHANGE The justification for the replacement of " Recovery Mode" with " Facility Mode" is given in TSCR 53. Within the context of the Recovery Operations Plan, this change is an administrative change and no Technical Justification is required.
3.
RECOVERY OPERATIONS PLAN TABLES 4.3-3 AND 4.3-8. AND SECTION 4.6.1.4.A DESCRIPTION OF CHANGE The once per shift channel check for the following survel!1ances has been changed to a daily surveillance:
Equipment Recovery Operations Plan Section o Intermediate Range Neutron Flux Rate Monitor Table 4.3-1 o Source Range Neutron Flux Rate Monitor Table 4.3-1 o Fuel Handling Building Exhaust Monitors Table 4.3-3 o SDS Monitors Table 4.3-3 o Fuel Transfer Criticality Monitor Table 4.3-3 o Fuel Pool A Criticality Monitor Table 4.3-3 o Fuel Handling Building Truck Bay Table 4.3-3 Criticality Monitor o Ending Fitting Storage Area Table 4.3-3 Criticality Monitor o Incore Thermocouples/RCS Temperature Detectors Table 4.3-7 o Borated Hater Storage Tank Level Table 4.3-7 o Reactor Vessel Water Level Monitor Table 4.3-8 o Spent-Fuel Storage Pool "A" Water Table 4.3-8 Level Monitor o Chlorine Detection Systems 4.3.3.7 o Fuel Transfer Canal (Deep End) Hater Table 4.3-8 Level Monitor o Internal Pressure 4.6.1.4.A REASON FOR CHANGE Changing the channel checks for the above surveillances from shift to daily surveillances is indicative of the high degree of reliability of the above 0084P
monitors and is consistent with the surveillances for other monitors at THI-?.
(e.g., Haste Handling and Packaging Facility Exhaust Monitor, Reactor Building Equipment Doors AMS-3, etc.). Additionally, this revision is consistent with the proposed " phase-down" of the Technical Specifications and the Recovery Operations Plan Sections as the Recovery Mode progresses.
Specifically, as THI-2 progresses through Modes 1, 2 and 3, there will be little, if any, Technical Specification related activities performed on a continuous 24-hour basis.
Thus, a daily channel check will still provide reasonable assurance of the operability of the monitor associated with Mode 1, 2, and 3 activities.
JUSTIFICATION FOR CHANGE There is no specific TMI-2 Technical Specification basis for requiring a shiftly channel check for the above referenced instruments. A shiftly surveillance has been generally applied to those instruments which detect or monitor potential conditions that could affect the safe shutdown condition of the plant (e.g., Reactor Vessel Water Level), or any significant radiological releases. Additionally, during Modes 2 and 3, the probability of occurence of these type events will be essentially eliminated. Therefore, based on this and the proven reliability of the subject instruments, such that the possibility of a multiple failure within a shiftly interval is highly unlikely, a daily channel check of'these instruments is judged to be adequate to demonstrate operability.
This proposed change also supports the' basic premise of TSCR 53 and R0PCR 38 in that certain Technical Specifications and surveillance requirements are phased out as TMI-2 progresses through-the three (3) phases of the Cleanup Program. As the Reactor Vessel is defueled and the defueling canisters are shipped off-site, a shiftly channel check will become increasingly unnecessary especially during the periods when there are no plant activities which require direct supervision by operations personnel.
4.
RECOVERY OPERATIONS PLAN SECTIONS 4.1.1.3 and 4.1.
1.4 DESCRIPTION
OF CHANGE The phrase "and Spent Fuel Storage Pool
'A'" has been deleted from Section 4.1.1.3.
Section 4.1.1.4 has been written to provide the boron concentration requirements for Spent Fuel Storage Pool "A".
The turveillance requirements are identical to those provided in 4.1.1.3.
REASON FOR CHANGE This proposed change is consistent with the proposed change to Technical Specifications 3.1.1.3 and 3.1.1.4 in TSCR 53.
JUSTIFICATION FOR CHANGE The justification for change is the same as that for Technical Specifications 3.1.1.3 and 3.1.1.4 in TSCR 53.
5.
RECOVERY OPERATIONS PLAN SECTIONS 4.1.3 AND 4.1.
3.1 DESCRIPTION
OF CHANGE The surveillance requirements for control assemblies in Sections 4.1.3 and 4.1.3.1 have been deleted. 0084P
REASON FOR CHANGE'
~
NRC Amendment Order dated July 17, 1984, deleted the limiting conditions for operation for control assemblies from the Technical Specifications.
The stated surveillance requirement is "no surveillance required." Since the limiting conditions for operation for the control assemblies have been deleted and there is no surveillance requirement under the current conditions, Sections 4.1.3 and 4.1.3.1 can be deleted.
JUSTIFICATION FOR CHANGE Since there is no limiting condition for operation and no surveillance requirement for the control assemblies, the' deletion of Sections 4.1.3 and 4.1.3.1 is an administrative change and no technical justification is required.
It is stated that "with the reactor vessel head removed and the control rod drive mechanisms removed or disconnected from the reactor vessel there is no surveillance required." Although there are conditional statements in the surveillance requirement, it is not possible to not meet these conditions.
With the rotating platform installed, the Reactor Vessel head cannot be replaced on the Reactor Vessel, and even if it could be reinstalled, the control rods were damaged so extensively in the March 28, 1979 accident they could not be reinstalled or connected to the drive mechanisms and removed under any conditions.
6.
RECOVERY OPERATIONS PLAN SECTION 4.3.1.1 " NEUTRON MONITORING INSTRUMENTATION" DESCRIPTION OF CHANGE The phrase "during Recovery Mode and" has been deleted from Section 4.3.1.1.
i REASON FOR CHANGE The phrase "during Recovery Mode" is specifying applicability.
Surveillance requirements support the associated limiting conditions for operation which, in turn, specifies applicability, therefore, this phrase has been removed from the surveillance requirements.
JUSTIFICATION FOR CHANGE Removing "during Recovery Mode and" from Section 4.3.1.1 in itself is an administrative change and no technical justification is required.
- However, TSCR 53 also has revised the applicability of 3.3.1.1 from " Recovery Mode" to
" Mode 1."
The justification for this change is in TSCR 53.
7.
RECOVERY OPERATIONS PLAN SECTIONS 4.3.2 AND 4.3.2.1 " ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION" AND TABLE 4.3-2 " ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION" DESCRIPTION OF CHANGE Sections 4.3.2 and 4.3.2.1 and Table 4.3-2 have been deleted from the Recovery Operations Plan.
, 0084P
REASON AND JUSTIFICATION FOR CHANGE Technical Specifications 3.3.2 and 3.3.2.1 have been deleted by TSCR 53.
.Therefore, this R0PCR is deleting the corresponding Surveillance Requirements
.given in Sections 4.3.2 and 4.3.2.1 and Table 4.3-2.
8.
RECOVERY OPERATIONS PLAN TABLE 4.3-3 " RADIATION MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS" DESCRIPTION OF CHANGE The following changes have been made:
o The Reactor Building Purge Sampler (AMS-3) has been deleted.
o ~
All shiftly channel checks have been changed to daily.
o The applicability for the CACE Vent Monitor has been changed from-
"During operation of the monitored system" to " Mode 1, during operation of the monitored system."
o The applicability of the Fuel Handling Building (FHB) Exhaust Monitor has been revised from "With radioactive waste in the Fuel Handling Building" to " Modes 1 and 2 with radioactive waste in the Fuel Handling Building."
o The action statement for the SDS Area Monitor (IX03) has been revised
'from 12-hours to 24-hours.
REASON FOR CHANGE The reasons for the above proposed changes are: a) delete those monitors whose basis as a Recovery Operations Plan surveillance requirement no longer exists; b) revise the applicability of various monitors to be consistent with the proposed modes of operation for THI-2 and; c) revise the action statements to be consistent with the surveillance requirements.
JUSTIFICATION FOR CHANGE A.
Reactor Building Purge Sampler (AMS-3)
The Reactor Building Purge Sampler (AMS-3) was added to the Recovery Operations Plan Change (ROPC) No. 18, dated November 30, 1982. As the basis for the addition of this monitor, the referenced R0PC stated, "These operability requirements have been prepared to assure that gross changes in containment airborne particulate radioactive material concen-trations are detected upstream of the Reactor Building purge filters during purge operations." Additionally, the R0PC stated "...the staff has determined that acceptable controls exist to both establish baseline data for concentrations of airborne radioactive particulates in the Reactor Building and to alert operations personnel for any abnormal radioactive particulate levels within the Reactor Building during routine operations."
Gross changes in airborne particulate radioactivity have been routinely monitored over the past 3 years using local monitoring including fixed filter recording instruments, high volume portable units, and breathing zone air samplers.
The scope of work has been such that the historical data enables accurate prediction of changes in airborne radioactivity as a function of work activity.
It has been observed that local instrumen- 0084P
'tation provides a more timely and accurate measure of airborne radioac-tivity. changes than does the Reactor Building Purge Sampler (AMS-3).
Additionally, baseline and historical trend data regarding-airborne radioactivity have been obtained using local instrumentation. sThese data include _ activity level, isotopic composition, and particulate size. These data have proven to be more useful than that obtained from the Reactor-Building Purge Sampler (AMS-3).
the use of local
' instrumentation will continue to build the data base.
Based on the above justification, GPU Nuclear believes that the basir, for retaining the Reactor Building Purge Sampler (AMS-3) in the Recovery Operations Plan is no longer-warranted.
B.
Revision of Shiftly Channel Checks The justification for revision of the shiftly channel checks fs
. presented in Change No. 3 of this evaluation.
C.
CACE Vent Monitor The CACE Vent Monitor was added to the Recovery Operations Plan as a result of R0PC No. 26 dated April 3, 1985.
This monitor was designed to operate concurrent with the ventilation system for the Containment Air Control Envelope (CACE).
The CACE is a structure adjoining the Reactor Building at the equipment hatch and is used as a staging and storage area for materials and equipment being transferred into and.out of the Reactor Building.
Currently, there are no planned or foreseeable activities that require use of the CACE 4)llowing the completion of Mode.1 Therefore, use of-C the CACE Ver;tilatlon System and the associated radiation monitor will also not be req'4 rad. However,~in the event that use of the CACE is required during Modet 2 and 3, the ventilation system and associated monitor would bo operated in accordance with approved procedures.
D.
Fuel Handling Buildina Exhaust Monitors The fuel Handling Building (FHB) Exhaust Monitors were added to Table 4.3-3 via NRC Amendment of Order dated December 19, 1984, which approved THI-2 Technical Specification Change Request 41 and Recovery Operations Plan Change Request 20.
These monitors were added to Table 4.3-3 concurrent with the addition of radiation monitors for the Mint Decay Heat Removal System and the Submerged Demineralizer System (SDS).
THe intent of the addition of the FHB Exhaust Monitors was to assure adequate radiation detection of radioactive processing activities in the FHB.
Following the completion of Mode 2, there will be no canisters containing core material in the FHB.
Thus, the amount of radionuclides that could be accidentally released to the environment will have been significantly reduced. Any such releases to the environment during Mode 3 will be monitored and detected via the station vent monitor (i.e.,
HPR-219).
Furthermore, the SDS Area Monitor during Mode 3 will be operable during any processing operation utilizing SDS.
Thus, the deletion of the requirement for the FHB Exhaust Montror during Mode 3 will not significantly reduce any safety margins. 0084P
E.
SDS Area Monit*r (IX03)
The action statement for the SDS area monitor (IX03) currently states, "If monitor becomes inoperable, repair or replace by equivalent equip-ment within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />." The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> requirement has been revised to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to be consistent with the revised surveillance for the channel check of this monitor. Additionally, SDS processing has significantly reduced the radionuclides in the RCS and RB sump such that relaxing the action statement to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> will not significantly reduce the margin of safety for this system.
For example, since February 1982, the radio-nuclide concentration of Cs-137 in the R8 sump has been reduced by a factor of 100.
It is noteworthy, that revising the action statement for the SDS area monitor does not affect any of the accident scenarios described in the SDS Technical Evaluation Report.
Furthermore, in the event that the SDS area monitor would be inoperable for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period without being detected, any radiological releases would be detected and alerted by the station vent monitors.
9.
RECOVERY OPERATIONS PLAN TABLE 4.3-7 AND TABLE 4.3-8 DESCRIPTION OF CHANGE The surveillance requirements in Table 4.3-7 for Reactor Vessel Water Level, Spent Fuel Storage Pool "A" Water Level and Fuel Transfer Canal (deep end)
Water Level have been transferred to new Table 4.3-8, and the Reactor Building pressure requirements have been transferred to Specification 4.6.1.4.a.
REASON FOR CHANGE The surveillance requirements for Reactor Vessel Water Level, Spent Fuel Storage Pool "A" Water Level and Fuel Transfer Canal (deep end) Hater Level have been transferred to new Table 4.3-8 and the surveillance requirements for Reactor Building pressure has been transferred to Specification 4.6.1.4.a to simplify the specification of the applicability for these requirements.
JUSTIFICATION FOR CHANGE The transferring of water level surveillance requirements from Table 4.3-7 to new Table 4.3-8 and to Specification 4.6.1.4.a are administrative changes and no technical justification is required.
- 10. RECOVERY OPERATIONS PLAN SECTIONS 4.4.2, 4.9.1 and 4.
9.3 DESCRIPTION
OF CHANGE The references to Table 4.3-7 has been changed to table 4.3-8 in Recovery Operations Plan Sections 4.4.2, 4.9.1 and 4.9.3.
REASON FOR CHANGE The references to Table 4.3-7 in Section 4.4.2, 4.9.1 and 4.9.3 have been changed to Table 4.3-8 to be consistent with other changes which transferred the surveillance requirements for the Reactor Vessel Water Level, Spent Fuel Storage Pool "A" Water Level and Fuel Transfer Canal (deep end) Hater Level to Table 4.3-8. 0084P
JUSTIFICATION FJR CHANGE Changing the references to Table 4.3-7 to Table 4.3-8 is an administrative change to be consistent with other change to the Recovery Operations Plan and no technical justification is required.
- 11. RECOVERY OPERATIONS PLAN SECTION 4.6.1.2 " CONTAINMENT ISOLATION" DESCRIPTION OF CHANGE Recovery Operations Plan Section 4.6.1.2 has been added.
REASON FOR CHANGE Section 4.6.1.2 has been added to specify Surveillance Requirements to support Technical Specification 3.6.1.2.
JUSTIFICATION FOR CHANGE Based on the justification for Technical Specification 3.6.1.2 a quarterly surveillance is sufficient to ensure containment isolation is belr.g main-tained.
The most preferred surveillance method is visual verification; however; in cases where this is not practical (e.g. high radiation areas),
documented evidence may be used. Documented evidence includes, but is not limited to, locked valves, red-tagged closed valves, deactivated automatic valves and pressure tests. Penetrations which have been closed by bolted or welded blind flanges provided a high degree of assurance that containment is being maintained and; therefore; they have been exempted from the surveillance.
- 12. RECOVERY OPERATIONS PLAN SECTION 4.6.1.4. " INTERNAL PRESSURE" DESCRIPTION OF CHANGE The shiftly channel check has been revised to a daily survelliance.
The reference to Specification 6.8.2 has been modified to indicate that is applies during Mode 1 only.
REASON FOR CHANGE The change from a shiftly surveillance to a daily surveillance is addressed in Change No. 3 of this evaluation.
The revision to the reference of Specifica-tion 6.8.2 is consistent with the rationale presented in TSCR 53 in that the criteria of Specification 6.8.2 will not apply following the completion of Mode 1.
SAFETY EVALUATION JUSTIFYING CHANGE The reference to Specification 6.8.2 was added to Recovery Operations Plan Section 4.6.1.4 via R0PC 28 dated April 12, 1985.
This change was necessi-tated to recognize the possibility for the Control Room Instruments to indi-cate a positive Reactor Building pressure (with respect to the Auxillary Building) when, in fact, the Reactor Building pressure is negative with respect to the environment.
The requirement for Specification 6.8.2 approval was to ensure the proper implementation of procedural requirements to maintain negative flow in the Reactor Building when it is opened to the environment.
Presently, such procedural requirements are in affect (e.g., 4210-0PS-3240.01, 0084P
" React $r Building Entry") and are approved by the NRC. During Modes 2 and 3, the Technical Specification requirements for non-positive pressure in the Reactor Building will still apply. Accordingly, whenever the Reactor Building is open to the atmosphere, procedural requirements to ensure air flow into the Reactor Building will still be maintained. Thus, this proposed change will not reduce any safet.v margins or result in increased effluents to the environment.
The Safety Evaluation Justifyirg Change for Specification 6.8.2 in TSCR 53 notes that following completion of Mode 1 the remaining inventory of radio-nuclides in the Reactor Building will not pose a potential for Reactor Building activities to exceed 10 CFR 50 Appendix I limits.
Thus, the criteria of Specification 6.8.2 should not apply to Recovery Operations Plan Section 4.6.1.4 after Mode 1.
13.
RECOVERY OPERATIONS PLAN SECTION 4.6.1.6 " CONTAINMENT AIRLOCKS (MODES 2 AND 3)"
DESCRIPTION OF CHANGE Recovery Operations Plan Section 4.6.1.6 has been added.
REASON FOR CHANGE Section 4.6.1.6 has been added to specify surveillance requirements to support Technical Specifications 3.6.1.6.
JUSTIFICATION FOR CHANGE The surveillance requirements for this surveillance are the same as those required by Section 4.6.1.3, " Containment Airlocks (Mode 1)."
Thus, this change is administrative in nature and no Technical Specification is required.
14.
RECOVERY OPERATIONS PLAN SECTION 4.6.3.1 " CONTAINMENT PURGE EXHAUST SYSTEM" DESCRIPTION OF CHANGE
" Prior to system operation if not performed within the previous 31 days and thereafter" has been added to 4.6.3.1.a.
" Prior to system operation if not performed within the previous 18 months and thereafter" has been added to 4.6.3.1.b.
REASON FOR CHANGE
" Prior to system operation..." has been added to 4.6.3.1.a and 4.6.3.1.b to clarify that surveillances are not required to be performed on the Containment Purge Exhaust System when it is not in service.
JUSTIFICATION FOR CHANGE The surveillance requirements have been revised only to clarify that survell-lance requirements are not necessary when the system is not in service. Since there have been no changes in the actual surveillances to be performed, these changes are administrative changes only and no technical justification is required. 0084P
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