ML18016B007

Application for Amend to License NPF-63,revising TS 3/4.2.2, TS 3/4.2.3 & TS 3/4.2.5,providing Clarification & Reducing Burden of Addl License Amend Processing by Implementing Guidance in GL 88-16 & NUREG-1431,Rev 1, Std TS W Plants.

ML18016B007
Person / Time
Site:	Harris
Issue date:	07/09/1999
From:	Scarola J CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18016B009	List: ML18016B007 ML18016B010
References
RTR-NUREG-1431 GL-88-16, HNP-99-071, HNP-99-71, NUDOCS 9907150096
Download: ML18016B007 (17)

Text

CATEGORY 1 REGULA rcY INFORMATION DISTRIBUTIO SYSTEM (RIDS)

ACCESSION NBR:9907150096 DOC.DATE: 99/07/09 NOTARIZED: YES DOCKET N FA'L 50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH.NAME AUTHOR AFFILIATION SCAROLA,J. Carolina Power & Light Co.

RECXP.NAME RECIPIENT AFFILIATION Records Management Branch (Document Control Desk)

SUBJECT:

Application for amend to license NPF-63,revising TS 3/4.2.2, TS 3/4.2.3 & TS 3/4.2.5,providing clarification Ec reducing burden of addi license amend processing by implementing guidance in GL 88-16 & NUREG-1431,Rev 1, "Std TS W Plants." A' DISTRIBUTION CODE: AOOID COPIES RECEIVED:LTR l ENCL L SIZE: i OR Submittal: General Distribution 4'ITLE:

NOTES:Application for permit renewal filed. 05000400 RECIPIENT COPIES RECIPIENT COPIES 0 ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL LPD2-2 LA 1 1 LAUFER,R. 1 1 INTERNAL: ACRS 1 1 0 1 1 NRR/DE/EEIB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-.ABSTRACT 1 1 OGC/RP 1 0 EXTERNAL: NOAC 1 1 D

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'I ijjl<<;jij!(I!Ij jjjjj, NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 11 ENCL 10

~4 CÃbM Carolina Power & Ught Company James Scarola PO Box 165 Vice President New Hill NC 27562 Harris Nuclear Plant JUL 8 1999 SERIAL: HNP-99-071 10 CFR 50.90 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICAL SPECIFICATIONS 3/4.2.2, 3/4.2.3, and 3/4.2.5

Dear Sir or Madam:

In accordance with the Code of Federal Regulations, Title 10, Part 50.90, Carolina Power &,

Light Company (CPAL) requests a revision to the Technical Specifications (TS) for the Harris Nuclear Plant (HNP). The proposed amendment revises TS 3/4.2.2, "HEAT FLUX HOT CHANNEL FACTOR FQ(Z)," TS 3/4.2.3, "RCS FLOW RATE AND ENTHALPY RISE HOT CHANNEL FACTOR", TS 3/4.2.5 "DNB PARAMETERS," an associated note in TS Table 2.2-1, and associated Bases. This change is consistent with NUREG-1431, Revision 1, "Standard Technical Specifications, Westinghouse Plants," dated April 1995 and the guidance provided by NRC Generic Letter 88-16, dated October 4, 1988. provides a description of the proposed changes and the basis for the changes. details, in accordance with 10 CFR 50.91(a), the basis for the Company's determination that the proposed changes do not involve a significant hazards consideration. provides an environmental evaluation which demonstrates that the proposed amendment meets the eligibilitycriteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental assessment is required for approval of this amendment request. provides page change instructions for incorporating the proposed revisions. provides the proposed Technical Specification pages.

moog 9907i50096 '7'70709 PDR ADOCK 05000400 P PDR 5rf13 Shearon Harris Road New Hill, NC Tel 919 362-2502 Fax 919 362-2095

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CPkL requests that the proposed amendment be issued such that implementation will occur within 60 days of issuance to allow time for procedure revision and orderly incorporation into copies of the Technical Specifications.

Please refer any questions regarding this submittal to Mr. J. H. Eads at (919) 362-2646.

Si erely, MSE/mse

Enclosures:

1. Basis for Change Request

2. 10 CFR 50.92 Evaluation

3. Environmental Considerations

4. Page Change Instructions

5. Technical Specification Pages J. Scarola, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief, and the sources of his information are employees, contractors, and agents of Carolina Power & Light Company.

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Mr. J. B. Brady, NRC Sr. Resident Inspector Mr. Mel Fry, Director, NC DEHNR Mr. R. J. Laufer, NRC Project Manager Mr. L. A. Reyes, NRC Regional Administrator

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bc: Ms. D. B. Alexander Mr. W. J. Hindman Mr. G. E. Attarian Mr. C. S. Hinnant Mr. R. H. Bazemore Mr. G. J. Kline Mr. C. L. Burton Ms. W. C. Langston Mr. H. K. Chernoff Mr. R. D. Martin Mr. B. H. Clark Mr. T. C. Morton Mr. W. F. Conway Mr. W. S. Orser Mr. G. W. Davis Mr. P. B. Summers Mr. W. J. Dorman Mr. J. M. Taylor Mr. R. J. Field Licensing File(s)

Mr. K. N. Harris Nuclear Records Ms. L. N. Hartz

ENCLOSURE 1 TO SERIAL: HNP-99-071 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICALSPECIFICATION TS 3/4.2.2, TS 3/4.2.3, TS 3/4.2.5 BASIS FOR CHANGE RE UEST B~ack round On July 27, 1994, the Nuclear Regulatory Commission (NRC) issued License Amendment No.

50 to the Harris Nuclear Plant (HNP) facility operating license. The purpose of the amendment was to allow reduced power operation when Reactor Coolant System (RCS) flow rate was below the 100% specified flow rate limit. Technical Specifications (TS) 3.2.3 Limiting Condition for Operation (LCO) states in part "The combination of indicated Reactor Coolant System (RCS) total flow rate and Thermal Power shall be maintained within the region of permissible operation shown on Figure 3.2-3."

HNP requested the TS change for License Amendment 50 as a contingency for modifications planned for the unit in Cycle 6. These changes included THOT reduction, New Fuel Vendor and New Fuel Design, and RCS RTD Bypass Manifold elimination. HNP was concerned that these changes could result in a measured RCS flow that was below the minimum RCS flow to support 100% reactor power operation. The changes that were implemented for Cycle 6 actually had minimal impact on RCS flow. The resulting TS change however, required implementation of the LCO Action requirements in situations which were not anticipated when the TS change was requested. The literal reading of the LCO requires operation within the region of permissible operation shown on Figure 3.2-3. Action c. of TS 3.2.3 directs remedial measures for being within the region of prohibited operation shown on Figure 3.2-3. Reactor Power as referred to in this submittal is a percentage of Rated Thermal Power for the HNP (2775 MWt). Reactor Power as determined by calorimetric has fluctuated above 100.0% for short periods of time. When Reactor Power is above 100%, HNP is currently required by TS to implement Action c. of LCO 3.2.3, since the combination of indicated RCS total flow rate and Thermal Power is in the prohibited operation region as shown on Figure 3.2-3. This has resulted in an unnecessary burden to perform a reactor core flux map when reactor power momentarily fluctuates above 100.0%.

As previously discussed, the purpose of License Amendment 50 was to provide a means to allow reduced power operation when RCS flow rate was measured less than the minimum required for 100% power. An additional requirement was inadvertently implemented as a result of this change, in that not only would the LCO be entered for reduced RCS flow, but also if reactor power fluctuated greater than 100%. HNP has a license condition to operate at reactor core power levels not to exceed 2775 megawatts thermal (100% Rated Thermal Power). HNP did not intend to create a new TS LCO requirement for maintaining reactor power less than or equal to 100.0%

by implementing License Amendment 50.

To clarify this TS and to reduce the burden of additional License Amendment processing, HNP proposes to implement the guidance in NRC Generic Letter (GL) 88-16, dated October 4, 1988, and NUREG-1431, Revision 1, "Standard Technical Specifications, Westinghouse Plants," dated April 1995 for TS 3/4.2.2, TS 3/4.2.3, TS 3/4.2.5.

Pro osed Chan e Harris Nuclear Plant (HNP) proposes the following changes to Technical Specifications (TS) 3/4.2.2, TS 3/4.2.3, TS 3/4.2.5, an associated note in TS Table 2.2-1, and associated Bases:

1. Remove the allowance for reduced power operation for reduced Reactor Coolant System (RCS) flow rate conditions.

2. Separate the requirements for F delta H and RCS flow rate in the format prescribed by NUREG-1431, Revision 1, "Standard Technical Specifications, Westinghouse Plants," dated April 1995. The F delta H requirements would remain in TS 3.2.3, while RCS flow rate requirements would be transferred to TS 3.2.5, DNB parameters. Change certain TS Actions and surveillance requirements to be consistent with NUREG-1431, Revision 1.

3. Implement the guidance of NUREG-1431, Revision 1 and NRC Generic Letter 88-16, dated October 4, 1988 for TS 3/4.2.2, TS 3/4.2.3, TS 3/4.2.5 and associated Bases by removing cycle specific parameters and placing that information into the Core Operating Limits Report (COLR).

Basis

1. Remove the allowance for reduced power operation for reduced Reactor Coolant System (RCS) flow rate conditions.

The proposed change to HNP TS involves removing the allowance for continued power operation at reduced levels when the TS LCO requirements for RCS flow rate are not met. The proposed change would require the unit to be removed from service (Reactor Power reduced to less than 5%) when the RCS flow rate limit is not met and cannot be restored within two hours.

The current TS Action allows continued plant operation for some situations when the RCS flow LCO limit is not met. Therefore, this aspect of the proposed change is more restrictive than current HNP TS.

License Amendment 50 to the HNP TS inadvertently implemented a requirement in TS 3/4.2.3 to perform a reactor core flux map when Reactor Power fluctuates above 100%. HNP has a license condition to operate at reactor core power levels not to exceed 2775 megawatts thermal (100%

rated core power). In the past, Reactor Power has momentarily fluctuated above 100%. A verbatim interpretation of TS 3/4.2.3 Action a.l.d). would require verification that the combination of thermal power and RCS flow are restored to the region of permissible operation as required by Figure 3.2-3. The proposed change willremove the capability to operate with RCS flow rate less than the LCO limit for 100.0% power.

2. Separate the requirements for F delta H and RCS flow rate in the format prescribed by NUREG-1431, Revision 1, "Standard Technical Specifications, Westinghouse Plants," dated April 1995. The F delta H requirements would remain in TS 3.2.3, while RCS Flow requirements would be transferred to TS 3.2.5, DNB parameters. Change certain TS Actions and surveillance requirements to be consistent with NUREG-1431, Revision 1.

The separation for F delta H and RCS flow rate requirements is in accordance with the format prescribed by NUREG-1431, Revision 1. The proposed changes to completion times for TS Actions and proposed changes to surveillance intervals are in accordance with NUREG-1431, Revision 1.

Per NUREG-1431, Revision 1 Bases, the completion times for TS Actions are acceptable because the plant is not allowed to remain in an unacceptable condition for an extended period of time. Sufficient time to reduce reactor power in an orderly manner or perform other required actions is also provided.

The surveillance intervals established by NUREG-1431, Revision 1 have been determined to be adequate for monitoring the change in power distribution. The surveillance intervals for power distribution are determined based on expected rate of change of power distribution over core life.

Surveillances are also required due to certain plant events, such as power changes, that may affect power distribution. Additionally, proposed TS Surveillance Requirement 4.2.5.2 is modified by a note which states this Surveillance Requirement is not required to be performed until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching greater than or equal to 95% RTP. As described in NUREG-1431, Revision 1 Bases for SR 3.4.1.4, this note allows entry into MODE 1, without having performed the SR, and placement of the unit in the best condition for performing the SR. This exception is appropriate since the heat balance requires the plant to be at greater than 95% RTP to obtain the stated RCS flow rate accuracies. The Surveillance shall be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> aAer reaching greater than or equal to 95% RTP. HNP has determined that RCS flow will be in the best condition for performing proposed surveillance 4.2.5.2 at greater than or equal to 95% RTP.

3. Implement the guidance of NUREG-1431, Revision 1 and NRC Generic Letter 88-16, dated October 4, 1988 for TS 3/4.2.2, TS 3/4.2.3, TS 3/4.2.5 and associated Bases by removing cycle specific parameters and placing that information into the Core Operating Limits Report (COLR).

NRC Generic Letter (GL) 88-16, dated October 4, 1988, was issued to encourage licensees to amend the Technical Specifications related to cycle-specific parameters. The Generic Letter stated the processing of changes to TS that are developed using an NRC approved methodology is an unnecessary burden on licensee and NRC resources. The generic letter provided guidance for relocation of certain cycle specific core operating limits from TS to the Core Operating Limits Report (COLR). This would allow changes to the values of the core operating limits without prior NRC approval as long as an NRC approved methodology for the parameter limit calculation is followed.

HNP proposes changing TS 3/4.2.2, TS 3/4.2.3, TS 3/4.2.5 and associated Bases by removing cycle specific parameters and placing that information into the COLR. In GL 88-16, the NRC staff concluded that it is essential to safety that the plant is operated within the bounds of cycle-specific parameter limits and that a requirement to maintain the plant within the appropriate bounds must be retained in the TS. However, the specific values of these limits may be modified by the licensees, without affecting nuclear safety, provided that these changes are determined using an NRC approved methodology and consistent with all applicable limits of the plant safety analysis HNP does not intend to alter the methodologies for any parameter limit calculation as a result of this change. The proposed change is in accordance with the plant safety analysis.

The relocated portions of the proposed change will be included in Core Operating Limits Report (COLR), plant procedure PLP-106, in accordance with GL 88-16. As a result of this proposed change, the NRC will receive a copy of the COLR and any changes as required by Section 6 of the HNP TS. Additionally, changes made to the COLR as a result of this proposed change and future changes to the COLR will be made in accordance with 10 CFR 50.59.

Coriclusions HNP proposes revising TS 3/4.2.2, TS 3/4.2.3, and TS 3/4.2.5 to eliminate the allowance for reduced Reactor Power operation when RCS Flow Rate is less than the TS limit. This portion of the proposed change is more restrictive than current TS. All changes described in this submittal are consistent with NUREG-1431, Revision 1. Relocated portions of TS as a result of this proposed change is in accordance with GL 88-16 and NUREG-1431, Revision l.

E1-4

ENCLOSURE 2 TO SERIAL: HNP-99-071 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICALSPECIFICATION TS 3/4.2.2, TS 3/4.2.3, TS 3/4.2.5 10 CFR 50.92 EVALUATION The Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. Carolina Power 8c Light Company has reviewed this proposed license amendment request and determined that its adoption would not involve a significant hazards determination. The bases for this determination are as follows:

Pro osed Chan e Harris Nuclear Plant (HNP) proposes the following changes to Technical Specifications (TS) 3/4.2.2, TS 3/4.2.3, TS 3/4.2.5, an associated note in TS Table 2.2-1, and associated Bases:

1. Remove the allowance for reduced power operation for reduced Reactor Coolant System (RCS) flow rate conditions.

2. Separate the requirements for F delta H and RCS flow rate in the format prescribed by NUREG-1431, Revision 1, "Standard Technical Specifications, Westinghouse Plants," dated April 1995. The F delta H requirements would remain in TS 3.2.3, while RCS flow rate requirements would be transferred to TS 3.2.5, DNB parameters. Change certain TS Actions and surveillance requirements to be consistent with NUREG-1431, Revision 1.

3. Implement the guidance of NUREG-1431, Revision 1 and NRC Generic Letter 88-16, dated October 4, 1988 for TS 3/4.2.2, TS 3/4.2.3, TS 3/4.2.5 and associated Bases by removing cycle specific parameters and placing that information into the Core Operating Limits Report (COLR).

Basis This change does not involve a significant hazards consideration for the following reasons:

The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed amendment will not introduce any new equipment or require existing equipment to function different from that previously evaluated in the Final Safety Analysis Report (FSAR) or TS.

As described in HNP TS Bases, the limits on heat flux hot channel factor, RCS flow rate, and enthalpy rise hot channel factor ensure that: (1) the design limits on peak local power density and minimum DNBR are not exceeded and (2) in the event of a LOCA the peak fuel clad temperature will not exceed the 2200 degree Fahrenheit ECCS acceptance limit.

Removing the allowance for reduced power operation for reduced RCS flow conditions is more restrictive than that currently allowed by TS. Power Distribution Limiting Conditions for Operation for heat flux hot channel factor and enthalpy rise hot channel factor are not affected by this change. Therefore, the consequences of an accident will not increase because of this change. Power Distribution limits place administrative restrictions on reactor core parameters and as such do not initiate nor mitigate accidents.

Power Distribution limits at HNP are developed using NRC approved methodologies.

Changing power distribution limits to be consistent with NUREG-1431, Revision 1 will not increase the probability or consequences of an accident that has been previously evaluated Relocating cycle specific information from TS to the COLR will not impact the ability of structures, systems, or components to mitigate accidents. Future changes to relocated requirements in the COLR will be submitted to the NRC for review in accordance with HNP TS Section 6.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed amendment will not introduce any new equipment or require existing equipment to function different from that previously evaluated in the Final Safety Analysis Report (FSAR) or TS. The changes are consistent with NUREG-1431, Revision 1 and the Commission's Final Policy Statement on Technical Specification improvements. The proposed amendment will not create any new accident scenarios, because the change does not introduce any new single failures, adverse equipment or material interactions, or release paths.

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

The proposed amendment does not involve a significant reduction in the margin of safety.

The LCO limit for RCS flow rate at 100.0% reactor power has not changed. The previous capability to operate with reduced RCS flow rate has been eliminated. This aspect of the proposed change is more restrictive than current plant TS in that continued reactor operation greater than 5% is not allowed if RCS flow rate is less than the LCO limit at 100% power.

Changes to TS 3/4.2.2, TS 3/4.2.3, TS 3/4.2.5 and associated Bases are in accordance with NUREG-1431, Revision 1. The completion times for TS Actions are acceptable because the plant is not allowed to remain in an unacceptable condition for an extended period of time. Sufficient time to reduce reactor power in an orderly manner or perform other required actions is also provided. The surveillance intervals established by NUREG-1431, Revision 1 have been determined to be adequate for monitoring the change in power distribution.

Relocating cycle specific information from HNP TS to the COLR is in accordance with E2-2

NRC GL 88-16. HNP does not intend to alter the methodologies for any parameter limit calculation as a result of this change. The proposed change is in accordance with the plant safety analysis. Therefore, the proposed change does not involve a significant reduction in the margin of safety.

E2-3

ENCLOSURE 3 TO SERIAL: HNP-99-071 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICALSPECIFICATION TS 3/4.2.2, TS 3/4.2.3, TS 3/4.2.5 ENVIRONMENTALCONSIDERATIONS 10 CFR 51.22(c)(9) provides criterion for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment to an operating license for a facility requires no environmental assessment if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant hazards consideration; (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite; (3) result in a significant increase in individual or cumulative occupational radiation exposure. Carolina Power 8c Light Company has reviewed this request and determined that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the amendment. The basis for this determination follows:

Pro osed Chan e Harris Nuclear Plant (HNP) proposes the following changes to Technical Specifications (TS) 3/4.2.2, TS 3/4.2.3, TS 3/4.2.5, an associated note in TS Table 2.2-1, and associated Bases:

1. Remove the allowance for reduced power operation for reduced Reactor Coolant System (RCS) flow rate conditions.

2. Separate the requirements for F delta H and RCS flow rate in the format prescribed by NUREG-1431, Revision 1, "Standard Technical Specifications, Westinghouse Plants," dated April 1995. The F delta H requirements would remain in TS 3.2.3, while RCS flow rate requirements would be transferred to TS 3.2.5, DNB parameters. Change certain TS Actions and surveillance requirements to be consistent with NUREG-1431, Revision 1.

3. Implement the guidance of NUREG-1431, Revision 1 and NRC Generic Letter 88-16, dated October 4, 1988 for TS 3/4.2.2, TS 3/4.2.3, TS 3/4.2.5 and associated Bases by removing cycle specific parameters and placing that information into the Core Operating Limits Report (COLR).

Basis The change meets the eligibilitycriteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the following reasons:

1. As demonstrated in Enclosure 2, the proposed amendment does not involve a significant hazards consideration.

2. The proposed amendment does not result in a significant change in the types or increase in the amounts of any effluents that may be released offsite.

The proposed change does not involve any new equipment or require existing systems to perform a different type of function than they are currently designed to perform. The change does not introduce any new effluents or increase the quantities of existing effluents. As such, the change cannot affect the types or amounts of any effluents that may be released offsite.

3. The proposed amendment does not result in a significant increase in individual or cumulative occupational radiation exposure.

The proposed change does not result in any physical plant changes or new surveillance which would require additional personnel entry into radiation controlled areas.

Therefore, the amendment has no affect on either individual or cumulative occupational radiation exposure.

E3-2

ENCLOSURE 4 TO SERIAL: HNP-99-071 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT TECHNICALSPECIFICATION TS 3/4.2.2, TS 3/4.2.3, TS 3/4.2.5 PAGE CHANGE INSTRUCTIONS REMOVE PAGE INSERT PAGE 2-4 2-4 2-10 2-10 3/4 2-5 3/4 2-5 3/4 2-9 3/4 2-9 3/4 2-10 3/4 2-10 3/4 2-10a 3/4 2-10a 3/4 2-10b 3/4 2-10b 3/4 2-14 3/4 2-14 B 3/4 2-2a B 3/4 2-2a B 3/4 2-4 B 3/4 2-4 B 3/4 2-5 B 3/4 2-5 B 3/4 2-6 B 3/4 2-6 N/A B 3/4 2-6a E4-1