ML20070P552
| ML20070P552 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/15/1991 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20070P559 | List: |
| References | |
| TAC-79970, ULNRC-2378, NUDOCS 9103270344 | |
| Download: ML20070P552 (14) | |
Text
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UNION D "*"'*"
b,lisCTIllC March 15, 1991 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, D.C.
20555 ULNRC-2378 Gentlemen:
TAC No. 79970 DOCKET NUMBER 50-482 CALLAWAY PLANT REVISION TO TECHNICAL SPECIFICATION 3/
6.1.1, 3/4~6.1.2 CONTAINMENT INTEGRITY AND CONTAINMENT LEAMAGT,,
AND PARTIAL EXEMPTION FROM 10CFR50, APPENDIX J Union Electric Company herewith transmits an application for amendment to Facility Op3 rating License No. NPF-30 for Callaway Plant.
Also accompanying the transmittal is a partial exemption requast, pursuant to the provisions of 10CFR50.12, from the s. sting requirements of 10CFh50, Appendix J.
This amendment application adds the words
" manual and closed", to Technical Specification Surveillance 4.6.1.la, revises the ACTION Statements in removes the tie Technical Specification 3/4.6.1.2[ng and inservice between integrated leak rate test
-inspection testing, and revises the s2rveillance interval to be more consistent with 10CFR50, Appendix J.
The approval of the proposed exemption requests would be beneficial in removing areas of uncertainty associated with as found versus as lett deceptance criteria when performing a containment integrated leakage rate test as was the case in the test recently performed at Refuel-4 (Reference ULNRC-2351, dated January 28, 1991).
Attachments 1, 2,
and 3 contain the Safety Evaluations and 10CFR50.12 special circumstances, the Significant Hazards Evaluation, and the Proposed Technical Specification Changes in support of this amendment request.
Very truly yours, bfGax
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/ Donald F. Schnell
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Attachments 4
'J 9103270344 9103.15
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STATE OF MISSOURI )
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Alan C.
Passwater, of Invful age, being first duly sworn upota cath says that he is Manager, Licensi'g and Fuels (Nuclear) for Union Electric Company; that he has read *1e foregoing document and know.3 the content thereof; that he han executed the same for and on behalf of said company v.4th full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
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By
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Alan C Pasowater Manager, Licensing and Fuels Nuclear SUBSCRIBED and sworn to before me this
/ESTI day of 7h-kd 1991.
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BAf?DARA J. PF AFF NOTARY PUBLO, STATE Of Mlf GURI MY COMYlSSION EXPIRES APRll 22, 1993 ST LOUIS COUNTY j
l' cc:
T. A.
Baxter, Esq.
Shaw, Pittman, Potts & Trowbridge 2300 N.-Street, N.W.
Washington, D.C.
20037 Dr.-J. O. Cermak
-m CFA, Inc.
4 Professional Drive (Suite _110)
Gaithersburg, MD 20879 R. C.
Knop Chief, Reactor Project Branch 1 U.S. Nuclear Regulatory Commission Region III-799 Roosevelt Road Glen Ellyn, Illinoin 60137 Bruce Bartlett Callaway Resident Office U.S. Nuclear Regulatory Commission RRM1 i
Steedman, Missouri 65077 M. D.
Lynch (2)
Office of Nuclear Reactor Regulation U.S.
Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E21 11555 Rockville Pike Rockville, MD 20852 m-Manager,- Electric Department Missouri Public Service Commission P.O. box 360 Jefferson City, MO 65102 Ron Kucera Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102 e
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bec: D. Shafer/A160.761
/QA Record (CA-758) lluclear Date E210.01 DFS/ Chrono D.
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Schnell J. E. Bi rit J.
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Laux M. A. Stiller r.
L. Randolph R.
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Irwin
- 11. Wutertenbaecher W.
R. Campbell A.
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P. Wendling D.
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Shafer W.
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Maynard (WCt400)
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Page 1 of 7 ULNRC-2378 S AFETY.,EVALUATIO!]
This amendment request addresses the following items:
1.
A change to Technical Specificat ion (T/S) 3/4.6.1.1 which addresses Conthinment Integrity.
2.
A partial.nemption from the 10CFR50, Appen ilx J.
Section III.A.1'.n) requir ement to stop the Typr-A test (Containment Integra ted Leakage Rate Test 01 CILRT) if excessive leakage is dotermined.
3.
A partial exemption from the 10CFR50, Appendix J, section III.A.5(b) acceptance critoria for Type A tests (CILRT), and associated change to T/S 4.6.1.2b.
4.
A partial exemption from the 10CFR50, Appendix J, Section III.D.1(a) requirement to perform the third Type A test (CILRT) during each 10-year service period when the plant is shutdown for the 10-year plant inservice inspections, and associated change to T/S 4.6.1.2a.
5.
A change te T/S 3/4.6.3.2, which addrennes Containment Lenhage, to revise the ACTION Statemente and clarify the Survetllance Requirements.
These changes to the T/S and exemption requests with their recpoetive safety evaluations and 10CFR50.12 special circumstances are discussed individually hereinafter.
ITEM _1 The proposed change to T/S 4.6.1.la consists of adding the following two words to the surveillance to be consistent with T/S Definition 1.7 fr-Containment Integrity.
" Manual" is added te describe the vah -s that are required to be closed for penetrations not capable of being closed by OPERABLE containment automatic isolation valves, and " closed" is added to describe the position they are secured in during accident conditions.
This change is administrative in nature in that no requirements are being altered and the operation of Callaway Plant with this change would not a.
Increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report.
The additional words added to the Surveillance Requirement are for clarity to be more consietent with the description of containment integrity and are adminintrative in nature, b.
Create the possibility for an accident or malfunction of equipment of a different type than any previously evaluated in the safety analysis report.
There are no design changes being made that would create the possibility for an accident or malfunction of equipment.
The change is merely an administrative change.
Pago 2 of 7 ULNRC-2378 E
c.
Reduce thn margin of nafety ne defined in the basis for any technieni specifiention.
The change provideo clarification and as an administrativo change.
Given the above discuss.on as well as that presented in the Significant flazardo Connideration, the proposed change does not adversely affect or endanger the health or safety of the generni public or involve a significant nafety hnzard.
. ITEM 2 Thin proposed exemption denis with the 10CFR50, Appendix J, Section III.A.1(n) requirement to stop the Type A tent (CILRT) if excessivo leeknge is determined The exemption would allow the satinf actory completion of the Type A test if the lenkngo enn be isolated and approprfately factored into the resulto.
Appetidix J,Section I!!.A.1(n) requiren that if during n Type A tent potentially excessive leaknan paths nro identified which will interfere with natisfactory completion of the tont, the Type A test shall be terminated and local leakage tenting perf ormed on the paths of concern.
Hopnirs and/or - adjustmento nhn11 be mado to affected equipment and a Typo A test performed.
Our picposed alternative approach to iollow to ensure the technicnl adequacy of Type A tanting in an follows:
When excearivo lonkago in-experienced during-n Type A tont, significant lenkn will be identified and isolated it om the tent.
Ponetrations no isolnted wil.1 be enpable of local lonkage rnto testing.
Once thene lenke have been inolated, the Type A tent will be continued.
Following the Typo A tent, local Jenknge reten will bo *nensured before and af tor t opn re to cach inolated leakage path.
The renults of the Type A tent will then be bnck-colrected using the " minimum pathway" tenknga rate fot each a
penettation.
The local lenhago mennurnmentn bnforn the repair are added to the Type A results to determino the "ns found' condition and possible "an found" Type A tent failure, which could incronne future Type A tont frequency en required by Sec tion III. A. f> to Appendix J.
The after-repair mennurements (the Typo A tent menoutement plus the "ns left" local lenknge raten) determine the final acceptability of the test.
For a satisfactory Type A tent, the corrected Type A renults -( the sum of the npproprinto local lenhages and the Type A test results) must be less than 75% of the maximum allowablo leakage rato L,.
This exemption will not pose nny undue risk to the henith and safety of the public or involve a significant safety hnzntd.
Special circumstances, no provided in 10CFR50,12(n)(2)(ii), are present justifying the partial exemption f rom Appendix J.
Namely, application of the regulation in the particular circumotances is not neceuenry to achieve its underlying-purpose, which is to ensure that accurato an_d conservative methods are used to asence the results of containment lonk rate tonts.
This in ej milar to an exemption request which han been previously approved at Carolina Power. & Light Company's II.B. Robinson Plant.
Pago 3 of 7 UhNRC-2378 JIEU This proponed exemption and changen to T/S 4.6.1.2b deals with the 10CFR50, Appendix J, Section III.A.5(b) acceptance criteria for Type A tests (CILRT).
The exemption requesto that the acceptance criterion for "as found" Type A teste be not at the enme values as the maximum allowable leakage rht.e, h,.
The objective of the Appendix J Type A test is to determine both the "an found" containment leakage condition and the final "as left" condition, if repairs are mado.
Firnt, a anti n f ac tory completion of a Type A test eenentially ensuren that actuni leakage rates ("no left") do not exceed those rates assumed by acciderit analysen, Second, the "an found" condition of containment must be measured to obtain an indication of the ability of the containment to remain lenktight throughout the period between testo and for purpoco of dolormining nubsequent testing frequency.
Our exemption request proponen to uno L na the neceptanco criterion for the "as found" Type A ton 6 renulto.
L is the actual leakage rate used in the plant safety analysifl to determine the offsito radiological consequences of an accident.
The "an left' test limit of 0.75 L was opecified in Appendix J in order to-provide a margin of 0.05 L for poss1Llo deteriorati >n of the containmont lonk-0.ightnonr. betwenn Typo A t e s t o.-
Dince L in the actuni number nnoumed in the offnito dono analysis, atid LMe "an_found" test measures leakage rato at.the ond of the period betwenn tonts no that mnrgin for deterioration 3
=in no longer needed, it.is technicnily acceptable to une L no the "as found" Type 6 tent acceptance criterton.
The prop 0 sod changen to Survnillance Requirement T/S 4.6.1.2b npecifies that L
will be used no the acceptanco critorion for the "an found" T9po A tent results-und 0.75 L,, will be used as the "as left" lenhage rato.
The T/S acceptadce critorlon of 4.6.1.2b remainn
-0.75 L -which represents the allowable operational leakage rate which 9t hn11 be mot befora placing the containment into servico -
i prior to renumption of powcr operation - t oJ 10w3 ng a tont.
These-T/S changes are connistent with our proposed partial exemption request to 10CFR50,-Appendix J,Section III.A.1(n) and
-do not involve an unreviewed safety question because operation of l
Callaway Plant with thero changes would noti a.
Increase the probability of occurrence ar the consequences of an accident-or malfunction of equipment important to enfoty previously evalunted in the nnfety analysis report, The Surveillance Requirement han neon cinri fied to be'more consistent with the intended objectives of Appendix J.
These changea do not impact the lenkngo rates ananmed by accident analynin.
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Attochment 1 Page 4 of 7 ULNRC-2378 b,
Create the possibility for an accident or malfunction of equipment of n different type than any previously evaluated in the safety analysis report.
There are no design changos being made that would create the possibility for an accident or malfunction of equipment.
The changes provide clarification to the Surveillance Requirement, c.
Reduce the margin of safety as defined in the basis for any technical specification.
The changes provide more direction and clarity to the Survo111anco Requiremont for performing the Type A tests required by Appendix J.
Given the above discussions, as well as those presented in the Significant Hazards Considoratica, the proposed changes do not adversely affect or endanger the health or safety of the general public or involve a significant safety hazard.
This exemption will not pose any undue risk to the health and safety of the public or involve a significant safety hazard.
Special circumstancos, as provided in 10CFR50.12(a)(2)(ii), are present justifying the partial exemption from Appendix J.
Namely, application of the regulation in the particular circumstances is not necoseary to achieve its underlying purpose, which is to ensure that accurate and conservativo methods are used to assess the-results of containmont leak rate tests.
This is consistent with the proposed changes to 10CFR50, Appendix J (Reference 51FR209, dated 10/29/86) and t.he T/S change and exemption request provicualy approved at Carolina Power & hight Company's ll.B. Robinson Plant.
ITEM _4 This proposed exemption and changen to T/S 4.6.1.2a deals with tho.10CFR50, Appendix J, Section III.D.I a) requiremont to t
perform lthe third Type A test (CILRT) during each 10-year service period when the plant is shutdown for the 10-year plant inservice inspections.
Section III.D.l(b) given parmionibin periods for testing as-periods when the plant f acility is nonopotntionn1 and secured in the shutdown condition under the administrativo control and in accordance with the safety procedures defined in
.the; license.
These permissible periods for testing would normally occur during a refucling shutdown.
'Throughout the service life of a water-cooled nuclear peer facility, 10CFR50.55a(g)(4)-requires that components which are-1 classified as-American Society of Mechanical Engineers (ASME)
Boiler and Pressure Vessel Code Class'1, C1nsa 2, and Class 3 meet the-requiraments set forth in the ASME Code Section XI, "Ru)es for Ilmarvice-Inspection of Nuclear Power Plant
-Companorts," to the extent practien1 within the limitations of design,-geometry, and materials of construction of the-components.. This section of the regulations also requires that inservice examinations of components and system pressure tests be conducted-in 10-year intervals.
For Cal 1away Plant this Eirat
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{
Page 5 of 7 1
UhNRC-2376 i
1 10-year interval runs from December 18, 1984 through December 18, j
1994 with subsequent intervnis to follow thrcughout the life of i
the-plant.
The inservice volumetric, surface, and vieuni 1-exatninntionn of cornponents and system pressure tests are performed j
during the 10-year inspection intervnlo with the mnjority being j
done during the refueling shutdowns that occur approximately i
every 18 months.
At the conclusion of the first 10-yent interval j
and at the conclusion of the following 10-year interynin all of the inservice inspection program plan examination requirements required by 10CFR50.55n(g)(4) will have been completed.
i Callawny Plant will not be shutting down at the end of the 10-yenr intervalo for an extended outage to perform pinnt incorvice inspections.
Therefore, the pet formance of the third l
Type A test (Cil.RT) nt the 10-year plant innervice innpection chut.down is impractienl.
Our proponed niternntive to this Appendix J requirement in to perform the thteo Type A t.ents at approx 1mntely equal intervnin within ench 10-year period, with the thi rd tent.of nach ret conducted an elow nr prnetieni te the cnd of the 10-yent pe ri od.
There wou.ld be no connection between the Appendix-J 10-year interval and the inservice innpection 10-yont intervnl.
The proposed change to surveillance Requirement T/S 4.6.1.2n deleton the requirement to perform the third tent-of each not during the_mhutdown for the 10-year plant inservice inspection.
'"he deletion of when the third test in perf ormed is connintent with our proponed partial exnmption requent to 10CFR50, Appendix J,
Section III.D,1( a ) and does not involve an unreviewed unfety question _ beenure operation of CalIaway Plant wi th thi n change l
would nott
_- n.
Incrense the prohnbility of occurtence or the consequencen of an accident or mn1 function of equipment important to eniety previoucly evnlunted in the Safety Analysin Report.
The deletion of thin requirement from the T/S doen not impact pinnt nnfety n3nce the underlying purpose of the requirement to perform 3 containment lenh rate tento at approximately equal intervals within each 10-year period remainn consistent with Appendix J objectivos, b.
Create the possibility for an accident or malfunction of
- j equipment of a different type than any previounly evn]unted in t.he Safet.y Analysis Report.
There are no denign changes being made that would create the ponnihility for an accident F
or mnif unc tion -- of equipment. -The change deleton an unnecessary tie between two regulations, but is consistent with the requirements of the two regulationn (Appendix J nnd 10CFR50.55n(g)(4)).
4 c.
Reduce the margin of safety no defined in the bnais for any technical specification.
This change deleton an unnecesanry i-requirement that does not impact the margin of safety provided by the technien1 specifications.
c.
-. _ _ -,. _. _. ~, _,. _, -.,. _ _. -... _. _ _. _ _ _ _ _ - - -. ~ _
i Tage 6 of 7 ULNRC-237B Given the above discussionr4, as well an there presented in the S$gnificant liar.ardo Consideration, the proposed changer do not.
adversely affect or endanger the health or safety of the general public or involve a significant safety hazard.
This exemption will not pose any undue risk to the health and safety of the public or involve a significant safety hazard.
Special circumstances, as provided in 10CFR50.12(a)(2)(ii), are
-present justifying the partial exemption from Appendix J.
Namely, application of the regulation in the particular circumetances is not necessary to achieve its underlying purpoco, which is to ensure that accurate and conservative methods are used in performing three containment leak rate tests at approximately equal intervals within each 10-year interval throughout the life of the 11 ant.
LTEILh The proposed changes to T/S 3/4.6.1.2 revise the exinting ACTION Statement into three ACTION Stat ments in lieu of one to be more
- compatible with the Limiting Condition for Operation, (LCO), and clarify the Surveillance Requirements to be more consistent with the intended requirements of 10CFR50,-Appendix J.
The expnnsion of the ACTION Statement from one into three provides more airection on what to do when the LCOs for containment leakagt rates are net being met.
Proposed ACTION Statement a. provides the corrertive measures to be taken when the overall containment integrated leakage rate exceeds the allowable leakage rate, L.
Proposed ACTION Stritement b.
modifies the existing ACTION Statement to specify what Action to take when the "as left" overall containment integrated leakage rate exceeds 0.75 L prior to increasing the Reactor Coolant System (RCS) temperRture above 200 F.
Proposed ACTION Statement provides the corrective measures to be taken when the combined c.leakage rate-for all penetrations and valves subject to Type B and C tests exceeds 0.60 L tente are performed while at power (i;e. RCS_above 200"E)if the By dividing the existing ACTION Statement into three, more direction is provided for corrective action to be taken when the LCO is not being met.
The existing ACTION Statement is unclear as to whether or not the 0.75 L is the
as found" or "as left" leakage rate and does not provi8e direction on what to do when
-Type B and C tests are not satisfied or a failure to satisfy the Type B and C criteria is uncovered when the RCS temperature is above 200*F.
The proposed change to Surveillance Requirement T/S 4.6.1.2a removes the "40 1 10 month intervals" that the three Type A-tests (CILRT) shall be conducted at and replaces it with "approximately-equal intervals".
The removal from the T/S of the schedule for conducting the three Type A tests will not result in any loss of regulatory control since the requirements of Appendix J te
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Page 7 of 7 ULNRC-2378 j -
10CFRSO provide a schedule for conducting these test.
The temoval of the 40 130 month time frame for test performance is also juntifiable si. ice it does not coincide with an 18-month refueling outage schedule._ Callaway Plant refuels on approximately an 20-month cycle and the 40 +10 month maximum 4
interval could cause a fourth test to be performed in a future l
10-year service period.
Therefore, because this duplication le unnecessary, the removal of this, T/S schedule as a line-item o
improvement is consintent with the Commission Policy Statement on T/S improvements.
This-approach in consistent with that taken in Generic Letter 91-01 in which the reactor vessel material-specimen withdrawal schedule has been removed from Technical Specifications because it is also contained in 10CFR50, Appendix H.
The proposed changes to T/S 3/4.6.1.2 do not involve an unreviewed safety question because operation of Callaway Plant with these changes would not:
a.
Increase the probabil'ity of occurrence or the concequences of an_ accident or malfunction of equipment important to safety previously evaluated in'the-safety analysis report.
The expansion of the ACTION Statements provides more definitive corrective action to take when an LCO is not in compliance, and the Surveillance Requirements have been clarified to be more consistent with the intended objectives of Appendix-J. - These chnngan do not impnet the leakage-t-
raten assumed by accident analynen, b.
Create the _ponsibility for an acejdent or malfunction cf equipment of a different type than any previously ovalunted in the safety ar.nlyrads report.
There-are no design changes i
being made that would clonto the possibili ty for an accident or malfunct: ion' of equipment.
The changes provide clarification to the ACTION Statements and Surveillance Requirements.
c.
Reduce the margin of safety as defined in the basis for any j
technical specification.
The changes provide more direction on what corrective measures to take when an LCO is not met and clarifieu the Surveillance Requirements for performing the Type A tests required by Appendix J.
l Given the above discuselons as well as those presented in the Significant Hazards Consideration, the propoced. changes do not adversely affect or endanger the health or safety of the general public or involve a significant safety hazard'.
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Att achment 2 Page 1 of a I
UL11RC-23 78 1
i' SIG111F.ICA14T llA".ARDS CO!4SIDERATIO14 i
This amendment-requeet revises Technien1 Specifications (T/S) 3/4.6.1.1 and 3/4.6.1.2 which address Containment Integrity and Containment Leakage.
'wo words, " manual and closed", are to be added to T/S 4. 6,1. la co be consistent wi th T/S Defini tion 1. 7
)
for Containment Integrity.
The changes to T/S 3/4.6.1.2 are to expand the existing ACTION Statement into three ACTIO!J Statements, remove the tio between CILRT testing and innervice 4
-inspection testing, and revines the curveillance interval to be more consistent with 10CFR50, Appendix J.
1 1.
The proposed change to T/S 4.6.3.la doca not:
Involve a significant increase in the probability or consequences of an accident previously evaluated.
The chance providen clarifiention and in adminintrative in natune.
Create the ponnibility of a new or dif ferent kind of accident from 6ny accident previounly evaluated.
There are no design changes being made that would create a new type of accident or malfunction and the method and manner of plant j
operation remainn unchanged.
Thin change is merely an admit.istrative change, c
invo:.ve a significant reduction in a margin of safety.
The 6-change provides clarification and is an administrat.3ve only change.
Therefore, the margin of nafety is unaffected.
2.
The proponed change to T/S 4.6.3.2b doen not:
Involve _ a signi ficant increase in the probability or consequences of an accident previously evaluated.
The Surveillance Requirement has been clarifled to be more consistent with the objectiven of Appendix J and thn off si te J
radiological consequences of an accidant assumed in the Sa fety Analysi s have not buen al tered.
Create the possibili ty of a now or dif ferent kind of accident from any-necident previously evaluated.
There ate no design changes being made that would create a new type of accident or malfunction and the method and manner of plant operation remain unchanged.
The change to the Surveillance Requirement provides clarification consistent with regulatory requirements.
Involve a significant reduction in a margin of safety.
There are no changes being made to the-safety limits-or safety system settings that would adversely impact plant safety.- The-change to the Surveillance Requi rement is in conformance with the requirements specified in Appendix J.
~
7 -,_.... -. -. - _ -
Athchment 2 i
1%ge 2 of 3
%NRC* 2378 i
3.
The proposed change to T/S 4.6.1.2a to dd eto the 4
requirement to perform the third tes' of each cet during the 4
shutdown for the 10-year plant $ % rvice inspection does not:
4 Involve a significant increase in the probability or consequences of an accident previously evaluated.
The deletion of this requirement from the T/S does not impact plant safety since the requirements of Appt.ndix J to perform the Type A tests (CILRT) must still be complied with.
1 Create the possibility of a new or different kind of accident from any accident previously evaluated.
There are no design changes being made that would etente a new type of e
accident or malfunction and the method and manner of plant operat2on remains unchanged.
The change deletes an
. unnecessary tie between two regulations, but still meets the intent of the regulations.
7 Involve a significant reduction in a margin of safety.
There are no changes being made to the safety limits or safety fyStem settings that would adversely impact plant safety.
The change deletes an unnecesonry requirement that does not impact the margin of safety.
4.
The proposed changes to T/S 3/4.6.1.2 do noti J nvolve a sistnif.tcant increase in the probability or consequences of an accident previously evaluated.
These proposed changes clarify an existing technical specification to provide more definitive corrective actions to take if the L
LCOs for contair nent leakage ratos are not being met.
- Alao, the demonstracion that containment leakage rates are in conforma % e.with Appendix J, 10CFR50, has been clarified,
-however the the intent has not been changed nor the offsite radiological consequences of an accident assumed in the safety analynis attored.
Create the possibility of a ncs or different kind of i'
accident from any accident previously evaluated.
There are no denign changes-being made that would create a new type of accident or malfunction and the method and manner of plant operation remains unchanged.
These changes merely provide d ear guidance to accomplish actions commiserate with the existing situation and Surveillance Requirements that are consistent with regulatory requirements.
1-Involve a significant reduction in a margin of safety.
There -_are no changes being made to the safety limi ts-or safety-system settings that would adversely impnct-plant safety.
These changes _ impose corrective actions consistent with other-Containment System Technical Specifications-and changes to the surveillance Requirements are in conformance with the requirements specified in Appendix J.
Therefore the margin of safety is unaffected.
. _ ~ _ _,.. _. _. _. _. _,. _ _ _ _ -. _ _ _ _ _. _ _ _ _ _, _. _, _ _. _,
Page 3 of 3 UI.!mC-2 378 linted on the abova -di scunnions, it has been determined ihnt thei requested Technien1 Specification revisione do not involve a significant increase in the probability or conoequences of an accident or other adverno condition over previous evnluntions; or crente the possibility of a new or different kind'of accident or condition over previous evaluations; or involve a significant reduction in a margin of safety.
Therefore, the requested license amendment doen not involve n r:ignificant hazardo consideration.
1 l
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