Text

Forwards TMI-1 TS Change Request 253 to Incorporate Certain Improvements from Std TS for B&W Plants (NUREG-1430)
	ML20135D092
Person / Time
Site:	Crane
Issue date:	12/03/1996
From:	James Knubel; GENERAL PUBLIC UTILITIES CORP.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20135D095	List: ML20135D092; ML20135D099;
References
	RTR-NUREG-1430 6710-96-2349, NUDOCS 9612090240
	Download: ML20135D092 (20)
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GPU Nuclear, Inc.

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Route 441 South NUCLEAR Post Office Box 480 Middletown, PA 17057 0480 Tel 717-944 7621 (717) 948-8005 December 03, 1996 6710-96-2349 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Dear Sir:

Subject:

Three Mile Island Nuclear Station, Unit 1 (TMI-1)

Operating License No. DPR 50 Docket No. 50-239 Technical Specification Change Request No. 253 Changes to Incorporate Improvements from the Revissi B&W Standard Technical Specifications (STS), NUREG-1430 In accordance with 10 CFR 50.4(b)(1), enclosed is TMI-l Technical Specification Change Request (TSCR) No. 253. The purpose of this TSCR is to incorporate certain improvements from the Standard Technical Specifications (STS) for B&W Plants (NUREG-1430).

Using the standards in 10 CFR 50.92, GPU Nuclear has concluded that these proposed changes do not constitute a significant hazards consideration, as described in the enclosed analysis performed in accordance with 10 CFR 50.91(a)(1). Also enclosed is a Certificate of Service for this request, certifying service to the chief executives of the township and county in which the facilities are located, as well as the designated official of the Commonwealth of Pennsylvania, Bureau ofRadiation Protection.

Sincerely, j

U i *k J. Knubel Vice President and Daector, TMI A%%i j\\ ON j

9612090240 961203 DR ADOCK 05000289 p

PDR

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Enclosures:

1) TMI-l TSCR 253 Safety Evaluation and No Significant Hazards Consideration

2) TMI-l Technical Specifications Revised Pages

3) Certificate of Service for TMI-l TSCR 253 cc:

RegionI Administrator TMI-l Senior Project Manager TMI Senior Resident Inspector 4

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i METROPOLITAN EDISON COMPANY 1

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JERSEY CENTRAL POWER AND LIGHT COMPANY t

PENNSYLVANIA ELECTRIC COMPANY d/b/a GPU ENERGY I

i GPU NUCLEAR, Inc.

l Three Mile Island Nuclear Station, Unit 1 Operating License No. DPR-50 Docket No. 50-289 Technical Specification Change Request No. 253 COMMONWEALTH OF PENNSYLVANIA

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COUNTY OF DAUPHIN

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This Technical Specification Change Request is submitted in support of Licensee's request to change Appendix A to Operatir g License No. DPR-50 for Three Mile Island Nuclear Station, Unit 1. As pan of this request, proposed replacement pages for Appendix A are also included.

All statements contained in this submittal have been reviewed, and all such statements made and matters set fonh therein are true and correct to the best of my knowledge.

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BY:

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President and Director, TMI Sworn and subscribed before me this 832. day of L 1996.

s Motary Public Nohn! Lt..J Suzanne C. I&lo'd.t. Nata:y f'ubhc Londondeny Twp.. Cauph.1 Ocunty My Commission E ;pires Nov. 22.1999 lAcmber. PennsyWania Assctiaton of Natanes

TMI-l TSCR 253 Safety Evaluation and No Significant Hazards Consideration Analysis

6710-96-2349 4

Page 1 of 10 4

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TECHNICAL SPECIFICATION CHANGE REOUEST (TSCR) NO. 253 GPU Nuclear requests that the following change be made to the existing TMI-l Technical Specifications (TS):

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A. Replacement pages:

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ii, iii, vii, 3-18a, 3-21, 3-22, 3-25, 3-33, 3-34, 3-34a, 3 -35, 3-3 5 a, 3-36, 3-36a, 3-38,3-40,4-8,4-9,4-48,4-50 B.

Deleted pages:

3-18b, 3-39 l

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New pages:

3-35b II.

REASON FOR CHANGE l

The primary purpose of this TSCR is to incorporate cenain improvements from the Revised Standard Technical Specifications (RSTS) for B&W Plants (NUREG-1430) that would allow deletion or relaxation of selected limiting conditions for operation (LCOs) that do not meet the criteria for technical specifications as set forth in 10 CFR 50.36(c)(2)(ii) and are not reflected in l

the Revised Standard Technical Specifications (RSTS) for B&W plants delineated.in NUREG 1430. The requirements of the deleted LCOs are contained in licensee controlled documents.

j This TSCR also proposes to delete or modify several Surveillance Requirements. As with the LCOs, the activities required by the propesed deletions to the Surveillance Requirements are contained in licensee controlled documents.

In addition, this TSCR proposes to add time clocks to certain LCOs and make editorial changes, 2

such as spelling corrections and Table of Contents corrections.

1 The requested changes are summarized as follows:

1 A.

Table of Contents pages ii, iii, and vii:

Page ii reflects the deletion oflimiting condition of operation (LCO) 3.1.10 and LCO 3.5.4.

Page iii corrects a typographical error by positioning page number 4-37 in its correct column, and reflects the deletion of suneillance requirement 4.7.2.

6710-96-2349 Page 2 of 16 Page vii reflects deletion of Figure 3.1-3, " Limiting Pressure vs Temperature Curve for 100 STD cc/ Liter H2O " and corrects description of Figure 5-4 and adds Figure 5-5 and its corresponding page number.

B.

Limiting condition for ope ation 3.1.10 and associated Figure 3.1-3, Control Rod Operatiorc Deletion oflimiting condition for operation 3.1.10 and Figure 3.1-3 in their entirety.

Limiting condition for operation 3.1.10 and its associated Figure 3.1-3 provide assurance of hydraulic buffer action during a control rod trip by precluding the collection of undissolved gases in the control rod motor tubes.

C.

Limiting condition for operation 3.3, Emergency Core Cooling, Reactor Building Emergency Cooling and Reactor Building Spray Systems:

Subsection 3.3.1.1.a is revised to provide timeclocks to restore the BWST baron concentration, water temperature, and volume to OPERABLE status.

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Subsection 3.3.1.2.c is revised to provide a timeclock to restore to open the core flood tank discharge valves.

Subsection 3.3.1.3.b is revised to provide timeclocks to restore NaOH tank concentration and BWST/NaOH tank level differential limits.

D.

Limiting condition for operation 3.4, Decay Heat Removal Capability:

j Subsection 3.4.1.1.a.(2) has been revised to delete the phrase "or be suberitical" and 4

extends the timeclock to be in COLD SHUTDOWN from 6 to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

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Limiting condition for operation 3.5.2, Control Rod Group and Power Distribution Limits-The spelling of" assure" is corrected in the Obiective statement of this LCO.

Subsection 3.5.2.2.a is revised to correct the spelling of" rod", and is also revised to provide actions and associated timeclocks of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and I hour.

Subsection 3.5.2.2.c is revised to modify the action and timeclocks of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

Subsection 3.5.2.2.e is revised to modify the action and provide timeclocks of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months .

Subsection 3.5.2.2.fis revised to provide a timeclock of I hour.

Subsection 3.5.2.2.g is revised to provide a timeclock of I hout

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i 6710-96-2349 Page 3 of 16 l

- Subsection 3.5.2.4.e is revised to change a timeclock from 4 to 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , and adding the phrase " verifications and/or" before the word " adjustments."

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l Subsection 3.5.2.4.e.1 has been replaced with actions and associated timeclocks involving verification that power peaking factors are within the COLR limits.

3 Old subsections 3.5.2.4.e.1,3.5.2.4.e.2, and 3.5.2.4.e.3 have been renumbered to 3.5.2.4.e.2,3.5.2.4.e.3, and 3.5.2.4.e.5 respectively.

l Subsection 3.5.2.4.fis revised to modify the action and provides a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months timeclock.

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Subsection 3.5.2.4.g is revised to change actions and provide timeclocks with and l

without the quadrant power tilt (QPT) alarm operable, and provides an action following QPT restoration to less than or equal steady state limit.'

i Subsection 3.5.2.5.b has been revised to include two subsections,3.5.2.5.b.1 and I

3.5.2.5.b.2.

Subsection 3.5.2.5.b.1 provides action regarding regulating rods inserted in the restricted operating region and associated timeclocks.

Subsection 3.5.2.5.b.2 provides action regarding regulating rods inserted in the unacceptable operating region and associated timeclocks.

Subsection 3.5.2.7.d is revised to provide action associated with the power peaking factors and a timeciock of once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months when not within imbalance limits.

Subsection 3.5.2.7.e is revised to change a fc.ur hour timeclock to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and changes a reactor power reduction requiremers..

Subsection 3.5.2.7.fis revised to change the axial power imbalance monitoring frequency from 2 to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when the axial power imbalance alarm is operable and every I hour when the alarm is inoperable.

Subsection 3.5.2.8 is revised to change the "30" effective full power days to "31."

The Bases to LCO 3.5.2,on page 3-35a, is revised to include the followmg subsections of LCO 3.5.4, Incore Instrumentation: 3.5.4.1, Axial Power Imbalance;

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3.5.4.2, Quadrant Tilt; and the Bases section with the following exceptions - Bases subsection c is not included, the last sentence of Bases subsection d.3 is not included, and Bases subsection e is not included. These additions to bases for LCO 3.5.2 result i

in the creation of a new page,3-35b.

.The Bases to LCO 3.5.2; on page 3-36, the last paragraph, the last sentence; is revised by replacing the phrase "at least every two hours" with "as specified."

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i 6710-96-2349 Page 4 of 16 The Bases to LCO 3.5.2; on page 3-36a, the last paragraph; is revised to reflect different high flux trip setpoints during the physics testmg program.

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Limiting condition for operation 3.5.4: Incore Instrumentation.

Deletion oflimiting condition for operation 3.5.4 and all subsections, except that l

Figures 3.5-1,3.5-2, and 3.5-3 are retained. Limiting condition for operation 3.5.4 specifies the functional and operational requirements of the incore instrumentation

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system for the Minimum Incore S) stem (MIS)..

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Surveillance Requirement Table 4.1-2:

l Minimum Equipment Test Frequency

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The frequency for item 2, Control Rod Movement, is revised from two weeks to 92 3

days.

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Surveillaw A Requirement Table 4.1-3:

Minimum Sampling Frequency Item 1.a of Table 4.1-3 is revised to change the frequency from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to 7 days.

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Surveillance Requirement 4.7.1, Control Rod Drive System Functional Tests

- Subsection 4.7.1.1 is revised to correct the spelling of" shaping".

The second paragraph, first sentence, of the Bases section is revised to specify "a minimum of 3% of travel" and changes "every two weeks" to "at a minimum of every 92 days."

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Surveillance Requirement 4.7.2, Control Rod Program Verification (Group vs. Core Positions)

Deletion of surveillarce requirement 4.7.2 in its entirety. Surveillance Requirement 4.7.2 verifies that the designated control rod (by core position 1 through 69) is operating in its programmed functional position and group. (rod I through 12, group l-8) l k

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6710-96-2349 Page 5 of 16 III.

SAFETY EVALUATION JUSTIFYING CHANGE

Background

The NRC has amended 10 CFR 50.36(c)(2)(ii) for the purpose ' f allowing licensees to improve Technical Specifications by simplifying them to place emphasis on two classes of technical matters; those that are related to the prevention of accidents and those that are related to the mitigation of accidents. The NRC has identified four criteria against which a Technical Specification limiting condition for operation (LCO) can be compared. Those criteria are:

Criterion 1 Installed instrumentation that is used to detect, and indicate in the control room, a

ignificant abnormal degradation of the reactor coolant pressure boundary.

Criterion 2 A process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Criterion 3 A structure, system, or component that is part of the primary success path and which functions oi sctuates to mitigate a Design Basis Accident or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

I Criterion 4 1

A structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.

If a current Technical Specification limiting condition for operation does not meet any of the above criteria, it may be proposed for deletion ifit is contained in other licensee controlled documents".

This TSCR proposes the deletion oflimiting conditions of operation that are currently contained in the TMI-l Technical Specifications that do not meet the criteria set forth in 10 CFR 50.36 (c)(2)(ii) and that are not contained in NUREG 1430, Revised Standard Technical Specifications for B&W Plants but that are contained in licensee controlled documents. The evaluation of the deletion of each LCO specifies why the I In this context, licensee controlled documents are those documents for which changes thereto must be evalua:ed in accordance with 10 CFR 50.59 prior to implementation. An example of a licensee controlled document is a site procedure.

i 6710-96-2349 Page 6 of16 current LCO does not meet any of the 4 criteria in 10 CFR 50.36 (c)(2)(ii), states that the LCO is not contained in NUREG 1430, RSTS and specifies what licensee controlled 4

document contains the requirements / activities addressed by the LCO.

In addition, the TSCR proposes the deletion of a surveillance requirement.

l The TSCR also proposes incorporations from NUREG 1430 that would allow deletion or relaxation of selected requirements without a reduction in plant safety.

Finally, there are numerous administrative and editorial changes, such as, to revise the Table of Contents and spelling corrections.

The changes are evaluated as follows:

Table of Contents. names li. iii. and vii j

i The changes are administrative in nature in that they reflect proposed changes and correct typographical errors and in the case of Figures 5-4 and 5-5 correct an omission associated with TS Amendment 170.

I Limitine Condition for Operation 3.1.10 and associated Finure 3.1-3 The current TMI-l Technical Specifications limiting condition for operation 3.1.10 and associated Figure 3.1-3 specifies allowable combinations of pressure and temperature for control rod operation and dissolved gas limits for the reactor coolant system when the control rods are withdrawn.

Maintaining the allowable combinations of pressure and temperature for control rod operation and dissolved gas limits for the reactor coolant system is intended to assure hydraulic buffer action during a control rod trip by precluding the collection of undissolved gases in the control rod motor tubes. Maintenance of the allowable combina+icus of pressure and temperature for control rod operation and dissolved gas j

limits for the reactor coolant system does not involve surveillance of plant parameters to prevent an accident nor is it directly involved in the mitigation of an accident. LCO 3.1.10 therefore does not meet any of the requirements of Criteria 1,2,3, or 4 in 10 CFR 50.36(c)(2)(ii) for retention in Technical Specifications.

1 There is no RSTS in NUREG 1430 concerning the allowable combinations of pressure and temperature for control rod operatio~n and dissolved gas limits for the reactor coolant system.

The monitoring of the allowable combinations of pressure and temperature for control rod operation and dissolved gas limits for the reactor coolant' system is addressed in TMI-l procedures 1103-2, " Fill and Vent of the Reactor Coolant System" and 1105-9 " Control i

Rod Drive System."

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6710-96-2349 Enclosure I t

Page 7 of16 l

LCO 3.1.10 and associated Figure 3.1-3 can be deleted from the TMI-l Technical l

Specifications because it does not meet the criteria of 10 CFR 50.36(c)(2)(ii) for a l

technical specification, there is no corresponding RSTS in NUREG 1430, and the monitoring of the allowable combinations of pressure and temperature for control rod l

operation and dissolved gas limits for the reactor coolant system is addressed in controlled l

plant procedures.

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1.imitine Condition for Operation 3.3 Subsection 3.3.1.1.a currently provides BWST volume, temperature, and concentration t

limits. However there are currently no timeclocks specified to get back within limits. The i

proposed change to this subsection would provide a 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months timeclock to restore the boron concentration or water temperature and a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months timeclock to restore the BWST volume.

These timeclocks are consistent with the RSTS, and provide reasonable restoration times consistent with other ECCS equipment.

Thus, addition of timeclocks for restoring BWST volume, temperature and concentration isjustified.

Subsection 3.3.1.2.c currently provides a requirement for the electrically operated discharge valves from the core flood tank to be assured open. However there is currently no timeclock specified to restore the valves to their required status. The proposed change to this subsection would provide a one hour timeclock to open the valve and remove power to the valve. This action and timeclock is consistent with the RSTS, and ensures that prompt action will be taken to return the inoperable core flood tank discharge valve l

to operable status.

Thus, an addition of a timeclock to restore the required valve status isjustified.

Subsection 3.3.1.3.b currently provides requirements for sodium hydroxide (NaOH) tank concentration and BWST/NaOH tank level differential limits. There are currently no i

timeclocks specified to get back within limits. The proposed change to this subsection would provide a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months timeclock to restore the NaOH concentration and a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months timeclock to restore the BWST/NaOH tank differential to within its limit. The proposed timeclocks are consistent with the timeclocks specified by the RSTS for the Spray Additive System. With the spray additive system inoperable, the spray system would still be available and would remove some iodine from the containment atmosphere in the event of a DBA. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months timeclock takes into account the low probability of the worst-case DBA occurring during this period.

Thus, addition of a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months timeclock for restoring NaOH tank concentration and BWST/NaOH tank differential isjustified.

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Page 8 of 16 Limitine Condition for Operation 3.4 Subsection 3A 1.1.a.(2) currently provides required action and associated timeclocks with more than one EFW pump or flow path inoperable. The proposed change to this subsection would delete the phrase "or be subcritical", and extend the timeclock to be in COLD SHUTDOWN from 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The phrase "or be subcritical" is used in conjunction with the action to restore the inoperable pumps or flow paths to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Thus, this phrase i

may result in unnecessarily hasty power reductions while still only requiring to be in HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . A controlled power reduction is more desirable and J

thus this phrase should be deleted. This phrase is not included in the RSTS. The extension of the timeclock to be in COLD SHUTDOWN from 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months provides a more reasonable time frame and is consistent with that provided in RSTS.

Thus, deletion of the phrase "or be subcritical", and extension of the timeclock to be in COLD SHUTDOWN from 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months isjustified.

Limitine Condition for Operation 3.5.2 Correction of the spelling of" assure" in the Objective statement, and " rod" in subsection 3.5.2.2.a is editorial.

Subsection 3.5.2.2.a currently states that operation with more than one inoperable rod in the safety or regulating rod banks is not permitted. However there are no timeclocks specified for reactor shutdown or verification of shutdown margin (SDM). The proposed change to this subsection would provide actions to bring the reactor to HOT SHUTDOWN within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and verify SDM within limits or initiate boration to restore within limits within I hour. These actions and timeclocks are consistent with the RSTS, and provide a reasonable time for reaching HOT SHUTDOWN from full power in an orderly manner and allows the operator adequate time to determine the SDM, Thus, addition of a 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months HOT SHUTDOWN timeclock and a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months timeclock to initiate boration if SDM is inadequate is justified.

Subsection 3.5.2.2.c currently provides reactor shutdown requirements associated with an inoperable rod as defined in Technical Specification 4.7.1. The proposed change would require an additional determination of adequate SDM 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months afler an initial determination of adequate SDM when it was determined that an inoperable rod exists. Currently the reactor is required to be brought to HOT SHUTDOWN until the adequate SDM is established. The proposed change would provide a 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months timeclock to bring the reactor to HOT SHUTDOWN. These proposed changes are consistent with the RSTS, and provide assurance that further degradation of the SDM is not occurring and also provide a reasonable time for reaching HOT SHUTDOWN from full power in an orderly manner.

Thus, addition of the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SDM determination and a 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months timeclock to reach HOT SHUTDOWN isjustified.

6710-96-2349 Page 9 of 16 Subsection 3.5.2.2.e currently provides reactor power reduction requirements associated with control rod dignment problems. The proposed change to this subsection adds a clarifying phrase, "and cannot be aligned per 3.5.2.2.f," immediately after 4.7.1.2. This phrase is added to highlight the existing paragraph 3.5.2.2.f and is editorial in nature.

l The proposed change also modifies the required power reduction from 60% to less than or equal to 60% of the thermal power allowable for the reactor coolant pump combination.

This change clarifies the intent of the existing subsection and is consistent with the RSTS.

The proposed change would provide a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months timeclock to reduce reactor power to less than or equal to 60% of the thermal power allowable for the reactor coolant pump combination, and a 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months timeclock to reduce the overpower trip setpoint. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months timeclock allows the operator suflicient time for reducing reactor power. The 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months timeclock allows the operator 8 additional hours after completion of the reactor power reduction to adjust the trip setpoint. In addition the proposed change would provide a requirement to verify the ejected rod worth (ERW) is within the assumptions of the ERW analysis and to verify that the power peaking factors are within the limits specified by the 4

COLR within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months timeclock is acceptable because local linear heat rates are limited by the reactor power reduction and sufficient time is provided to perform the required evaluation. These proposed changes are consistent with the RSTS.

Thus, these proposed changes to subsection 3.5.2.2.e arejustified.

Subsection 3.5.2.2.f currently provides an allowance for continued operation with a control rod inoperable per Specification 4.7.1.2. Operation may continue provided the rods in the group are positioned such that the rod that was declared inoperable is maintained within allowable group average position limits of Specification 4.7.1.2. The proposed change to this subsection would provide a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months timeclock to perform the required action. This timeclock is consistent with the RSTS, and is acceptable because local xenon redistribution during this short interval will not cause a significant increase in local linear heat rate..

Thus, addition of a timeclock to position the rods appropriately isjustified.

Subsection 3.5.2.2.g currently provides an allowance for normal operation of 100 percent of the thermal power allowable for the reactor coolant pump combination with a control rod inoperable. Operation at 100 percent of the thermal power allowable for the reactor coolant pump combination may continue provided that the rod that was declared inoperable is maintained within the allowable group average position limits in Specification 3.5.2.5. The proposed change to this subsection would provide a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months timeclock to perform the required action. This timeclock is consistent with the RSTS, and is acceptable because local xenon redistribution during this short interval will not cause a significant increase in local linear heat rate..

Thus, addition of a timeclock to maintain the inoperable rod within the appropriate group average position limits is justified.

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Page 10 of 16 i.

Subsection 3.5.2.4.e currently provides requirements for reducing the quadrant power tih n

to less than the tilt limit. 'I he proposed change to this subsection would revise the existing 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months timeclock to reduce the quadrant power tilt to les s than the tilt limit to a 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months timeclock. This 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months timeclock is consistent with the RSTS; and is reasonable based R

j on the need to limit the potentially adverse xenon redistribution, the low probability of an accident occurring while operating out of specification, and the number of steps required to complete the required action.

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i Subsection 2 *.2.4.e also currently allows an alternate action when the quadrant power tilt is beyond the tilt limit which requires that "the following adjustments in setpoints and j.

limits shall be made:". The proposed change would modify this phrase as follows: "the j

following verifications and/or adjustments in setpoints and limits shall be made:". The current subsection 3.5.2.4.e currently lists 3 adjustments in setpoints and limits that are made if this alternate action is followed when the quadrant power tilt is beyond the tilt limit. The proposed change would add a 4th step, that of verifying the power peaking factors within the COLR limits once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and to restore QPT to less than or equal to the steady state limit within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , or perform steps 2,3,&4 below. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months timeclock is a reasonable amount of time to allow the operator to obtain a power distribution map and to verify the power peaking factors. Repeating this activity every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is a reasonable frequency at which to ensure that continued verification of the power peaking factors is obtained as core conditions that influence quadrant power tilt change.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months timeclock to reduce QPT to less than the steady state limit is a reasonable time for investigation and corrective measures. By adding a new step 1, the existing 1,2,and 3 steps are renumbered to steps 2,3, and 4. These proposed changes are consistent with the RSTS.

Thus, revision of the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months timeclock to a 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months timeclock and the addition of a power peaking factor verification with associated 2 and 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months timeclocks is justified.

4 i

Subsection 3.5.2.4.f currently provides for the reactor to be placed in the HOT

. SHUTDOWN condition if quadrant tilt is in excess of the maximum tilt limit defined in the COLR. The proposed change would revise this action to reduce thermal power to less j

than or equal to 15% full power within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . A power reduction to at most 15% full

)

power ensures local linear heat rates do not exceed allowable limits while the cause is being determined and corrected. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months timeclock is reasonable to allow the operator t

to reduce reactor power to less than or equal to 15% full power without challenging plant systems. This action and associated timeclock is consistent with the RSTS.

Thus, revision of the HOT SHUTDOWN requirement to a reduction ofless than or equal to 15% full power within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months isjustified.

Subsection 3.5.2.4.g currently provides a minimum monitoring frequency of quadrant tilt every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months when power operation is above 15% of rated power. The proposed change would revise the quadrant power tilt monitoring frequency to every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when the QPT alarm is inoperable and every 7 days when the alarm is operable. Should the plant

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6710-96-2349 Page 11 of16 i

computer become inoperable, performing a calculation every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient to l

follow any changes in the QPT that may approach the setpoint because with the exception l

of control rod related eff'ects, which are detected by other systems, QPT changes are slow,and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months also provides operators sufficient time to undertake corrective actions j

if QPT approaches the setpoints. When the plant computer alarm is operable operating

[

experience has confirmed the acceptability of the 7 day frequency to ensure the plant i

computer software and Incore Detector System inputs for monitoring QPT are functioning properly. Also, the proposed change would require verification hourly for 12 consecutive hours, or until verified acceptable at greater than or equal to 95% full power when QPT has been restored to less than or equal to the steady state limit. These 12 consecutive j

hourly checks are performed to determine whether the period of any oscillation due to xenon redistribution causes the QPT to exceed the steady state limit again. This proposed j

change is consistent with the RSTS.

b i

Thus, revision of the quadrant tilt monitoring requirements is justified.

Subsection 3.5.2.5.b currently provides a four hour timeclock to achieve an acceptable regulating control rod position. The proposed change would revise this subsection by 1

adding two additional subsections which would provide requirements for having regulating j

rods inserted in the restricted operating region, and requirements for having regulating rods inserted in the unacceptable operating region.

The new subsection 3.5.2.5.b.1 would require that acceptable control rod positions be attained within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months if regulating rods were inserted in the restricted operating region.

Also, the power peaking factors shall be verified within limits once every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months while in the restricted region, or power shall be reduced to less than or equal to the power allowed by the insertion limits. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months timeclock is acceptable in that it allows the operator sufficient time for obtaining a power distribution map and for verifying the power peaking factors. Repeating this every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months hours is acceptable because it ensures that continued l

verification of the power peaking factors is performed as core conditions change. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months timeclock allowed for operating in the restricted region is reasonable based on the low probability of an event occurring simultaneously with the limit out of specification in 4

this relatively short time period. In addition, it precludes long term depletion with abnormal group insertions or configurations, thereby limiting the potential for an adverse

~

xenon redistribution.

The new subsection 3.5.2.5.b.2 would require that if regulating rods were inserted in the unacceptable operating region, boration be initiated within 15 minutes to restore SDM to less than or equal to 1% delta k/k, and regulating rods are restored to within the restricted region within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , or reduce power to less than or equal to the power allowed by the rod insertion limits. The 15 minute timeclock for initiating boration is reasonable, based on limiting the potential xenon redistribution, the low probability of any accident occurring in this relatively short time period, and the number of steps required to complete this action. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months timeclock allows sufficient time for borated water to enter the RCS from the chemical addition and makeup systems, thereby allowing the regulating rods to be withdrawn to the restricted region.

.. ~. -. -.. _. - -

l 6710-96-2349 l

1 Page 12 of 16 These changes to subsection 3.5.2.5.b are consistent with the RSTS. Thus, the revision of the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months timeclock to a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months timeclock, and other additions to this subsection are i

justified.

l i

Subsection 3.5.2.7.d currently provides that corrective measures be taken to maintain l

axial power imbalance within the envelope defined in the COLR. The proposed change to

{

this subsection would provide a verification every two hours that the power peaking factors are within limits when not within the axial power imbalance envelope. This two hour frequency provides reasonable time to ensure that continued verification of the i

power peaking factors is obtained as core conditions change, because little rod motion i

occurs in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months due to fuel burnup, the potential for xenon redistribution is limited, and j

the probability of an event occurring in this short time frame is low. This verification j

requirement is consistent with the RSTS.

Thus, addition of a verification requirement for power peaking factors when not within the axial power imbalance envelope defined in the COLR is justified.

l Subsection 3.5.2.7.e currently provides a 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months timeclock to achieve acceptable axial power imbalance. If not achieved within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months reactor power shall be reduced until i

imbalance limits are met. The proposed revision to this subsection would change the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months timeclock to a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months timeclock, and revise the reactor power reduction requirement to a reduction to less than or equal to 40% full power within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The 24 I

hour ti neclock is reasonable based on the low probability of a limiting event occurring simultaneously with the axial power imbalance outside the limits. In addition, this 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months j

timeclock precludes long term depletion of the reactor fuel with excessive axial power 1

imbalance and gives the operator sufficient time to reposition the APSR's or regulating rods to reduce the axial power imbalance because adverse effects of xenon redistribution and fuel depletion are limited. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months timeclock is reasonable based on limiting a potentially adverse xenon redistribution, the low probability of an accident occurring in this relatively short time period, and the number of steps required to complete this action.

These proposed changes are consistent with the RSTS.

Thus, revision of the timeclock from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and revising the reactor power reduction requirement are justified.

Subsection 3.5.2.7.f currently provides axial power imbalance monitoring requirements of once every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months during power operation above 40% of rated power. The proposed revision to this subsection would change the axial power imbalance monitoring frequency from 2 to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when the axial power imbalance alarm is operable and every I hour when the alarm is inoperable. If the plant computer becomes inoperable, then the excore system or minimum incore detector system may be used to monitor the axial power imbalance. Although these systems do not provide a direct calculation and display of the axial power imbalance, a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months frequency provides reasonable time between calculations for detecting any trends in the axial power imbalance that may exceed its alarm setpoint and for undertaking corrective action. When the plant computer alarm is operable a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months frequency is acceptable because the mechanisms that can cause axial power imbalance, such as xenon redistribution or control rod drive mechanism malfunctions that

6710-96-2349 i

l Page 13 of 16 cause slow axial power imbalance increases, can be discovered by the operator before the 4

specified limits are violated. This change in monitoring frequency is consistent with the RSTS.

Thus, revision of the axial power imbalance monitoring requirements from every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months with the alarm operable and every hour when the alarm is inoperable is justified.

l Subsection 3.5.2.8 currently requires that a power map be taken at intervals not to exceed 30 effective full power days using the incore instrumentation detection system in order to verify the power distribution is within the limits shown in the COLR. The proposed change to this subsection would revise the interval from 30 to 31 effective full power days.

This change is requested to avoid any potential confusion regarding the time period for this requirement, since the intent is for a monthly interval and methly is defined as 31 days.

Thus, changing the interval for obtaining a power map from not to exceed 30 effective full power days to 31 effective fidl power days isjustified.

The Bases to LCO 3.5.2 is revised to include the following subsections of the current j

4 LCO 3.5.4, "Incore Instrumentation": Subsection 3.5.4.1, Axial Power Imbalance; 3.5.4.2, Quadrant Tilt; and the Bases of LCO 3.5.4 with the following exceptions - Bases subsection c is not included, the last sentence of Bases subsection d.3 is not included, and Bases subsection e is not included. The sections of LCO 3.5.4 which are proposed to be excluded in the Bases to LCO 3.5.2 involve the functianal and operational requirements of the minimum incore system (MIS). The MIS does not meet any of the requirements of Criterion 1,2,3, or 4 in 10 CFR 50.36(c)(2)(ii) for retention in Technical Specifications.

The Bases to LCO 3.5.2 is also revised on page 3-36, the last paragraph, the last sentence, by replacing the phrase "at least every two hours" with "as specified." This change is necessary to reflect the proposed changes for monitoring quadrant power tilt and axial power imbalance with the computer alarm is out of service.

Finally, the Ba:;es to LCO 3.5.2 is revised on page 3-36a, the last paragraph, to reflect the different high flux trip setpoints used during the physics testing program.

These proposed changes to the Bases of LCO 3.5.2 include appropriate information about the incore instrumentation system from the current LCO 3.5.4, which is being proposed for deletion, and revisions made necessary due to proposed changes to monitoring requirements and changes made to the physics testing program. Thus, these changes are justified.

Limitine Condition for Operation 3.5.4 1

LCO 3.5.4 currently provides the specification for the functional and operational requirements of the incore instrumentation system for the Minimum Incore System (MIS).

The proposed change would delete this LCO.

i i

6710-96-2349 Enc!osure 1 i

Page 14 of16 j

The MIS is not installed instrumentation used to detect degradation of the RCS pressure boundary, therefore Criterion 1 is not satisfied. The MIS is not a process variable that is i

an initial condition assumption in a design basis accident, therefore, Criterion 2 is not satisfied. The MIS is not connected to a Design Basis Accident or Transient that either 4

assumes the failure of or presents a challenge to the integrity of a fission product banier, j

thus Criterion 3 is not satisfied. The MIS has not been shown by PRA or operating i

experience to be significant to public health and safety, therefore LCO 3.5.4 does not meet Criterion 4.

i l

There is no technical specification in the RSTS contained in NUREG 1430 regarding the i

MIS.

j L

TMI-l procedures which address the MIS are 1301-5.3, Monthly Calibration of MIS, and i,

1203-7, Hand Calculation When PPC OOS.

i In summary, the deletion of LCO 3.5.4 isjustified because LCO 3.5.4 does not meet

]

criterion 1 through 4 of 10 CFR 50.36(cX2Xii), is not contained in the RSTS, and is addressed in controlled plant procedures.

Surveillance Reauirement Table 4.1-2 i

Table 4.1-2, item 2 currently requires movement of each control rod every two weeks, when the reactor is critical. The proposed change to this item would change the frequency of this control rod movement to every 92 days. This timeclock is consistent with the RSTS. Verifying each control rod is operable would require that each rod be tripped.

However, tripping each control rod during power operation could result in radial tilts.

Moving each control rod by 3% will not cause radial or axial power tilts, or oscillations, to occur. The 92 day frequency takes into consideration other information available to the operator in the control room such as the control rod misalignment indications and alarm which adds to the determination of operability of the rods.

Thus, revising the frequency for control rod movement from every two weeks to every 92 days isjustified.

Surveillance Reauirement Table 4.1-3 Table 4.1-3, item 1.a currently requires a Reactor Coolant Specific Activity Determination to compare to the 100/SpCi/gm limit at least once each 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months during POWER OPERATION, HOT STANDBY, STARTUP, and HOT SHUTDOWN. The proposed change to this item would provide a 7 day frequency rather than the existing 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This surveillance provides an indication of any increase in gross specific actisity.

The results of this surveillance allows proper remedial action to be taken before reaching j

the LCO limit under normal operating conditions. This 7 day frequency is consistent with i

the RSTS. The 7 day frequency considers the unlikelihood of a gross fuel failure during that time period.

6710-96-2349 Page 15 of16 Thus, revising the frequency for this surveillance item is justified.

Surveillance Reauirement 4,7,1

- The spelling of" shaping" is corrected in subsection 4.7.1.1. This is an editorial change.

The second paragraph, first sentence, of the Bases section currently states that each -

control rod drive mechanism shall be exercised by a movement of approximately two inches of travel every two weeks. This proposed ch:nge would revise this sentence to specify "a movement of a minimum of 3% of travel at a minimum of every 92 days."

Moving each control rod by 3% will not cause radial or axial power tilts, or oscillations, to occur. The 92 day frequency takes into consideration other information available to the operator, such as control rod alignment and associated operability requirements. This change would be consistent with the proposed change to Surveillance requirement Table 4.1-2, item 2 which proposes to revise the Control Rod Movement frequency from the current 2 weeks to 92 days. The 3% of travel is consistent with the RSTS.

Thus, revising the Bases to surveillance requirement 4.7.1 is justified.

Surveillance.Rennimnent L7,2 The current surveillance requirement 4.7.2 verifies that the designated control rod (by core position 1 through 69) is operating in its programmed functional position and group. This surveillance requirement contains specifications that are intended to prevent patching errors in the patch panel or connectors in the cables leading to the control rod drive assemblies, and prevent improperly connecting cables inside the Reactor Building. These types of errors would result in the affected control rod being inoperable. Since this surveillance requirement does not have a corresponding LCO and is formatted similar to an LCO, the four criteria will be used to determine ifit may be proposed for deletion.

Control Rod Program Verification is not installed instrumentation used to detect and indicate in the control room a significant abnormal degradation of the reactor coolant pressure boundary. Thus, criterion 1 does not apply. Control Rod Program Verification does not involve an initial conditior of a Design Basis Accident or Transient analysis and thus does not meet cr'.terion 2 or criterion 3. Control Rod Program Verification has not been shown in operazing experience or in the TMI-l PRA to be significant to the public health and safety and therefore criterion 4 is also not met.

There is no technical specification or surveillance requirement that addresses Control Rod Program Verification in the RSTS contained in NUREG 1430.

Proper rod program verification is addressed in TMI-l procedure 1301-9.2.

I

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6710-96-2349 i

Page 16 of16 l

The deletion of surveillance requirement 4.7.2 from the TMI-l technical specifications is justified because it does not meet criteria 1 through 4 of 10 CFR 50.36(cX2Xii), is not i-contained in the RSTS of NUREG 1430, and is addressed in a controlled plant procedure..

j.

IV.

NO SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS GPU Nuclear has determined that this Technical Speci6 cation Change Request involves no

{

significant hazards consideration as defined in 10 CFR 50.92 because:

i

1. Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability of occurrence or the consequences of an accident previously evaluated. The proposed amendment deletes limiting conditions for operation (LCOs) from the TMI-1 Technical Specifications that are no longer required to be

' addressed in Technical Specifications per 10 CFR 50.36(cX2Xii). The proposed amendment also deletes a Surveillance requirement from the TMI-l Technical Specifications. This surveillance requirement has no corresponding LCO and is formatted in the typical LCO format, These items are addressed in licensee controlled documents.

This proposed amendment incorporates relaxation of selected timeclocks and surveillance j

frequencies consistent with NUREG 1430 and adds a timeclock to a unique LCO. The proposed changes do not modify the operation, limits or controls of systems, structures or components relied upon to prevent or mitigate the consequences or accidents previously evaluated. Also, the reliability of systems and components relied upon to prevent or mitigate the consequences of accidents previously evaluated is not degraded by the proposed changes. Therefore, this change does not involve a significant increase in the probability of occurrence or the consequences of an accident previously evaluated.

2. Operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated because no new failure modes are created by the proposed changes.

3. Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety. The proposed amendment does not change any operating limits for reactor operation.

l V.

IMPLEMENTATION It is requested that the amendment authorizing this change become effective within 60 days ofissuance.

1

ML20135D092

Text

Dear Sir:

Subject:

Enclosures:

Background

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