HL-5698, Application for Amends to Licenses DPR-57 & NPF-5,revising TS 2.1.1.2 by Deleting Footnote Which Specifies That SLMCPRs Are for Cycle 18 Only & Deleting TS 5.6.5.b.2

Application for Amends to Licenses DPR-57 & NPF-5,revising TS 2.1.1.2 by Deleting Footnote Which Specifies That SLMCPRs Are for Cycle 18 Only & Deleting TS 5.6.5.b.2

ML20197H508
Person / Time
Site:	Hatch
Issue date:	12/04/1998
From:	Sumner L SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20197H513	List: HL-5698, Application for Amends to Licenses DPR-57 & NPF-5,revising TS 2.1.1.2 by Deleting Footnote Which Specifies That SLMCPRs Are for Cycle 18 Only & Deleting TS 5.6.5.b.2 ML20197H517
References
HL-5698, NUDOCS 9812140123
Download: ML20197H508 (7)

Text

_ _. _ .-.

'. Lswis Sumner Southtrn Nucitar

, Vice President Optrrting Compzny, loc.

Hatch Project Support 40 l.wemess Parkway Post Office Box 1295 Birmingham Alabama 35201 Tel 205.992.7U9 Fax 205.992.0341 December 4, 1998 SOUTHERN L Docket Nos. 50-321 COMPANY

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50-366 HL-5698 U.S. Nuclear Regulatory Commission ATrN: Document Control Desk Washington, D.C. 20555 Edwin 1. IIatch Nuclear Plant Request to Revise Technical Specifications:

Safety Limit Minimum Critical Power Ratios (SLMCPRs)

L-iies and Gentlemen.

In accordance with the provisions of 10 CFR 50.90, as required by 10 CFR 50.59(c)(1), Southern Nuclear Operating Company (SNC) hereby proposes changes to the Plant liatch Unit I and Unit 2 Technical Specifications (TS), Appendix A to Operating Licenses DPR 57 and NPF-5, respectively. This application proposes to change Unit 1 TS Section 2.1.1.2 to delete the footnote which specifies that the SLMCPRs are for Cycle 18 only This application also proposes to delete Unit I and Unit 2 TS section 5.6.5.b.2). Also, Section 5.6.5.b.1) of each TS is being incorporated into Section 5.6.5.b.

Enclosure i provides a description of the proposed changes and an explanation of the basis for each change. Enclosure 2 details the bases for SNC's determination that the proposed changes do not involve a significant hazards consideration. Enclosure 3 provides page change instructions for incorporating the proposed changes. Following Enclosure 3 are the revised Technical Specifications pages. The corresponding marked-up pages follow behind Enclosure 4.

Southern Nuclear Operating Company requests the proposed amendment to be issued and effective \

prior to restart from the Plant flatch Unit I outage currently to begin April 1999.

k Mr. II. L. Sumner, Jr. states he is Vice President of Southern Nuc! car Operating Company and is authorized to execute this oath on behalf of Southern Nuc! car Operating Company, and to the best of his knowledge and belief, the facts set forth in this letter are true.

Respectfully submitted,

&&vv) 1 H. L. Sumner, Jr. ,c ,1g Sworn to andsubscribed btp e me this k day of__/ 1998.

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Nc:ary Public Commission Erpiration Date: 9Wk R lil9 9812140123 981204 PDR ADOCK 05000321 P PDR ,

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U.S. Nuclear Regulatory Comnussion '

Page 2 l

December 4,1998 1

IFUeb y-l l

Enclosures:

1 4

1. Basis for Change Request

2. 10 CFR 50.92 Evaluation j 3. Page Change Instructions l

. 4. Hand-Marked Pages l cc: Southem Nuclear Ooeratina Comoany

Mr. P. H. Wells, Nuclear Plant General Manager l 1

SNC Document Management (R-Type A02.001)  !

l U.S. Nuclear Regulatory Commission. Washington. D.C.

l Mr. L. N. Olshan, Project Manager - Hatch j l

U.S. Nuclear Reculatory Commission. Region II Mr. L. A. Reyes, Regieral Administrator Mr. J. T. Munday, Senior Resident Inspector - Hatch State of Georgia Mr. L. C. Barrett, Commissioner - Department of Natural Resources l

l

. HL-5698

Enclosure 1 Edwin I. Hatch Nuclear Plant Request to Revise Technical Specifications:

Safety Limit Minimum Critical Power Ratios (SLMCPRs) 4 Basis for Change Request Proposed Change 1 SNC requests that the Technical Specifications contained in Appendix A of the Plant Hatch Unit 1 Operating License DPR-57 be revised to delete the footnote in section 2.1.1.2 that ties the Safety Limit Minimum Critical Power Ratio (SLMCP.R) to Cycle 18.

Basis for Pronosed Change i Prior to Hatch-l Cycle 18 the SLMCPR f'r each operating cycle was based on what was thought to be a bounding generic SLMCl>R for the most limiting fuel type in the core. In 1996, however, it was discovered that under certain conditions the generic SLMCPR may not be bounding for all operating cycles. In consultation with the NRC, GE agreed to implement a new methodology for calculating cycle-specific SLMCPRs. The cycle-specific limit appears in the Technical Specifications and is the basis for determining cycle-specific MCPR Operating Limits (OLMCPR) which uppearin the Core Operating Limits Report (COLR). The cycle-specific SLMCPRs are based on explicitly modeling the bundle R-factor distribution and the radial power distribution in the core.

Since the Hatch-1 Cycle 18 SLMCPR was larger than the generic Safety Limit for the limiting fuel type in the core, SNC submitted a request to the NRC to increase the TS value to 1.10 (and 1.12 for single loop operation). As part of their approval, the NRC determined that a footnote should be included in the TS restricting the new SLMCPR to Cycle 18 only. GE has calculated the cycle-specific SLMCPR for Hatch-1 Cycle 19 and determined that it does not increase as a result of the change in either fuel design or core configuration. It is concluded, therefore, that the current TS value remains valid for the next operating cycle and that the only TS change required to implement the new value is a change in the footnote restricting its applicability to Cycle 18.

As an alternative to revising the footnote in Section 2.1.1.2 every cycle, SNC proposes to delete it. This will allow an existing SLMCPR to be used for multiple, successive cycles as long as the value remains bounding for all of those cycles, as determined by cycle-specific calculations. This change obviates the need to expend utility and NRC resources to revise the TS when the SLMCPR does not change. If the TS value is determined to be non-bounding for an operating cycle, it will be revised prior to the startup of that cycle.

IIL-5698 El-1

1

, Enclosure 1 Basis for Change Request )

i l

On the other hand, if a cycle-specific calculation shows that an existing TS value is overly conservative, SNC may revise the TS to decrease the SLMCPR, or not revise the TS and continue to use the existing TS value.

4 Proposed Change 2 SNC requests that the Technical Specifications contained in Appendices A of the Plant IIatch Unit I and 2 Operating Licenses, DPR-57 and NPF-5, respectively, be amended to l delete Section 5.6.5.b.2) ofeach TS. Also, Section 5.6.5.b.1) of each TS is being incorporated into Section 5.6.5.b. )

I i

l Basis for Proposed Chanye 2 l One of the requirements for removing cycle-specific power distribution limits from the Technical Speci0 cations (TS) and putting them in the Core Operating Limits Report l

(COLR) was the inclusion of references in the Technical Specifications to the NRC- '

approved methods used to develop those limits. The NRC-approved Reload Licensing Analysis (RLA) methods for analyzing GE BWR fuel assemblies are described in GESTAR-II which appears as the reference in Section 5.6.5.b.1)in both the Unit I and 2 Technical Specifications. At the time the COLR was approved for Plant Hatch, both units had four of Advanced Nuclear Fuel's Lead Use Assemblies in their cores.

Reference 5.6.5.b.2) was included in the Technical Specifications to reference the NRC- l approved methods used to analyze those assemblies. Since the ANF LUAs have been I permanently discharged from the Unit I and Unit 2 reactors, Section 5.6.5.b.2) no longer describes NRC-approved methods used to analyze fuel in the Hatch reactors. Therefore, this section is being deleted. The remainder of the proposed change involves incorporating the information presently in 5.6.5.b.1) into 5.6.5.b.

IIL-5698 E l-2

Enclosure 2 Edwin I. Ilatch Nuclear Plant Request to Revise Technical Specifications:

Safety Limit Minimum Critical Power Ratios (SLMCPRs) 10 CFR 50.92 Evaluation Proposed Change 1 SNC requests that the Technical Specifications contained in Appendix A of the Plant Hatch I' 'it 1 Operating License DPR-57 be revised to delete the footnote in l

section 2.1.1.2 that ties the Safety Limit Minimum Critical Power Ratio (SLMCPR) to Cycle 18. l 1

l Basis for Proposed Change I l

No Siunificant Hazards Consideration Determmation. .

The change does not involve a significant hazards consideration for the follow.'ng reasons:

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

The footnote in Section 2.1.1.2 of the Hatch-1 Technical Specificat.ons restricts the applicability of the Safety Limit for MCPR (SLMCPR) to Cycle 18 only. By applying the same NRC-approved methods used to calculate the Cycle 18 SLMCPR it has been determined that the current value is bounding for Cycle 19 as well. However, because of the footnote, it can not be applied to Cycle 19 without a Technical l Specifications amendment. In order to eliminate . ire Technical Specifications revisions that do not change the SLMCPRs values, SNC proposes to delete the footaote which ties those values to a specific operating cycle. Removing the footnote does not change the method ofcalculating SLMCPR for other cycles, nor does it eliminate the requirement to revise the Technical Specifications if a different value is used for future cycles. Deletion of the cycle-specific footnote does not change the operation of any plant structure, system or component; therefore, it has no affect on 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 previously evaluated.

Deleting the cycle-specific footnote in Section 2.1.1.2 of the Technical Specifications does not result in any new methods of operating the facility and does not involve any facility modifications. No new initiating events or transients result from this change.

IIL-5698 E2-1

Enclosure 2 10 CFR 50.92 Evaluation Therefore, this proposed change does not create the possibility of a new or ditTerent kind of accident from any previously evaluated.

3.

The proposed amendment does not involve a signi6 cant reduction in a margin of safety.

, The purpose of the SLMCPR in the Technical Speci6 cations is to ensure at least 99.9% of the fuel pins in the core are expected to avoid transition boiling during the worst anticipated operational occurrence (AOO) throughout an operating cycle. The footnote in Section 2.1.1.2 of the llatch-l Technical Speci6 cations is intended to I

ensure the correct SLMCPR is used each cycle. Prior to the Spring of 1996, the Safety Limits had been calculated for each Riel type, independently of operating cycle. '

As long as the limiting fuel type in the core did not change from cycle to cycle, the Safety Limit did not change. It was discovered in 1996, however, that generic SLMCPRs based on fuel type alone may not be bounding for all cycles for all reactors. In respense to this discovery GE committed to evaluating SLMCPRs based on cycle-unique information as a more accurate method of ensuring 99.9% of the fuel pins in the core are expected to avoid transition boiling during AOOs. The new '

methodology, which is now applied each cycle, is based on NRC-approved methods and incorporates implementing procedures that model cycle-specinc parameters. This methodology was used to calculate the Cycle 18 value that is currently in the Technical Speci6 cations. The same procedure was also employed to determine that the Hatch-l Cycle 19 SLMCPR and it was determined the Cycle 19 value is bounded by the Cycle 18 value. Thus, except for the footnote in Section 2.1.1.2, there is no need to revise the Ilatch-l Technical Specifcations in order to ensure the correct SLMCPR is implemented for Cycle 19. As a way of avoiding similar changes in the future, SNC proposes that the footnote be deleted. Since NRC-approved methodology will still be used to determine the cycle-specific SLMCPRs to ensure that ensure 99.9% of the fuel : ,e are expected to avoid transition boiling during AOOs, there will be no reduci i of margin of safety as a result of this change.

Prgposed Change 2 SNC requests that the Technical Speci6 cations contained in Appendices A of the Plant flatch Unit I and 2 Operating Licenses, DPR-57 and NPF 5, respectively, be amended to delete Section 5.6.5.b.2) of each TS and Section 5.6.5.b 1)is being incorporated into Section 3.6.5.b. of each TS.

HL-5698 E2-2

Enclosure 2 10 CFR 50.92 Evaluation 4

Basis for Proposed Change 2 1

No Significant flazards Consideration Determinatiort 1

l The change does not involve a significant hazards consideration for the following reasons:

1

1. The proposed amendment does not involve a significant increase in the probability or  !

consequences of an accident previously evaluated.

l Section 5.6.5.b.2) no longer describes NRC-approved methods for analyzing fuel in the Unit I and Unit 2 reactors because the ANF LUAs have been permanently discharged. Deleting Section 5.6.5.b.2) from the Administrative Controls portion of i

the Technical Specifications does not change the operation of any structure, system, or component in tb facility. Therefore, this amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

l

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

)

l Deleting Section 5.6.5.b.2), which describes the use of ANF methods for analyzing LUAs, from the Technical Specifications does not result in any new methods of operating the facility and does not involve any facility modifications. No new initiating events or transients result from this change. Therefore, this proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

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

ANF LUAs are no longer used as fuelin the Plant flatch reactors, therefore, ANF NRC-approved methods described in Technical Specifications Section 5.6.5.b.2) are not used to determine power distribution limits which appear in the COLIL GE's reload licensing methodology described in Section 5.6.5.b.1) will be incorporated into Section 5.6.5.b. and will continue to be used to analyze the GE fuel in both units.

Therefore, this change does not involve a significant reduction in the margin of safety.

IIL-5698 E2-3

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