ML20012E011

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Application for Amends to Licenses NPF-68 & NPF-81,revising Tech Specs to Remove Limits Associated W/Reactor Physics Parameters from Tech Specs & Place in Separate Core Operating Limits Rept
ML20012E011
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 03/22/1990
From: Hairston W
GEORGIA POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20012E012 List:
References
ELV-01266, ELV-1266, GL-88-16, NUDOCS 9003290212
Download: ML20012E011 (12)
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, : Geo'D ai Power company .

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i DGWJ f Adanta, George 30308:

g - Telepho.ne 404 526 3195 -

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. 40 inverness Center Parkway -

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Post Office Box 1295.

Birmingham, Alabama 35201' Telephone 205 868-5581-March 22, 1990 U"' 5St*" t*a4*m 1 W. o. Haltston, Ill

. Sorwor Vce President -

Nuclear Operabons -

ELV-01266-0211 4 Docket Nos. 50-424 50-425 U. S. Nuclear Regulatory Commission

-ATTN: Document Control Desk

(' Washington,= D. C. 20555:

Gentlemen:-

h 1 V0GTLE ELECTRIC GENERATING PLANT u REVISION TO TECHNICAL SPECIFICATIONS

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G RE OPERATING LIMITS REPORT

['L, In:accordance with provisions of 10 CFR 50.90 and 10 CFR 50.59 Georgia Power Company (GPC) proposes to amend the Vogtle Electric Generating Plant (VEGP)

Units 1 and 2 Technical Specifications, Appendix A to Operating Licenses NPF-68 and.NPF-81. .The Technical Specifications for which changes are requested K involve limits associated with reactor physics parameters that may change for 1 each fuel cycle. This amendment will remove such cycle specific limits from'the Technical S)ecifications and place them in-a separate Core Operating Limits Report whict will be defined in the Technical Specifications. ' This alternative l: sto modifying the' individual Technical Specifications for each core reload is responsive to industry and NRC efforts to improve Technical Specifications, as L described in NRC Generic Letter 88-16.

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, Enclosure 1 provides a detailed description of the proposed. changes and the l basis for the change request.

k Enclosure 2 provides.the basis for a determination that the proposed changes do-not involve.significant hazards considerations.

Enclosure 3 provides instructions for incorporating the proposed changes into the Technical Specifications. The proposed revised pages for the combined VEGP

. Units 1 and 2 Technical Specifications ~are provided in Enclosure 3.

b Enclosure 4 includes sample Core Operating Limits Reports for VEGP Units 1 and 2 L ,

-based on the current operating cycle for Unit 2 and Cycle 3 for Unit 1.  !

In;accordance with 10 CFR 50.91, the designated state official will be sent a copy'of this letter and all enclosures.

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I~ U. S.= Nuclear Regulatory Commission i ELV-01266- j Paae Two l l Mr. W. 'G. Hairston,-III states that he is a Senior Vice President of Georgia i Power _ Company ~and_ is authorized to execute this oath on' behalf of Georgia Power l Company and that, to-the best-of his knowledge and belief, the facts set forth - ,l in this letter'and enclosures are true.

1 GEORGIA POWER COMPANY I 1

By: I h-W. G. Hairston, Ill .

SworntoandsubscribedbeforemethisANdayof "Ola u [ , 1990, t its s01,Y o '

Notary (fublic JuCERON fMRESom 15,1992 I

'WGH,III/HWM/gm -l 4

1' Enclosures.

L 1. Basis for Proposed Change

2. 10 CFR 50.92 Evaluation
3. Instructions for' Incorporation and Revised Pages

-4. Sample Core Operating Limits Report for Unit I and Unit 2 ,

c(w): Georaia Power Comoany Mr. C. K. McCoy . ,

Mr. G. Bockhold, Jr. l Mr. P. D. Rushton

.Mr. R.-M.-Odom NORMS Southern Company Services Inc. 1 Mr. L. B. Long I 1

L U. S. Nuclear Reaulatory Commission J l: Mr. S. D. Ebneter, Regional Administrator l Mr. T. A; Reed, Licensing Project Manager, NRR Mr. R. F. Aiello, Senior Resident Inspector ,

1 State of Georaia _

Mr. J. L. Ledbetter, Commissioner, Department of Natural Resources

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ENCLOSURE 1 I'

V0GTLE ELECTRIC GENERATING PLANT REQUEST FOR TECHNICAL SPECIFICATIONS CHANGE l

CORE OPERATING LIMITS REPORT BASIS FOR PROPOSED CHANGE ProDosed Chanaes These changes to the Technical Specifications relocate certain core operating-  !

. limits to a separate report, called the Core Operating Limits Report (COLR). .The necessary changes to the Technical Specifications are administrative in nature J and involve making the appropriate references to the COLR, adding the definition i of the COLR and revising-section 6 of the Technical Specifications to describe ,

L the administrative controls that apply to the COLR. The proposed. changes are l described below:-

1. Revisions to the Index )

1 The index is revised to indicate the addition of _the definition of the COLR j and the removal of the required shutdown margin curves (Figures 3.1-la l through 3.1-2b), the rod bank insertion limit curve (Figure 3.1-3), the .j axial flux difference limits (Figure 3.2-1) and the normalized FQ(Z) as a .1 function'of core height (Figure 3.2-2). The index entry for the Radial l

i. Peaking Factor Limit Report is changed to Core Operating Limits Report. In cases where a figure deletion can be done without affecting the page i numbering sequence it is deleted completely, where it-affects the page l- numbering sequence the figure is noted as deleted.
2. Section 1.10 definitions The definition of COLR is added as definition 1.10, the other definitions are renumbered accordingly.
3. Specification 3/4.1.1.1-l-

l This-specification is revised by removing the SHUTDOWN MARGIN limit for MODES 1 and 2 and replacing it with a reference to the COLR.

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4. Specification 3/4.1.1.2 l This specification is revised by removing the SHUTDOWN MARGIN limit for L MODES 3, 4 and 5 and replacing it with a reference to the COLR, this includes removing Figures 3.1-la, 3.1-lb, 3.1-2a and 3.1-2b.

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y n ENCLOSURE 1 (CONT'D)

!- REQUEST FOR TECHNICAL SPECIFICATIONS CHANGE i CORE OPERATING LIMITS REPORT  :

BASIS FOR PROPOSED CHANGE .

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5. Specification 3/4.1.1.3 i This_ specification is revised by adding a reference to the COLR for the

'Beginning of Cycle Life and End of Cycle Life Moderator Temperature Coefficient-(MTC)= limits. The 300 ppm surveillance limit is also placed in.

the COLR. The maximum allowable MTC will remain in the ' specification.

L 6. Specification 3.1.3.1 ,

t l The ACTION statement for this specification refers to Figure 3.1-3. This .

i figure is also being removed from the Technical Specifications and placed in-  :

the COLR. Therefore, the reference to Figure 3.1-3 is replaced with_a .

L reference to Specification 3.1.3.6.

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7. Specification 3/4.1.3.5.

i The Shutdown Rod insertion limit is replaced with a reference to the limit: ,

l in the COLR.

8. Specification 3.1.3.6 r 3 ~

The control rod insertion limits are replaced with a reference to the limits in the COLR. This includes removing Figure 3.1-3 from the Technical Specifications and placing it in the COLR.

9. Specification 3/4.2.1 The value of the AXIAL FLUX DIFFERENCE (AFD) target band and Acceptable Operation limits for AFD are removed from the Technical Specifications and replaced with a reference to the COLR. This includes removing Figure 3.2-1 from the Technical Specifications.

.10. Specification 3/4.2.2 The F0 limit function at RATED of core height THERMAL are replacedPOWER (RTP) and by references theCOLR.

to the normalized Fg (ThisZ) as a includes removing Figure 3.2-2 from the Technical Specifications. The value of the Power Factor Multiplier for Fxy is also removed from the Technical Specifications surveillance requirement and placed in the COLR. The' reference to the Radial Peaking Factor Limit Report, contained in Specification 4.2.2.2.e is also replaced by a reference to the COLR.

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ENCLOSURE 1 (CONT'D)

' REQUEST FOR TECHNICAL SPECIFICATIONS CHANGE CORE OPERATING LIMITS REPORT BASIS FOR PROPOSED CHANGE

11. Specification 3.2.3 The values of. the' Nuclear Enthalpy Rise Hot Channel Factor at RTP and its associated Power Factor Multiplier are removed from the Technical Specifications. and placed in the COLR.
12. Bases 3/4.1.1.1 and 3/4.1.1.2 This section is revised to indicate that required SHUTDOWN MARGIN is -l provided in the COLR.
13. Bases 3/4.1.1.3 i This section is revised by removing references to specific MTC values.
14. Bases 3/4.2.1 This section-is revised by deleting the reference to a specific Fg value and '  !

noting that it is specified in the COLR. The phrase "the normalized axial -;

peaking factor" is replaced by "K(z)" which provides a more accurate description of the F (Z)

Q upper bound envelope. The reference to Figure 3.2-1 is also replaced by a reference to the COLR.  :

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15. Bases 3/4.2.2 and 3/4.2.3  ;

This section is revised by referring to the COLR for the location of the '

value of Fxy for RTP instead of referring to the Radial Peaking Factor Limit Report

16. Specification 6.8.1.6 l p

l: The description of the Radial Peaking Factor Limit Report administrative  !

I requirements-is. replaced by a description of the administrative requirements l for the COLR.  !

These Technical Specification revisions are attached with Enclosure 3.

Basis The reactor physics parameters for each reload cycle differ depending on such variables as the previous cycle burnup, number and enrichment of fuel assemblies, and expected cycle length or energy. In addition, the practice of placing these cycle specific parameters in the Technical Specifications has resulted in cycle designs that were based on design restrictions that avoided changes to the Technical Specifications. In Generic Letter 88-16 the NRC provided guidance for removal of cycle specific reactor physics parameters that are calculated using NRC approved methodology from the Technical Specifications.

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ENCLOSURE l'(CONT'D) J

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L REQUEST FOR TECHNICAL SPECIFICATIONS CHANGE l

CORE OPERATING LIMITS REPORT ]

BASIS FOR PROPOSED CHANGE

-Basis-(cont'd)

The generic letter provides. for removal of these parameters by placing them in a '

Core Operating Limits Report (COLR) that would be submitted to the NRC following any change in the reactor physics parameters. This is similar to the manner in  :

which the Radial Peaking Factor Limit Report is currently being su) plied to the NRC. The COLR will include the same information as the Radial Pea (ing Factor Limit Report as well as additional cycle specific reactor physics parameters that are calculated according to the NRC approved methods. ,

This proposed revision to the Technical Specifications is administrative in nature since it does not change any of the limits or surveillance requirements.

It provides additional flexibility for core design, in that it allows changes of the parameters to be made consistent with the burnup and energy constraints of the cycle without requiring a License Amendment, yet it assures that the NRC is informed of the reactor physics parameters that are being-used. The changes to the Technical-Specifications are included in Enclosure 3. Enclosure 2 is an evaluation in accordance with 10 CFR 50.92 to demonstrate that these changes to the Technical Specifications do not involve any significant hazards l considerations. - A Core Operating Limits-Report for Cycle 3 of Unit I and l Cycle 1 of Unit 2 is included as Enclosure 4.

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k ENCLOSURE 2

. V0GTLE ELECTRIC GENERATING PLANT REQUEST FOR TECHNICAL SPECIFICATIONS CHANGE  :

CORE OPERATING LIMITS REPORT i

10 CFR 50.92 EVALUATION q Backaround 1

Generic Letter 88-16, dated October 4,1988, was issued to encourage licensees 1 to prepare changes to Technical Specifications related to cycle-specific parameters. These Technical Specification changes will relocate cycle-specific parameter limits from Technical Specifications to the Core Operating Limits Report:(COLR). Presently-the parameter limits in the Vogtle Electric Generating Plant'(VEGP) Technical Specifications are calculated using NRC-approved methodologies. These limits are evaluated for every reload cycle and may be u revised periodically as appropriate to reflect changes to cycle-specific '

variables. This is an administrative burden on both the NRC and Georgia Power Company (GPC).

The generic letter provided guidance for relocation of certain cycle-dependent core operating limits from the VEGP Technical Specifications. This would allow .

changes to the values of core operating limits without prior approval (i.e.,

license amendment) by the NRC, so long as NRC-approved methodologies for the parameter limit calculations are followed. Revisions _to core operating limits due to'the VEGP core reloads or other changes would involve a safety review in accordance with the requirements of 10 CFR 50.59.

L I- The revised Administrative Controls Section of this license amendment request l identifies the methodology used to determine each parameter limit proposed for

-inclusion in the COLR. These methodologies are currently used to calculate the limits for each VEGP core reload design or, when any other revisions-are made L

that affect these core operating limits.

Proposed Chanae The proposed technical specification changes concern the relocation of several i cycle-specific core operating limits for VEGP from Technical Specifications to E the COLR. A new definition of the COLR will be added to the Technical Specifications. Additionally, certain individual . Technical Specifications will be modified to note that cycle-specific parameter limits are contained in the COLR. A COLR paragraph will be added to the Administrative Controls Section 6.8.1.6 of the Technical' Specifications hich will replace the Radial Peaking Factor Limit Report. The proposed COLR also provided. Future reports, or report revisions, will be provided to NRC upon issuance, to allow continued trending of the cycle-specific param. , by the NRC.

s; ENCLOSURE 2.(CONT'D)

REQUEST FOR TECHNICAL SPECIFICATIONS CHANGE CORE OPERATING LIMITS REPORT i

10 CFR 50.92 EVALUATION Proposed Chanae (continuel)..

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The proposed changes will reference the:COLR for specific parameters and will ensure that cycle-specific parameters are maintained within the limits of the COLR. The cycle-specific parameter limits proposed ~ for relocation ~ to the COLR as part of this-license amendment request include:

(a) 3.1.1.1 SHUTDOWN MARGIN for MODES I and 2 (b) 3.1.1.2 SHUTDOWN MARGIN for MODES 3, 4 and 5 '

(c) 3.1.1.3 Moderator. Temperature Coefficient .

(d) 3.1.3.5 Shutdown Rod Insertion Limits (e) 3.1.3.6 Control Rod Insertion Limits (f) 3.2.1 Axial Flux Difference (g) 3.2.2 Heat Flux Hot Channel Factor (h) 3.2.3 Nuclear Enthalpy Rise Hot Channel Factor The proposed changes are consistent with the requirements of 10 CFR 50.36 and the staff's proposed policy for improving Technical Specifications, delineated in SECY-86-10, " Recommendations for improving TS." The policy allows process variables such as core operational limits to be controlled by specifying them ,

numerically in the Technical Specifications or by specifying the method of calculating their numerical values, if the staff finds that the correct limits will be followed in operating the plant. The proposed revision references the NRC-approved calculation methodologies. The development of cycle-specific core operating limits will continue to be performed by the referenced methodologies which have been accepted by the NRC.

'The proposed changes to the Technical Specifications are considered to be improvements and are consistent with the NRC stated policy for improving L

Technical Specifications (52 FR 3788, February 6, 1987).

Safety Evaluation The current Technical Specification method of controlling reactor physics parameters to assure conformance to 10 CFR 50.36 (which requires the lowest functional performance levels acceptable for continued safe operation) is to specify the values determined to be within the acceptance criteria using an NRC-approved calculation methodology. As previously discussed, the methodologies for calculating these parameter limits have been reviewed and approved by the NRC and are consistent with the applicable analyses presented in the Final Safety Analysis Report (FSAR).

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i ENCLOSURE 2 (CONT'D)

REQUEST FOR TECHNICAL SPECIFICATIONS CHANGE CORE OPERATING LIMITS REPORT 10 CFR 50.92 EVALUATION Safety Evaluation (continued)

The removal'of cycle dependent variables from the Technical Specifications has no impact upon plant operation or safety. No safety-related equipment, safety

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function, or plant operations will be altered as a result of this proposed change. Since the applicable FSAR limits will be maintained and the Technical Specifications will continue to require operation within the core operational

. limits calculated by these NRC-approved methodologies, this proposed change is administrative in nature. Appropriate actions to be taken if limits are-violated will also remain in the Technical Specifications.

. This proposed change will control the cycle-specific parameters within the acceptance criteria and assure conformance to 10 CFR 50.36 by using the approved methodology instead of specifying Technical Specification values. The COLR will ,

document the. specific parameter limits resulting from GPC calculations, including mid-cycle or other revisions to parameter values. Therefore, the proposed change is in conformance with the requirements of 10 CFR'50.36.

Any changes to the COLR will be made in accordance with the provisions of 10 CFR 50.59. From cycle to cycle, the COLR will be revised such that the appropriate core operating limits for the applicable cycle will apply. Technical

- Specifications will not be changed.

Determination of Sianificant Hazards Pursuant to 10 CFR 50.91 GPC has determined that operation of the facility in .

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accordance with the proposed license amendment request does not involve any significant hazards considerations as defined by NRC regulations in 10 CFR 50.92. The following discussion describes how the proposed amendment satisfies l

each of the three standards of 10 CFR 50.92(c),

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

The removal of cycle-specific core operating limits from the VEGP -

Technical Specifications has no influence or impact on the probability or consequences of a Design Basis Accident (DBA) occurrence. The cycle-specific core operating limits, although not in Technical Specifications, will be followed in the operation of the VEGP. The proposed amendment still requires the same actions be taken when or if limits are exceeded as required by current Technical p Specifications.

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a ENCLOSURE 2 (CONT'D)

REQUEST FOR TECHNICAL SPECIFICATIONS CHANGE-CORE OPERATING LIMITS REPORT 10 CFR 50.92 EVALUATION l Each accident-analysis addressed in the VEGP Final Safety Analysis  :

Report (FSAR) will be examined with respect to changes-in cycle-dependent parameters, which are obtained from application of the -

NRC-approved reload design methodologies,.to ensure that the transient evaluation.of.new reloads are bounded by previously accepted analyses.

  • This examination, which will be performed per requirements of 10 CFR 50.59, ensures that future reloads will not involve a significant  ;

increase in the probability or consequences of an accident previously evaluated.

2)- The proposed change does not create the possibility of a new or -

different kind of accident from any accident previously evaluated.

l As stated earlier, the removal of the cycle specific variables has no influence or impact, nor does it contribute in any way to the probability or consequences of an accident. No safety-related

  • equipment, safety function, or plant operation will be altered as-a result of this proposed change. The cycle specific variables are calculated using the NRC-approved methods and submitted- to the NRC to .

allow the Staff to continue to trend the values of these limits. The Technical Specifications will continue to require operation within the u required core operating limits and appropriate actions will be taken L

when or if limits are exceeded. .

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

l. 3)' The proposed amendment does not result in a significant reduction in l the margin of safety.

The margin of safety is not affected by the removal of cycle-specific core operating limits from the Technical Specifications. The margin of safety presently provided by current Technical Specifications remains unchanged. Appropriate measures exist to control the values of these cycle-specific limits. The proposed amendment continues to require operation'within the core limits, as obtained from the

. NRC-approved reload design methodologies. The required actions to be taken when or if limits are violated remain unchanged.

The development of the limits for future reloads will continue to conform to those methods described in NRC-approved documentation. In addition, each future reload involves a 10 CFR 50.59 safety review to assure that operation of the unit within the cycle-specific limits will not involve a significant reduction in margin of safety.

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. ENCLOSURE 2-(CONT'D)-.

REQUEST FOR TECHNICAL SPECIFICATIONS CHANGE j CORE OPERATING LIMITS REPORT j 10 CFR 50.92 EVALUATION Therefore, the proposed changes are administrative in nature and do not impact the operation of VEGP in a manner that involves a reduction to the margin of safety.

Conclusion The Commission has provided guidance concerning the application of the standards _ ,f l: for determining whether a significant hazards consideration exists. This L: guidance (51 FR 7750) includes examples of the type of amendments that are L- considered not likely to involve significant ha7ards considerations. The proposed change is similar to the examples of atministrative' changes ' identified

.in 51 FR 7750. Additionally, the proposed change is consistent with the NRC policy for improving technical specifications (52 FR 3788) and the proposed change is consistent with 10 CFR 50.36 and 10 CFR 50.59.

In view of the preceding, GPC has determined-that the proposed license amendment

.does not involve any significant hazards considerations.

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ENCLOSURE 3 <

V0GTLE ELECTRIC GENERATING PLANT ,

REQUEST FOR TECHNICAL SPECIFICATIONS CHANGE CORE OPERATING LIMITS REPORT INSTRUCTIONS FOR INCORPORATION-

,g The proposed amendment to the Technical Specifications would be incorporated as follows:

Remove Paae Insert Paae I and.II I and II III* and IV III and IV V and VI* V and VI XXIII and XXIV

  • XXIII and XXIV 1-1*'and 1-2 1-1 and 1-2 .l 1-3 and'l-4 1-3 and 1-4 l 1-5 and 1-6 1-5 and 1-6 1-7 and 1-8*- 1-7 and 1-8 1 3/4 1-1 and 3/4 1-2* 3/4 1-1-and 3/4 1-2 l 3/4 1-3-and 3/4 1-3a 1 3/4 1-3b and 3/4 1-3c d 3/4 1-3d and 3/4 1-4 3/4 1-3 and 3/4 1-4 3/4 1-5 and 3/4 1-6* 3/4 1-5 and 3/4 1-6 3/4 1-13* and 3/4 1-14 3/4 1-13 and 3/4 1-14 3/4 1-15 and 3/4 1-16* 3/4 1-15 and 3/4 1-16 3/4 1-19* and 3/4 1-20 3/4 1-19 and 3/4 1-20 3/4 1-21 and 3/4 1-22 3/4 1-21

. 3/4 2-1 and 3/4 2-2 3/4 2-1 and 3/4 2-2 3/4 2-3 and-3/4 2-4 3/4 2-3 and 3/4 2-4 r 3/4 2-5 and 3/4 2-6 3/4-2-5 and 3/4 2 3/4 2-7 and 3/4 2-8 3/4 2-7 and 3/4 2-8 B.3/4 1-1 and B 3/4 1-2 B 3/4 1-1 and B 3/4 1-2 B 3/4 2-1 and B 3/4 2-2 B 3/4 2-1 and B 3/4 2-2 B 3/4 2-5 and B 3/4 2-6* .B 3/4 2-5 and B-3/4 2-6 6-21 and 6-22* 6-21 and 6-21a 6-22

  • Overleaf page containing no change.

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