ML20080P352
| ML20080P352 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 02/06/1984 |
| From: | Beckham J GEORGIA POWER CO. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19292C282 | List: |
| References | |
| NED-84-030, NED-84-30, TAC-54432, TAC-54433, TAC-54607, NUDOCS 8402220514 | |
| Download: ML20080P352 (15) | |
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NED-84-030 February 6, 1984 Director Nuclear Reactor Regulation Attn: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 Division of Licensing U. S. Nuclear Regulatory Canission Washington, D.C. 20555 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DFR-57, NPF-5 EDNIN I. HA'ICH NUCLEAR PLANT UNITS 1, 2 REQUEST 'IO CHANGE TECHNICAL SPECIFICATIONS APW/RBM/ TEX'H SPEC IMPROVMEtTTS
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e In accordance with the provisions of 10 CER 50.90 as rquired by the provisions of 10 CFR 50.59 (c) :1), Georgia Power Cmpany (GPC) hereby g
proposes mendments to the Edwin I.
Hatch Units 1 and 2 Technical p
Specifications (Appendix A to each Operating License). These changes would 6
imp 1 ment the Average Power Range Monitor, Rod Block Monitor, and Technical Y
Specification (ARTS) Improvment Progrm, add the Extended Ioad Line Limit &k
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_ Analysis (FTHA) for power-map extension at Plant 'llatch.
B sed iin Nuclear g4
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u Regulatory Cmmission (NRC) approvals, we are planning to install these d
proposed changes on Unit 2 during the current outage and consquently, 3
request NRC review to support this schedule.
By this letter, we also rquest a meeting at a date as soon as is mutually agreeable to discuss 4
these proposed changes with the NRC staff in order to facilitate the review process.
4.
'Ihe IRTS Improvment Progra includes changes to the Average Power Range gy Monitor (APRM) scrm and rod block trip parmeters, changes to the Rod Block 4
l Monitor (RBM) hardware and trip logic, and modifications of the Technical
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Specifications to adquately implement tl:ese changes at Plant Hatch.
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primary goals are to:
M 1.
Replace the APFM scra and rod block trip setdown rquirments with more
%Nd d meaningful limits to reduce the need for manual setpoint adjustments and 43yY to allow more direct thermal limits administration; 2.
Change the RBM hardware using state-of-the-art electronics, including:
(a) reassigment of Incal Power Range Monitor (LPPM) inputs to the RBM 4
to improve response of the RBM; and (b) revision of the RBM trip logic and signal normalization procedures to improve its man / machine interface increasing the accessible region of operation above the rated load line, g&'
to conform with analyses of operational transients initiated frm q-off-rated conditions; 8402220514 840206 PDR ADOCK 03000321 P
FDR l
Georgia Power d Director of Ntx: lear Reactor Regulation Washington, D.C.
February 6, 1984 Page two 3.
Introduce new rquirments for flow and power dependent MCPR and MAPLHGR operating limits, to support elimination of the APIE setdown requirment and to be consistent with the new RBM power dependent trip setpoints.
%e requirments necessary for partial or emplete bypass of the RBM are clarified; and 4.
Modify the Technical Specifications in order to adquately imp 1 ment the above changes.
%e analyses which justify these changes and which determine instrment setpoints and operating limits consistent with their impleentation are discussed in more detail in NEDC-30474-P (includal in Attactnent 3) and its supporting references.
%ese include transient analyses, rod withdrawal error analyses, and loss-of-coolant accident (LOCA) analyses.
%e Extended Ioad Line Limit Analysis (FUJA) perfomed by General Electric is intended to justify expansion of the operating region of the e
power / flow map frm that currently used to that shown in Figure 1-1 of NEDC-30260 (included in Attachment 3).
The analysis provides justification for changing the APEM flow-biased rod block setpoint.
Both the Plant Review Board and the Safety Review Board have evaluated these proposed Technical Specification changes and have determined that the imp 1 mentation of these proposed changes would not constitute an unreviewed safety question.
%e probability of occurrence or the consequences of an accident or malfunction of safety related quipnent would not be increased above those analyzed in the FSARs.
%e probability of occurrence of each event evaluated in the FSARs would be unaffected by operation of either reactor in the region of the power / flow map made accessible by changing the APFM rod-block line parameters.
Furthermore, no new causes that could lead to occurrence of the FSAR events could be identified, due to use of the expanded operating region.
Changes in the RBM design will improve RBM reliability and enhance operator interface with the RBM, reducing the probability of a rod withdrawal error event due to operator error.
Information presented in NEDC 30474-P shows that the consquences of accidents and transient events which might be affected by implmentation of the ARTS program are bounded by the consequences of the sme events initiated frm current licensing basis conditions, provided the appropriate adjustments to the operating limits and REM setpoints are utilized.
%e proposed Technical Specification changes will assure that needed adjustments are made.
Georgia Power d Dire.ctor of Nuclear Reactor Regulation Washington, D. C.
Feb m ary 6, 1984 Page three ne possibility of an accidsit or malfunction of a different type than analyzed in the FSARs does not result from this change. Neither the maximum core power (2436 MW) nor the maximum core flow rate will be increased by ARTS.
%e maximum core power level at a given care flow rate will rmain constrained by the flow-biased APPM rod block and by the flow-biosed thermal Power Monitor Scrm.
No new failure modes are introduced by the proposed changes in the setpoints for this instrumentation or by the design changes to the RBM.
%e margins of safety as defined in the Technical Specifications is not reduced.
Analyses performed to support elimination of the APPM setdown rquirment and changing the APPM trip parmeters were done with methods previously approved by the NRC.
%e acceptance criteria used in the ARTS Progrm for defining the off-rated MCPR and APLHGR rquirments and the power-biased PEM setpoints were the sme criteria defined for fuel-rod integrity in the original licensing basis.
There is no reduction in the margins of safety because all acceptance criteria are met under the new e
systs.
Included with this proposal is a determination of amendment class (Attachtent 1). We have determined this to be a Class IV anendment for one unit and e Class I for the other, and hsve enclosed the appropriate payment.
Instructions for incorporation of these changes along with copies of the affectal Technical Specifications pages are encloscd (Attachnent 3).
Attachnent 3 is organized so that the changes to each unit are addressed separately.
Please note tnat sane information has been marked as
" proprietary" in order to protect the camercial interests of the NSSS vv=v%.
In accordance with 10 CFR 2.790, an affidavit is included in Attachnent 3 which rquests that certain information be withheld fran the public domain.
Finally. the supporting docunents, NEDC 30474-P and NEDC 30260, are included in Attachment 3.
As required by 10 CFR 50.92, a basis for each proposed Technical Specification change is enclosed with this subnittal as Attachment 2.
Pursuant to the rquirments of 10 CFR 50.92, J.
L. Ledbetter of the Georgia Department of Natural Resources will be sent a copy of this letter ar.d all applicable attachnents, l
l 700775
Georgia Power 1 Director of Nuclear Reactor Regulation Washington, D. C.
February 6, 1984 Page four J. T. Beckhm, Jr. states that he is Vice President of Georgia Power Cmpany and is authorized to execute this oath on behalf of Georgia Power Cmpany, and that to the best of his knowledge and belief the facts set forth in this letter are trua.
GEORGIA POhTR CmPANY By:
(~
J.
'. Beckhm, Jr. #
Sworn to and subscribed before me this 6th day of February,1984.
- Aw f w#-
Notary Public, Cdrgia. Stata at (Targ, Notary Public S
My Cornmamn Emacs Aug.26,1986 DLT/tm Enclosure xc:
H. C. Nix, Jr.
Senior Resident Inspector J. P. O'Reilly, (NRC-Region II)
J. L. Ledbetter 700775
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Georgia Power d A'ITAONDIT 1 hRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, hTF-5 EDRIN I. HA'ICH NUCIIAR PIANT UNITS 1, 2 REOUEST 'IO OIANGE TDCHNICAL SPECIFICATIONS APFM/RW/1ECH SPEC IMPPOVEMENTS Pursuant to 10 CFR 170.12 (c), Georgia Power Cmoany has evaluated the attached proposed mendments to Operating Licenses DPR-57 and NPF-5 and has determined that:
a)
The proposed amen &ents to not rquire the evaluation of a new Safety Analysis Report or rearite of the facility license; b)
The proposed men &ents to not contain several cmplex issues, does not involve ACRS review, and does not rq uire an enviromental impact statcrnent; c)
The proposed mentents do involve a cmplex issue which results in several changes of the Class III type; d)
The proposed mendments result in a Class IV amendment for one unit and a Class I m endment for the other unit.
Georgia Power d ATTACINENT 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HA'ICH NUCLEAR PIAVI UNI 7S 1, 2 REQUEST 'IO CHANGE TECHNICAL SPECIFICATIONS APhM/RBM/ TECH SPEC IMPROVEMENTS Pursuant to 10 CFR 50.92, the following statments provide a sumary of and the basis for the proposed changes:
1.
Change the slope of the flow-biased Average Power Range Monitor / Simulated Thermal Power Monitor (APFM/ STIM) scrm and rod block setpoints frcra 0.66 to 0.58 an:' change their intercept values such that, at rated core flow, the setpoints are unchanged frm their current values.
BASIS:
The Extended Load Lipe Limit Analyses (ELLIA) provide the analytical bases for raising the APTM scrm and rod block lines at the bottm of 9
the flow control range by reducing the flow biasing slopes frm 0.66 to 0.58.
Analyses have shown that the consequences of events initiated frm within the region of the Power-Flow operating map, made accessable by this change, are bounded by the consquences of the see events initiated frm the licensing basis condition.
Adjusting the zero-drive-flow intercept values as indicated assures that the rated-flow setpoints maintain the margins existing under current analyses. This proposed change therefore has no adverse effects on the probability or consequences of previously postulated accidents.
Because no physical change is rquired to operate in the ELIA, the proposed changa does not create the possibility of a new, previously unanalyzed accident. As stated above, because the consquences of events initiated within the ELLIA region are bounded by the consequence 7 of the sme events initiated frm licensing basis conditions, margins of safety are not affected, t
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% eorgiaPower1 G
Attachtent 2 page 2 2.
The ARTS improvments have been divided into five areas of changes. %e changes have been analyzed collectively and the results reported in IEDC-30474-P, " General Electric BWR Licensing Report: Average Power Range Monitor, Rod Block Monitor and Technical Specification Improvment (ARTS) Program For Edwin I. Hatch Nuclear Plant, Units 1 and 2."
These changes taken together pose no adverse effects on the probability or consquences of previously postulated accidents, does not create any type of unanalyzed accident and does not affect the margin of safety. A specific discussion of each proposed change is addressed below.
A. Delete the requirment for setdown of the APFM/STm flow-biased scrm and rod block setpoints, when fraction of core rated thermal power exceeds the core maximum fraction of limiting power density (MFLPD).
BASIS:
This change deletes the APM scrm and rod block trip setdown requirments and replaces the with more meaningful limits to reduce the need for manual setpoint adjustments and to allow more direct themal limits administration.
%is rquirment originated frm the obsolete Hench-Levy Minimm Critical Heat Flux Ratio (MCHFR) thermal limit criterion.
%e change to TrAB/GEXL with its de-sphasis of local thermal-hydraulic conditions and the move to secondary reliance on flux scram for licensing transient evaluations (for transients terminated by anticipatory or direct scram) has provided more effective and operationally acceptable alternatives to the setdown requirment.
We ARTS progra uses transient analyses to define themal operating ifmits which conservatively assure that all licensing criteria are satisfied without setdown of the APFM scrm and flow biased rod block trips.
All operating limit restrictions rquired to support elimination of the cetdown rquirments are incorporated into the Technical Specifications by changes identified under itms C and E below.
B. Replace the Rod Block Monitor (RBM) flow-biased trip equation with power-dependent setpoint definitions, incorporate RBM filter and time delay setpoints, and change the PIM downscale trip setpoint.
70C775
Georgia Power d Attactrnent 2 page 3 BASIS:
Revision of the RBM trip logic provides a systs response which more accurately reflects the actual margin to the safety limit at various power conditions.
An exhaustive, generic Rod Withdrawal Error (RWE) analysis was performed to evaluate the upgraded RBM systs.
It was shown that all rquirments for prevention of cladding failure during an RWE are met, if the logic setpoints, filter setpoints, time delays and downscale trips defined in this
- change, and the power-dependent Minim m Critical Power Ratio (MCPRp) operating limit adjustment, defined in Its C belov, are implmented.
C. Define a new power-dependent Minimm Critical Power Ratio (MCPRp) specification, define a new flow-dependent Minimum Critical Power Ratio (MCPC,g) specification to replace the current multiplier, Kp, and defire the governing MCPR limit for any power and flow condition.
BASIS:
As part of the justification for reoval of the APFM setdown 9
rs,"irment, it is necessary to define the operating limit MCPR (OIMCPR) such that no postulated transient events initiated frm other than rated power or rated flow conditions may result in violation of the MCPR Safety Limit.
Analyses of the limiting transients have shown that the power-dependent multiplier (Kp) to the rated-power, rated flow operating limit MCPR conservatively bounds the initial MCPR needed to meet GETAB requirments.
The flow-dependent MCPR requirment, MCPRp, was derived frm results of analysis of slow-flow runout events and, thus, serves the see purpose as the Kg multipliers which it replaces.
No MCPRp is rquired for Autmatic Flow Control, because that mode of operation vill not be used. % e governin9 MCPR limit for any power and flow condition is the greater of the values determined based on core power considerations (MCPRp) os core flow considerations (MCPRp).
%e power-dependent MCPR requirment is also consistent with the definition of the Rod-Blcck Monitor setpoints and the generic Rod Withdrawal Error analysis defined in Its B above.
D.
Add new kod Block Monitor (RBM) operability and surveillance requirments, including the definition vf Limiting Rod Pattern for Rod Withdrawal Error (RhT).
e 700775
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Georgia Power 1 page 4 PASIS:
The generic RWE analysis performed for ARTS was used to determine the pre-RWE MCPR margin that would assure that the cmplete withdrawal of any single control rod would not violate the Safety Limit.
his change defines the limiting core MCPR values which assure that the existing RIN systs design bases are met. Whenever the operating MCPR is above the limiting values, cmplete REM bypass is justified.
Analyses also justify cmplete bypass of the RBM systs below 30%
of rated thermal power.
This change also would require a functional test of the RBM prior to withdrawal of control rods when RBM cperability is rq uired and when only one RBM channel is operable.
For Hatch Unit 1, the Limiting Conditions for Operation with only one or neither RBM channel operable are defined for use when PBM operability is required.
E.
Add new MAPU G multipliers MADFACp, MAPFACp, and definition of governing MAPUG.
BASIS:
In the absence of the APRM scram setdown rquirement, new limits are substituted to assure empliance with the fuel thermal-mechanical design bases.
Power-dependent limits on maximm average planar linear heat generation rate (MAPLHGP) were generated frm the same transient calculations used to determine the power-dependent MCPR multiplier, Kp (Its C
above).
Flow-dependent MAPLHGR rquirments were derived such that the peak transient MAPLHGR during slow-flow runout transients will not increase above the fuel design basis values.
For ease of administration, the new limits are defined as multipliers which apply to the existing fuel-type and exposure-dependent MAPLHGR limits. The flow-dependent multiplier definition also incorporates the requirments derived frm the IOCA analysis. %e most limiting of the MAPLHGR multipliers at any time is the governing MAPLHGR limit.
700775
Georgia Power d Attachnent 2 page 5 3.
Delete or modify affected bases and make editorial changes.
BASIS (For Hatch Unit 1):
Editorial changes to the Technical Specifications are proposed to clarify (1) the definition of the bypass power level below which turbine stop and control valve position scrms are not required; (2) the descriptions of the functional deoendence of the operating limit MCPR and the APUKIR limit; (3) the figure captions assigned to the rated power-rated flow MCPR operating limits; (4) the nmenclature used and the maximum allowable setpoint for the APFM high neutron flux scrm and the Simulated Thermal Power Monitor scrm; (5) the ntrnbering of sections under the Limiting Systs Safety Settings Neutron Flux Trips; (6) the nmenclature for the APRM Rod Block and Rod Block Monitor upscale trips; and (7) the references to Limiting Rod Pattern, adding the phrase "for RWE".
To:hnical Specifications bases would be changed to (1) delete references to the APFM/ STEM scram and rod block peaking factor setdown requirment; (2) identify the REM systa logic changes and operability raguirments; (3) replace references to the Kf analysis bases with descriptions of the MCPRp bases and add descriptions of the Kp MCPR multiplier, the power and flow-dependent MAPUK;R multipliers, and the governing MCPR operating limit and MAPLHGR limit; (4) delete the approximate Power Flow Map and add a reference to document where the correct map is presented; and (5) correct a reference to the 800F Ioss of Feedwater Heating Event.
BASIS (For Hatch Unit 2):
Editorial changes to the Technical Specifications are proposed to clarify (1) the definition of the bypass power level below which turbine stop and control valve position scrams are not required; (2) the descriptions of the functional dependence of the operating limit MCPR and APLHGR limit; (3) the figure captions assigned to the rated power-rated flow MCPR operating limits; and (4) footnote (a) in Table 3.3.5-2 relating to the APFM rod block flow dependence.
4 eorgiaPower1 G
Attacinent 2 page 6 Technical Specification bases would be changed to (1) delete references to the APFM/ STEM scrm and rod block peaking factor setdown requirment; (2) identify the RBM systm logic changes and operability rEquirments; (3) replace references to the Kg analysis bases with descriptions of the MCPRp bases and add descriptions of the Kp MCPR multiplier, the power and flow dependent MAPUER multipliers, and the governing MCPR operating limit and MAPUiGR limit; (4) add a clarifying rmark to the introduction of the Power Distribution Limits Bases; (5) add to the lists of references where appropriate; and (6) delete a reference to cycle-specific OINCPR transient results.
'Ihe above changes are intended to either achieve cor.sistency throughout the Technical Specifications, to correct
- errors, or to change j
nonenclature.
Because such changes are purely administrative, these changes are consistent with Itm (i) of the " Examples of Anendments that are Considered Not Likely to Involve Significant Hazards Considerations", listed on page 14870 of the April 6,1983 issue of the Federal Register and will not result in a
significant hazards consideration.
G 700775
Georgia Power d ATTAONDTP 3 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCl NUCIEAR PIAh'r UNITS 1, 2 REQUEST TO OWEE TEDINICAL SPECIFICATIOG APfN/RIN/ TECH SPEC IMPROVEMNIS PROPOSED TirHNICAL SPECIFICATIGE REVISIONS
%e Technical Specifications for Plant Hatch Units 1 and 2 are proposed for revision as presented in this section.
Tables which provide instructions for incorporating the revisions are given at the beginning of each unit's proposed Technical Specifications revisions.
b
_j 1
l GENERAL EL; TRIC C0MPANY AFFIDAVIT I, Glenn G. Sherwood, being duly sworn, depose and state as follows:
1.
I am Manager, Safety and Licensing Operation, General Electric Company, and have been delegated the function of reviewing the information described in paragraph 2 which is sought to be withheld and have been authorized to apply for its withholding.
2.
" General Electric BWR Licensing Report:
Average Power Range Monitor, Rod Block Monitor and Technical Specification Improvement (ARTS) program for Edwin I. Hatch Nuclear Plant, Units 1 and 2" December 1983 (NEDC-30474-P).
3.
In designating material as proprietary, General Electric utilizes the definition of proprietary information and trade secrets set forth in the American Law Institute's Restatement Of Torts, Section 757.
This definition provides:
"A trade secret may consist of any formula, pattern, device or compilation of information which is used in one's business and p
which gives him an opportunity to obtain an advantage over competitors who do not know cr use it....
A substantial element of secrecy must exist, so that, except by the use of improper means, there would be difficulty in acquiring informa-tion....
Some factors to be considered in determining whether given information is one's trade secret are:
(1) the extent to which the information is known outside of his business; (2) the extent to which it is known by employees and others involved in his business; (3) the extent of measures taken by him to guard the secrecy of the information; (4) the value of the information to him and to his competitors; (5) the amo nt of effort or money expended by him in developing the information; (6) the ease or difficulty with which the information could be properly acquired or duplicated by others."
4.
Some examples of categories of information which fit into the definition of proprietary information are:
a.
Information that discloses a process, method or apparatus where prevention of its use by General Electric's competitors without license from General Electric constitutes a competitive econoraic advantage over other companies; b.
Information consisting of support,ing data and analyses, includ-ing test data, relative to a process, method or apparatus, the p
application of which provide a competitive economic advantage, Q
e.g., by optimization or improved marketability; 7
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c.
Information which if used by a competitor, would reduce his Q
expenditure of resources or improve M.i competitive positicc in the design, manufacture, shipment, lu tcilation, assurance or quality or licensing of a similar product; d.
Information which reveals cost or price information, production capacities, budget levels or commercial strategies of General Electric, its customers or supr,11ers; e.
Information which reveals aspects of past, present or future General Electric customer-funded development plans and programs of potential commercial valta to General Electric; f.
Information which discloses pite. table subject matter for which it may be desirable to obtain patent protection; g.
Information i ich General Electric must treat as proprietary according to agreements with other parties.
5.
In addition to proprietary treatment given to material meeting the standards enumerated above, General Electric customarily maintains in confidence preliminary and draf t material which has not been subject to complete proprietary, technical and editorial review.
This practice is based on the fact that draft documents often do not appropriately reflect all aspects of a problem, may contain tentative conclusions and may contain errors that can be corrected during (N.
normal review and approval procedures.
Also, until the final V
document is completed it may not be possible to make any definitive determination as to its proprietary nature.
General Electric is not generally willing to release such a document to the general public in such a preliminary form.
Such documents are, however, on occasion furnished to the NRC staff on a confidential basis because it is General Electric's belief that it is in the public interest for the staff to be promptly furnished with significant or potentially significant information.
Furnishing the document on a confidential basis pending completion of General Electric's internal review permits early acquaintance of the staff with the information while protecting General Electric's potential proprietary position and permitting General Electric to insure the public documents are technically accurate and correct.
6.
Initial approval of proprietary treatment of a document is made by the Subsection Manager of the originating component, the man most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge.
Access to such documents within the Company is limited on a "need to know" basis and such documents at all times are clearly identified as proprietary.
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7.
The procedure for approval of external release of such a document is (s) reviewed by the Section Manager, Project Manager, Principal Scientist or other cquivalent authority, by the Section Manager of the cognizant Marketing function (or his delegate) and by the Legal Operation for technical content, competitive effect and determination of the accuracy of the proprietary designation in accordance with the standards enumerated above.
Disclosures outside General Electric are generally limited to regulatory bodies, customers and potential customers and their agents, suppliers and licensees only in accordance with appropriate regulatory provisions or proprietary agreements.
8.
The document mentioned in paragraph 2 above has been evaluated in accordance with the abave criteria and procedures and has been found to contain information which is proprietary and which is customarily held in confidence by General Electric.
9.
The information contained herein is the result of extensive analyses performed at considerable cost to the General Electric Company.
The development and verification of these methods, as well as their application and execution ccst in excess of $1.5 million.
STATE OF CALIFORNIA
) ss:
COUNTY OF SANTA CLARA
)
I Glenn G. Sherwood, being duly sworn, deposes and says:
A i
That he. has read the foregoing affidavit and the matters stated therein are true and correct to the best of his knowledge, information, and belief.
Executed at San Jose, California, this ]/g day ofhc.EMMa,190J.
tilenn G. Sherwood General Electric Company Subscribed and sworn before me this lfp-jay ofbcEmMA198g 20 5,
&4 11_
NOTA'RY PUBLIC, STATE OF6 CALIFORNIA AJW:pab/B12089 12/8/83
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