ML20211H018

Application for Amend to Licenses DPR-57 & NPF-5,revising Tech Specs to Achieve Consistency W/Ge Transient Analysis Methodology Re Scram Time Testing.Documents Supporting Proposed Change Withheld (Ref 10CFR2.790).Fee Paid

ML20211H018
Person / Time
Site:	Hatch
Issue date:	02/13/1987
From:	James O'Reilly GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19292G819	List: ML20211H018 ML20211H081
References
SL-1831, TAC-64779, TAC-64780, NUDOCS 8702260041
Download: ML20211H018 (18)

Text

Georg a Fbwer Company 333 Piedmont Avenue Atlanta, Georgia 30308 Telephone 404 526 7851 Maihng Adaress:

Post Office Box 4545 Atlanta. Georgia 30302 James P. O'Reitty tre sou!myn ew:rc sf terv s Senior Vice President Nuclear Operations SL-1831 1084C February 13, 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

REACTIVITY CONTROL, FUEL THERMAL LIMITS AND EDITIORIAL CHANGES Gentlemen:

In accordance with the provisions of 10 CFR 50.90, as required by 10 CFR 50.59(c)(1), Georgia Power Company hereby proposes changes to the Technical Specifications, Appendix A of each of the Operating Licenses, DPR-57 and NPF-5.

The proposed changes would involve revisions to the Unit 1 and Unit 2 Technical Specifications regarding scram time testing in order to achieve consistency with the new General Electric transient analysis methodology. The changes would also allow for the insertion of four Lead Test Assemblies (LTAs) into the Unit 1 reactor during the upcoming refueling outage. Specifically, the proposed changes to the Technical Specifications would:

1. Delete the formula used to determine the statistical scram speed limit (Units 1 and 2).

2. Change the scram speed measurement requirements (Unit 1).

3. Change the definition of design power (Unit 1).

4. Revise the Option A MCPR limit for 8x8 fuel (Unit 1).

5. Add APLHGR limits for LTA fuel assemblies (Unit 1).

6. Revise the APLHGR limits curve for an existing fuel type  !

(Units 1 and 2).

These proposed revisions will allow Georgia Power Company to take full advantage of the GEMINI methodology, improve plant operations, and test a new fuel design in the Plant Hatch Unit 1 reactor.

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U. S. Nuclear Regulatory Commission ATTN: Document Control Desk February 13, 1987 Page Two Enclosure 1 provides detailed descriptions of the proposed changes and circumstances necessitating the change request.

Enclosure 2 details the bases for our determination that the proposed changes do not involve significant hazards considerations.

Enclosure 3 provides page change instructions for incorporating the proposed changes.

The proposed changed Technical Specifications pages for Unit 1 and Unit 2 follow Enclosure 3.

To support the proposed changes, Enclosure 4 provides documents which have not been submitted to the NRC. Please note that some information contained in Enclosure 4 has been marked " Proprietary" to protect the commercial interest of the fuel vendor. In accordance with the requirements of 10 CFR 2.790, an affidavit is included therein which requests that certain information be withheld from public disclosure.

Payment of the filing fee in the amount of one hundred and fifty dollars is enclosed.

In order to allow time for procedure revisions and orderly incorporation into copies of the Technical Specifications, we request that the proposed amendment, once approved by the NRC, be issued with an effective date to be no later than 60 days from the date of issuance of the amendment.

Pursuant to the requirements of 10 CFR 50.91, a copy of this letter and all applicable enclosures will be sent to Mr. J. L. Ledbetter of the Environmental Protection Division of the Georgia Department of Natural Resources.

f tr. James P. O'Reilly states that he is Senior Vice President of Georgia Power Company and is authorized to execute this oath on behalf of Georgia Power Company, and tht to the best of his knowledge and belief the facts set forth in this letter are true.

GEORGIA POWER C0iiPANY By: o.mwL h 6 James P. O'Reilly 1084C i

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U. S. Nuclear Regulatory Comission ATTN: Document Control Desk February 13, 1987 Page Three Sworn t3 and subscribed before me this 13th day of February 1987.

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~GKM/lc Enclosures c: Georgia Power Company U.S. Nuclear Regulatory Commission Mr. J. T. Beckham, Jr. Dr. J. N. Grace, Regional Administrator Mr. 11. C. Ni x , J r. Mr. P. Holmes-Ray, Senior Resident GO-NORMS Inspector-Hatch State of Georgia Mr. J. L. Ledbetter 1084C

A ENCLOSURE 1 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

REACTIVITY CONTROL, FUEL THERMAL LIMITS-AND EDITIORIAL CHANGES BASIS FOR CHANGE REQUEST PROPOSED CHANGE 1:

Proposed Change 1 revises the Minimum Critical Power Ratio (MCPR) scram time parameters given in the current Unit 1 and Unit 2 Technical Specifications. One of these limits, T B, is the statistical scram speed limit which forms the basis for a reduction in the Operating Limit MCPR (0LMCPR) due to increased scram speeds over the minimum speeds required by the Technical Specifications.

At present, the Unit 1 formula used to calculate T B is defined in the Technical Specifications as-g 1/2 T

B

= 0.710 + 1.65 1 (0.053) n

{N9

. i =1 -

where:

0.710 = the mean of the scran speed distribution (designated as u) assumed in the GENESIS analyses to calculate the Option B HCPR.

0.053 = the standard deviation (designated as o )of the scram speed distribution.

The Unit 2 formula is the same, except that the mean is 0.834, and the standard deviation is 0.059. This slight difference is due to the fact that Unit 2 scram time testing is based upon rod position in notches t rather than percentage of rod insertion.

General Electric derived the values listed above by evaluating the BWR industry data base for scram speeds. Since the derivation of the p and a for the GENESIS set of methods, the scram speed data base has expanded, and new values of p and a have been determined. To simplify the Technical Specifications, we propose that the formula for calculating TB be deleted, thus allowing Georgia Power Company (GPC) the flexibility to use the most up-to-date industry experience when determining OLMCPRs for Plant Hatch.

For consistency, the definitions for T , r ave, and T A would also be deleted from the Technical Specifications, even though these values are unaffected by a reevaluation of the scram time data base.

1084C El-1 02/13/87

L ENCLOSURE 1 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

REACTIVITY CONTROL, FUEL THERMAL LIMITS AND EDITIORIAL CHANGES BASIS FOR CHANGE REQUEST Background for Proposed Change 1:

General Electric has determined that the change in MCPR is dependent in part upon the speed of control rod insertion during the reactor scram which occurs during a transient. In the GENESIS methodology for calculating the Option A OLMCPR, GE assumed that all control rods would be inserted at the speed given in the Technical Specifications. However, scram speeds for most BWRs are significantly faster than the speeds required by the Technical Specifications. Therefore, to take credit for this, the Option B method of calculating OLMCPR was devised. For BWR plants that can demonstrate increased scram speeds, the Option B OLMCPR is considerably lower than the Option A li: nit.

The scram speed associated with Option B, T B, is determined from a statistical distribution of scram speeds which have occurred at BWR pl ants. Thus, T B, which is defined as the Option B acceptance criterion for the average time required for rods to travel from their fully withdrawn position to 20-percent inserted, depends upon the mean and the standard deviation of the distribution of scram speeds assumed in the Option B MCPR calculation. (The Unit 2 Technical Specifications approximate "20-percent inserted" is notch position 36, thus the p and o included in the formula for calculating T B are numerically dffferent.) The form of the equation is:

T B

= 4 + A(n)o ,

where:

4 = the mean of the scram speed distribution assumed by GE in the Option B MCPR calculation.

3 = the standard deviation of u ,

A(n) = a function of the number of rods tested; as the number increases, A(n) decreases, thus TB decreases.

The GEMINI Option B adjustment factors were derived using a scram speed data base which was broader than the data base used in deriving the GENESIS adjustment factors. As a resul t, the mean and the standard deviation of the distribution used in the analyses have changed. To simplify the Technical Specifications, it is proposed that the formula for calculating TB be deleted. The formula will be retained in the 1084C El-2 02/13/87

ENCLOSURE 1 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

REACTIVITY CONTROL, FUEL THERMAL LIMITS AND EDITIORIAL CHANGES BASIS FOR CHANGE REQUEST plant procedures. The scram time testing requirements, in addition to the necessity to show conformance to the existing OLMCPR, will remain unchanged.

Basis for Proposed Change 1:

The change in the scram speed data base is reflected in GE's submittal to the NRC concerning the GEMINI application methodology for deriving OLMCPRs from results of transient calculations (Reference 1). The GEMINI methods and their applications, including improved scran times, have been approved by the NRC (References 2 and 3).

The proposed Technical Specifications changes will not alter GPC's method of determining that the average scram speeds at Plant Hatch conform to the distribution assumed in the licensing analyses for Option B. If Option B limits are exceeded (i.e., Tave greater than T B), the application of either the GENESIS or the GEMINI methodology contains a provision for increasing the OLMCPR up to a value based upon Technical Specifications scram speeds. To date, Plant Hatch operating data indicate that scram speeds used in the GEMINI Option B analyses are corservative.

Although the value for T B will change because the values of p and o are different, the definitions for T , T ave, and T A Will remain the same.

PROPOSED CHANGE 2:

Proposed Change 2 revises the requirements for the scram times given in the Unit 1 Technical Specifications. Currently, the percentage of rod insertion is measured as 'a function of time; however, the plant's scram time recorder indicates rod position in notches. Since the percentages that appear in the Technical Specifications do not correspond to any particular notch, a conversion has to be made from rod position to percentage.

This change will require that during scram time testing, rods reach a given notch position instead of percentage inserted within a certain length of time, thereby simplifying plant operations and eliminating the difference between the Unit 1 and Unit 2 Technical Specifications. The exact changes are listed below.

1084C El-3 02/13/87

ENCLOSURE 1

, REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

REACTIVITY CONTROL, FUEL THERMAL LIMITS AND EDITIORIAL CHANGES BASIS FOR CHANGE REQUEST 7

i[

Current Proposed

' Technical Specificationss Technical Specifications

!. Scram time from fully withdrawn Scram time from fully to 90% inserted - 7 seconds withdrawn to notch position 06 - 7 seconds

! All operable control rods - All operable control rods -

scram time from fully scram time from fully.

I withdrawn (% inserted) withdrawn (notch position) l l 5% - 0.375 seconds 46 - 0.358 seconds 20% - 0.90 seconds 36 - 1.096 seconds i 50% - 2.00 seconds 26 - 1.860 seconds 90% - 3.5 seconds 6 - 3.419 seconds Three out of four in Three out of four in 2x2 array - scram time 2x2 array - scram time 1 -from fully withdrawn from fully withdrawn

(% inserted) (notch position) t 5% - 0.398 seconds 46 - 0.379 seconds i 20% - 0.954 seconds 36 - 1.162 seconds

'50% - 2.120 seconds 26 - 1.972 seconds 90% - 3.80 seconds 6 - 3.624 seconds Background for Proposed Change 2:

This change is being proposed to simplify the work required to monitor .

i compliance with the scram time specified in the Technical Specifica-tions. At Plant Hatch, the scram time recorder indicates rod position in notch positions.

• Tor Unit 1, the notches have to be converted to

! " percent of rod , fully inserted" in order t.o be compared with the Technical Specifications. In changing to a "nntch position basis," the possibility of error and the amount of time ' required to make the

, comparison will be reduced, because the conversion to a percentage basis will be eliminated. In addition, establishing consistency between the i Unit.1 and the Unit 2 Technical Specifications will reduce the 1 possibility of personnel error, because the plant procedures for determining compliance with the scram times given in the Technical

Specifications will be even more similar.

e i- 1084C El-4 02/13/87 l

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4 9

ENCLOSURE 1 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

REACTIVITY CONTROL, FUEL THERMAL LIMITS AND EDITIORIAL CHANGES BASIS FOR CHANGE REQUEST Basis for Proposed Change 2:

Scram time testing is performed every cycle to ensure that all rods are

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2 operable and capable of performing their intended safety function. Since rod position is indicated as the number of notches withdrawn rather than the percent inserted, plant operations ccn be simplified by defining the scram time testing Technical Specifications in terms of notch position.

> GE has determined that the Technical Specifications scram times for the notch positions listed above are equivalent to the current values (Reference 4).

. PROPOSED CHANGE 3:

Proposed Change 3 revises the current value of and the references to the

' initial power level assumed for certain transients in the Hatch Unit 1 Technical Specifications Bases. This change is needed to achieve i consistency with the change in power level associated with GE's new L transient methods known as GEMINI. This NRC-approved methodology has been incorporated into the GE licensing topical report, GESTAR II (Reference 1).

l Background for Proposed Change 3:

1 I For pressurization transients, GE begins by assuming that the reactor is operating at a power level which is associated with a particular steam fl ow. In the GENESIS methods, the initial steam flow was 105 percent, and the corresponding reactor power was approximately 104 percent of rated or 2537 MWt. For pressurization events analyzed using GEMINI methods, the power level uncertainty is included in the adjustment factors used to determine the Option A and Option B limits. Therefore,

- these events are an'alyzed at rated power instead of the Design Power as defined in the Technical Specifications, and the resultant ACPR is increased to account for power level uncertainty.

Basis for Proposed Change 3:

The basis for reducing the initial power level assumed in the transient analyses is explained in GE's submittal to the NRC concerning the GEMINI application methods (Reference 1). GE has shown that the GEMINI methods, including the initial reactor power specified in Reference 4, conservatively predicted actual transient events at an operating plant.

1084C El-5 02/13/87

r ENCLOSURE 1 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

REACTIVITY CONTROL, FUEL THERMAL LIMITS AND EDITIORIAL CHANGES BASIS FOR CHANGE REQUEST This approach was found to be acceptable by the NRC as evidenced by their safety evaluation (Reference 3).

PROPOSED CHANGE 4:

In accordance with the NRC-approved new GEMINI methodology, GPC proposes to reduce the Unit 1 Option A limit from 1.35 to 1.33 for all Hatch 18x8 fuel. Al though Unit 1 has always operated with T ave less than T B, the change in T B assumed in the GEMINI analyses may increase T

the probability that T ave will be greater than B at some time during an operating cycle. In that case, the OLMCPR will fall between the Option A and the Option B limit. Under these conditions, GPC would benefit from an Option A limit which is as small as possible. Therefore, it is proposed that Option A be calculated using the approach which is consistent with the GEMINI methodology.

Background for Proposed Change 4:

To account for the model uncertainties associated with GENESIS, the NRC imposed a 4.4-percent penalty on the final MCPR. This approach became known as the Option A procedure for calculating the MCPR limit. However, for those utilities that could demonstrate scram speeds faster than the Technical Specifications requirements, the NRC approved an alternative procedure, known as Option B, for calculating the MCPR limit. As planned, the Option B limit was lower than the Option A limit. Depending upon the measured average scram speed 'of the rods, the OLMCPR was determined to be greater than or equal to the Option B limit but less than or equal to the Option A limit.

The application of the new GEMINI methodology improved the approach used i to determine the Option A limit for pressurization transients. The details of the new Option A calculation are described in References 1 and 7.

Basis for Proposed Change 4:

Even though GEMINI may calculate an Option B MCPR which is lower than the value calculated with GENESIS, the Option B Technical Specifications limit will not be changed at this time. Reducing the Option A OLMCPR by 0.02 relative to its current value is expected to provide additional operating flexibility, while still maintaining a margin to the results of cycle-specific analyses performed with GEMINI.

1084C El-6 02/13/87

L ENCLOSURE 1 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

REACTIVITY CONTROL, FUEL THERMAL LIMITS AND EDITIORIAL CHANGES BASIS FOR CHANGE REQUEST PROPOSED CHANGE 5:

Georgia Power Company intends to load four GE Lead Test Assemblies (LTAs) as part of the Hatch 1 Reload 10 fuel batch. These assemblies, known as the 1987 Hatch 1 LTAs, will replace four of the GE78-BP80RB284 bundles which would have otherwise been used. Proposed Change 5 will add a new set of APLHGR limits (in the form of an APLHGR limit curve) for the LTA fuel, since the limits differ from those of any other fuel referenced in the Technical Specifications.

Background for Proposed Change 5:

Georgia Power Company (GPC) and GE are jointly studying advanced fuel designs for BWRs. In line with GE's " test before use" philosophy, GPC is

planning to load four LTAs into Hatch 1 as part of the Reload 10 fuel batch. The unique design features and the expected fuel performance improvements of the LTAs are described in Reference 5. The design features are generally aimed at maximizing overall plant economics, increasing thermal margins during operation, increasing stability, and

~

i simplifying reactor operations. The program at Plant Hatch is designed

!- to demonstrate, at least in part, the benefits associated with the LTA design changes.

! Basis for Proposed Change 5:

All aspects of the LTA bundle design are analyzed with NRC-approved codes and methods for steady-state, transient, and accident conditions. The proposed APLHGR limits comply with all of the thermal-mechanical limits for BWR fuel and with the licensing criteria described in 10 CFR 50.46 (Reference 9). General Electric also used currently approved methodology to predict the performance of the LTAs under LOCA CONDITIONS.

In the LOCA analysis, GE assumed that the initial peak linear heat generation rate (LHGR) for the highest power rod in the bundle is 14.4 kW/ft, which is a thermal-mechanical restriction. However, the LHGR Technical Specifications limit for the LTAs will be held to 13.4 kW/ft at this time and will be monitored as such by the plant process computer.

Likewise, the current MCPR limits for 8x8 fuel are expected to be applicable to the LTA fuel assemblies.

1084C El-7 02/13/87

n ENCLOSURE 1 ,

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

REACTIVITY CONTROL, FUEL THERMAL LIMITS AND EDITI0 RIAL CHANGES BASIS FOR CHANGE REQUEST In conclusion, the acceptability of APLHGR limits for the 1987 Hatch 1 LTAs is based upon the analyzed compliance with the requirements of 10 CFR 50.46. As stated in Reference 6, the GE codes used in the analyses comply with the methodology specified in 10 CFR 50, Appendix K, and are applicable for analyzing the new GE fuel design.

PROPOSED CHANGE 6:

Proposed Change 6 would add an APLHGR limit data point at an exposure of 1.0 Gwd/t on the curves for P8DRB283 and BP8DRB283 80-mil fuel. (This applies to both units.)

Basis for Proposed Change 6:

The proposed APLHGR limit data point at 1.0 Gwd/t was included in the original GE analysis (Reference 8). However, this value was inad-vertently omitted when the current graph was drawn based upon the values contained in Reference 8.

1084C El-8 02/13/87

L ENCLOSURE 1 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

REACTIVITY CONTROL, FUEL THERMAL LIMITS AND EDITIORIAL CHANGES BASIS FOR CHANGE REQUEST

REFERENCES:

1. Letter, J. S. Charnley (GE) to H. N. Berkow (NRC), " Revised Supplementary Information Regarding Amendment 11 to GE Licensing Topical Report NEDE-240ll-P-A," (GESTAR II), dated January 16, 1986.

2. Letter, C. O. Thomas (NRC) to J. S. Charnley (GE), " Acceptance for Referencing of Licensing Topical Report, NEDE-240ll-P-A, Rev. 6, Amendment 11, ' General Electric Standard Application for Reactor Fuel' (GESTAR II)," dated November 5,1985.

3. Letter, G. C. Lainas (NRC) to J. S. Charnley (GE), " Acceptance for Referencing of Licensing Topical Report NEDE-240ll-P-A, ' General Electric Licensing Reload Report,' Supplement to Amendment 11," dated March 22,1986.

4. Letter CJP:86-269, J. P. Hibert (GE) to L. K. Mathews (SCS), " Plant Hatch Scram Insertion Times," dated November 21, 1986.

5. Letter CJP:86-254, C. J. Paone (GE) to L. K. Mathews (SCS), " Final Lead Test Assembly Information Submittal," dated November 13, 1986.

6. Letter, T. A. Ippolito (NRC) to R. Engel (GE), " Lead Test Assembly Licensing," September 23, 1981.

7. Letter, J. S. Charnley (GE) to G. C. Lainas (NRC), " GEMINI /0DYN Statistical Adders for BWR 4/5 (with RPT) - EOC," dated July 28, 1986.

8. Letter, CJP:86-076, from J. P. Nibert (GE) to L. K. Mathews (SCS),

"MAPLHGR Limits for Several Fuel Types," dated March 31, 1986.

9. Letter, CJP:86-256, C. J. Paone (GE) to L. K. Mathews (SCS), "LOCA Analysis of Hatch 1 1987 LTAs," dated November 13, 1986.

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l 1084C El-9 02/13/87 l

ENCLOSURE 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

REACTIVITY CONTROL, FUEL THERMAL LIMITS AND EDITIORIAL CHANGES 10 CFR 50.92 EVALUATION Pursuant to the requirements of 10 CFR 50.92, Georgia Power Company (GPC) has evaluated the proposed amendments for Plant Hatch Units 1 and 2 and has determined that their adoption would not involve a significant hazards consideration. The basis for this determination is as follows:

PROPOSED CHANGE 1:

This proposed modification would delete the Technical Specifications formula for determining T B in order to give Georgia Power Company the maximum flexibility to use BWR industry experience with respect to scram time testing. For consistency, the definitions for T , T ave, and TA would also be deleted, since the value of the Operating Limit Minimum Critical Power Ratio (0LMCPR) depends upon all four variables.

Basis for No Significant Hazards determination:

This proposed change does not involve a significant hazards considera-tion, because it would not:

1. Involve a significant increase in the probability or consequences of an accident previously eval uated, because no change in plant operation will occur as a result of this change. The definitions of T T ave, and OLMCPR Option A and Option B will T , T A. B.

remain the same and will be monitored at the site in the same manner l as before. The value for T B will change as a resul t of a reevaluation of the BWR scram time data base. The new scram time distribution that was used to determine T B for the Option B MCPR limit was reviewed and approved by the NRC in their consideration of the GEMINI application methodology.

2. Create the possibility of a new or different kind of accident from any previously analyzed, because no change in plant equipment or 7

, operations will occur as a result of this change.

i

3. Involve a significant reduction in the margin of safety, because the OLHCPR will continue to be based upon either actual measured scram speeds or a conservative assumption relative to scram speeds. Both of these methods have been previously approved by the NRC.

1084C E2-1 02/13/87 i

r ENCLOSURE 2 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

REACTIVITY CONTROL, FUEL THERMAL LIMITS AND EDITIORIAL CHANGES 10 CFR 50.92 EVALUATION PROPOSED CHANGE 2:

This proposed change will replace the current Unit 1 Technical Specifications method of measuring control rod scram times with an equivalent method in order to simplify plant operations and eliminate the difference between Unit 1 and Unit 2 Technical Specifications in this respect. The new Technical Specifications scram times will be based upon measured notch position (e.g., 36 notches withdrawn) rather than percentage of rod inserted (e.g., 20 percent).

Basis for No Significant Hazards Determination:

This proposed change does not involve a significant hazards consideration, because it would not:

1. Involve a significant increase in the probability or consequences of an accident previously eval uated, because no change in plant equipment operation will occur as a result of this change. In addition, rod scram speeds will meet a criterion equivalent to the current Technical Specifications. Thus, during the time critical to transient phenomena, there will be no decrease in the rate of negative reactivity insertion due to control rod motion.

2. Create the possibility of a new or different kind of accident from any previously analyzed, because no significant change in plant equipment or operations will occur as a result of this change.

3. Involve a significant reduction in the margin of safety, because scram speeds as a function of notch position will be essentially equivalent to scram speeds as a function of percentage of rod inserted. The proposed values for Unit 1 are identical to the current Unit 2 values.

PROPOSED CHANGE 3:

This proposed change would revise, in the Hatch 1 Technical Specifications, the initial power assumed for certain transients from 2537 MWt to 2436 MWt to reflect the initial reactor power used in the GEMINI methodology in calculating CPR.

1084C E2-2 02/13/87

ENCLOSURE 2 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

REACTIVITY CONTROL, FUEL THERMAL LIMITS AND EDITIORIAL CHANGES 10 CFR 50.92 EVALUATION Basis for No Significant Hazards Determination:

This proposed change does not involve a significant hazards considera-tion, because it would not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated, because this change is being made to reflect changes consistent with the GE!!INI methodology used for transient analyses.

2. Create the possibility of a new or different kind of accident from any previously analyzed, because no change in plant equipment or operations will occur as a result of this change.

3. Involve a significant reduction in the margin of safety, because the GEMINI methodology, including the change in initial reactor power, has been shown to conservatively predict the results of actual transient phenomena at an operating BWR. The GEMINI methods have been reviewed and approved by the NRC.

PROPOSED CHANGE 4:

This proposed change would reduce the Option A MCPR liuit for Unit 1 from 1.35 to 1.33 for all Hatch 18x8 fuel. This is being done to maximize the MCPR margin for all scram speeds.

l Basis for No Significant Hazards Determination:

This proposed change does not involve a significant hazards consideration, because it would not:

l 1. Involve a significant increase in the probability or consequences of l an accident previously evaluated, because no change in equipment operations will occur as a result of this change. The new Option "A"

! MCPR value will still ensure that the initial operating value assumed in the LOCA analyses will be conservative for all operating conditions.

2. Create the possibility of a new or different kind of accident from i any previously analyzed, because no change in plant equipment or l operations will occur as a result of this change.

1 1084C E2-3 02/13/87

ENCLOSURE 2 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

REACTIVITY CONTROL, FUEL THERMAL LIMITS AND EDITIORIAL CHANGES 10 CFR 50.92 EVALUATION

3. Involve a significant reduction in the margin of safety, because the method used to determine the Option "A" limit is consistent with the application of GEMINI. This method has been reviewed and approved by the NRC for use by BWR utilities. _

PROPOSED CHANGE 5:

Georgia Power Company proposes to add an AFLHGR limit curve to the Unit 1 Technical Specifications to reflect the thermal-mechanical and Emergency Core Cooling System (ECCS) limits on four Lead Test Assemblies (LTAs) which are expected to be part of the Hatch 1 Reload 10 fuel batch.

Basis for No Significant Hazards Determination:

This proposed change does not involve a significant hazards consideration, because it would not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated, because the operating limits for the LTAs were determined using approved methods which ensure that all acceptance criteria for accidents are met.

2. Create the possibility of a new or different kind of accident from any previously analyzed, because no change in plant design or operation is involved, except for relatively minor changes in the mechanical, thermal-hydraulic, and nuclear aspects of the fuel design for a small quantity of assemblies.

3. Involve a significant reduction in the margin of safety, because approved methods will be used to determine all operating limits for the new assemblies.

PROPOSED CHANGE 6:

Georgia Power Company proposes that the APLHGR limits curve provided in the Unit 1 and Unit 2 Technical Specifications for P8DRB283 and BP80RB283 80-mil fuel be modified to include a previously omitted data point at 1.0 Gwd/t.

1084C E2-4 02/13/87

-. _ _ _ - - ___-______________________ __. _ __ _ _ _ _ _ _ _ _ _ _ _ J

L ENCLOSURE 2 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

REACTIVITY CONTROL, FUEL THERMAL LIMITS AND EDITIORIAL CHANGES 1TLFR 50.92 EVALUATION Basis for No Significant Hazards Determination:

This proposed change does not involve a significant hazards consideration, because it would not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated, because the additional APLHGR limits data point - was determined using approved methods, therefore ensuring that all acceptance criteria for accidents were met.

2. Create the possibility of a new or different kind of accident from any previously analyzed, because no change in plant equipment or operations will occur as a result of this change.

3. Involve a significant reduction in the margin of safety, because the addition of the proposed APLHGR limits data point is conservative relative to the current approved value.

1084C E2-5 02/13/87

nk ENCLOSURE 3 NRC DOCKET 50-321, 50-366 OPERATING LICENSE DPR-57 EDWIN I. HATCH NUCLEAR PLANT UNIT 1 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

REACTIVITf CONTROL, FUEL THERMAL LIMITS AND EDITIORIAL CHANGES PAGE CHANGE INSTRUCTIONS The proposed changes to Technical Specifications (Appendix A to Operating Licenses DPR-57 and NPFS) would be incorporated as follows:

UNIT 1 Remove Page Insert Page X X 1.0-2 1.0-2 1.1-10 1.1.10 1.1-11 1.1-11 1.2-6 1.2-6 3.3-2 3.3-2 3.3-3 3.3-3 3.3-10 3.3-10 3.11-2 3.11-2 3.11-2a 3.11 -2a Figure 3.11-1 (Sheet 5) Figure 3.11-1 (Sheet 5)

Figure 3.11-1 (Sheet 6) Figure 3.11-1 (Sheet 6)

Figure 3.11-4 Figure 3.11-4 UNIT 2 Remove Page Insert Page 3/4 2-4h 3/4 2-4h 3/4 2-6 3/4 2-6 3/4 2-7 3/4 2-7 1084C 02/13/87