Text

Request for Addition of Surveillance Requirements Note for LCO 3.7.7 (NL-16-1617)
	ML17199A121
Person / Time
Site:	Hatch
Issue date:	07/10/2017
From:	Hutto J; Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-16-1617
	Download: ML17199A121 (23)
	v • d • e

~ Southern Nuclear J . J. Hutto Regulatory Affairs Director 40 lnvem~ss Center PdtlW.l)

Post CJflicc l:lox 1295 Birmingham. AL 352-'2 205 992 5S72 tel 205 992 760 I fa' jjhutto@' "luthcmcn wm JUll 0 2017 Docket Nos.: 50-321 NL-16-1617 50-366 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Unit 1 and 2 Request for Addition of Surveillance Requirements Note for LCO 3.7.7 Ladies and Gentlemen:

In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Southern Nuclear Operating Company (SNC) requests an amendment to Renewed Facility Operating License Nos. DPR-57 and NPF-5 for the Edwin I. Hatch Nuclear Plant (HNP) Units 1 and 2. The proposed change (1) adds a Note to the Surveillance Requirements (SRs) of the Hatch Nuclear Plant (HNP) Unit 1 and Unit 2 Technical Specifications (TS) 3.7.7 clarifying that the SRs are not required to be met when the LCO does not require the Main Turbine Bypass System to be Operable, (2) clarifies that LCO 3.2.3, "LINEAR HEAT GENERATION RATE" also has limits for an inoperable Main Turbine Bypass System that are made applicable as specified in the Core Operating Limits Report, and (3) deletes an outdated footnote for LCO 3.2.3.

SNC requests approval of the proposed license amendments by 6/20/2018. The proposed changes would be implemented within 90 days of issuance of the amendment.

This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at 205.992.7369.

U.S. Nuclear Regulatory Commission NL-16-1617 Page2 Mr. J. J. Hutto states he is Regulatory Affairs Director of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.

Respectfully submitted, J. J. Hutto Regulatory Affairs Director \. )

)

JJH/RMJ Sworn to and subscribed before me this )J2_ day of ~ 12017.

~L ~&L Notary Public My commission expires: /D -g*cJ. o11

Enclosures:

1. Basis for Proposed Change

2. Marked-up Technical Specification (TS) and TS Bases Pages

3. Clean Technical Specification Pages cc: Regional Administrator, Region II NRR Project Manager- Hatch Senior Resident Inspector- Hatch Director, Environmental Protection Division - State of Georgia RType: CHA02.004

Edwin I. Hatch Nuclear Plant Unit 1 and 2 Request for Addition of Surveillance Requirements Note for LCO 3.7.7 Enclosure 1 Basis for Proposed Change to NL-16-1617 Basis for Proposed Change

1.

SUMMARY

DESCRIPTION The proposed change (1) adds a Note to the Surveillance Requirements (SRs) of the Hatch Nuclear Plant (HNP) Unit 1 and Unit 2 Technical Specifications (TS) 3.7.7 clarifying that the SRs are not required to be met when the LCO does not require the Main Turbine Bypass System to be Operable, (2) clarifies that LCO 3.2.3, "LINEAR HEAT GENERATION RATE" also has limits for an inoperable Main Turbine Bypass System that are made applicable as specified in the Core Operating Limits Report, and (3) deletes an outdated footnote for LCO 3.2.3.

2. DETAILED DESCRIPTION 2.1 Main Turbine Bypass System Design and Operation The Main Turbine Bypass System is designed to control steam pressure when reactor steam generation exceeds turbine requirements during unit startup, sudden load reduction, and cooldown. It allows excess steam flow from the reactor to the condenser without going through the turbine. The bypass capacity of the system with all three bypass valves operable is approximately 20% of the Nuclear Steam Supply System rated steam flow for both Unit 1 and Unit 2 (although the bypass valves may be considered operable with less than all three valves operable). Sudden load reductions within the capacity of the steam bypass can be accommodated without reactor scram. The Main Turbine Bypass System is assumed to function during events crediting the system (e.g. feedwater controller failure- maximum demand) as discussed in Chapter 15 of the HNP Unit 2 Final Safety Analysis Report (FSAR). (This Chapter is common to both units.) Opening the bypass valves during the pressurization event mitigates the increase in reactor vessel pressure, which affects the minimum critical power ratio (MCPR) and linear heat generation rate (LHGR) during the event. As a result, when the Main Turbine Bypass System is inoperable, penalties must be applied to the MCPR and LHGR.

2.2. Current Technical Specifications Requirements HNP TS 3.7.7 provide the requirements for the Main Turbine Bypass System. The LCO provides two methods to meet the LCO requirements: the Main Turbine Bypass System is required to be Operable or more restrictive thermal limits must be applied. TS 3.2.2, "Minimum Critical Power Ratio (MCPR)," and TS 3.2.3, "Linear Heat Generation Rate," includes thermal limits that must be applied when the Main Turbine Bypass System is inoperable. The MCPR and LHGR limits are specified in the Core Operating Limits Report (COLR). Either option, an Operable Main Turbine Bypass System or more restrictive thermal limits, is an acceptable method for meeting the LCO. If the LCO is not met, LCO 3.7.7 Required Action A.1 provides 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to either restore the system to Operable status or to apply the Turbine Bypass System inoperable thermal limits. The Surveillance Requirements (SRs) only provide testing requirements for the Main Turbine Bypass System.

2.3. Reason for the Proposed Change The current TS requires the SRs of TS 3.7.7 to be performed even when the LCO does not require the Main Turbine Bypass System to be Operable. This creates a conflict within the TS. If HNP is relying on the LCO option to apply more restrictive thermal limits and does not perform the SRs, SR 3.0.1 requires the LCO to be declared not met. HNP would then enter Action A, which requires the LCO to be met within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . However, the LCO is already met. HNP would E1-1 to NL-16-1617 Basis for Proposed Change remain in Action A until the SRs are performed, which is in conflict with the LCO requirements and with LCO 3.0.2, which requires entering Actions only when the LCO is not met.

The current TS LCO 3.7.7 only mentions that the LCO 3.2.2 MCPR limits are made applicable when the main turbine bypass system is inoperable. However, LCO 3.2.3 also has more restrictive limits for an inoperable main turbine bypass system. The Conditions, Required Actions, and associated Completion Times for LCOs 3.2.2, 3.2.3, and 3.7.7 are all essentially identical. All three LCOs give 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to satisfy the requirements of the LCO if it's not met, and then 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months thereafter to reduce THERMAL POWER to less than 24% RTP. Modifying the LCO 3.7.7 to clarify the more restrictive LHGR rates need to be met for an inoperable main turbine bypass system therefore does not actually modify the current requirements.

Both HNP Unit 1 and Unit 2 have an outdated footnote on their LHGR LCOs that state the cycle for which these requirements are effective. Both units are past that respective cycle. Therefore, these footnotes are being deleted to avoid possible confusion to whether this LCO is in effect.

2.4 Description of the Proposed Change The proposed change (1) adds a Note to the Surveillance Requirements (SRs) of the Hatch Nuclear Plant (HNP) Unit 1 and Unit 2 Technical Specifications (TS) 3.7.7 clarifying that the SRs are not required to be met when the LCO does not require the Main Turbine Bypass System to be Operable, (2) clarifies that LCO 3.2.3, "LINEAR HEAT GENERATION RATE" also has limits for an inoperable Main Turbine Bypass System that are made applicable as specified in the Core Operating Limits Report, and (3) deletes an outdated footnote for LCO 3.2.3.

The proposed change is supported by changes to the TS Bases. The regulation at Title 10 of the Code of Federal Regulations (1 0 CFR), Part 50.36, states, "A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications." A licensee may make changes to the TS Bases without prior NRC staff review and approval in accordance with the Technical Specifications Bases Control Program. The proposed TS Bases changes are consistent with the proposed TS changes and provide the purpose for each requirement in the specification consistent with the Commission's Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, dated July 2, 1993 (58 FA 39132). Therefore, the Bases changes are provided for information and approval of the Bases is not requested.

3. TECHNICAL EVALUATION The Main Turbine Bypass System is assumed to function during events crediting the system (e.g. feedwater controller failure- maximum demand) as discussed in Chapter 15 of the Unit 2 FSAR (which is common to both units). Opening the bypass valves during the pressurization event mitigates the increase in reactor vessel pressure, which affects the MCPR and LHGR during the event. An inoperable Main Turbine Bypass System may result in the need to apply MCPR and LHGR penalties.

The Surveillance Requirements (SRs) in TS 3.7.7 only test the Main Turbine Bypass System.

TSs 3.2.2 and 3.2.3 contain SRs that verify the MCPR and LHGR limits, respectively, including the limits applied when the Main Turbine Bypass System is inoperable.

E1-2 to NL-16-1617 Basis for Proposed Change LCO 3.7.7 provides two options to meet the LCO. One option is to maintain the Main Turbine Bypass System Operable. The second option is to apply the Main Turbine Bypass System inoperable thermal limits. Thus, if the second option is chosen, there is no requirement for the Main Turbine Bypass System to be Operable. This proposed change clarifies this current allowance. In other LCOs in the BWR/4 ISTS, Notes are provided for clarity under similar

conditions. For example, TS 3.1 0.3 in the BWR/4 ISTS provides two LCO options to meet part

d. Each of the two LCO options (d.1 and d.2) has a specific SR to ensure that option is met; SR 3.1 0.3.2 includes a Note stating that it is not required to be met if SR 3.1 0.3.1 is satisfied for LCO 3.1 0.3.d.1 requirements. This proposed Note is similar and is being added for the same reasons as needed in LCO 3.1 0.3. Thus, the proposed change is consistent with the manner in which optional SRs are identified as not being required under certain conditions.

The proposed change does not affect the requirement to meet the LCO, nor does it affect the requirements to perform the SRs when the Main Turbine Bypass System is being used to meet the LCO. Thus, there is no impact to the safety analyses due to the proposed change.

The other two changes made in this LAR (clarify that LCO 3.2.3, "LINEAR HEAT GENERATION RATE" also has limits for an inoperable Main Turbine Bypass System that are made applicable as specified in the Core Operating Limits Report and delete an outdated footnote for LCO 3.2.3), are purely administrative since there are no actual TS requirements being modified by these changes.

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Criteria The following regulatory requirements have been considered:

Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36, "Technical specifications," in which the Commission established its regulatory requirements related to the contents of the TS. Specifically, 10 CFR 50.36(c)(3) states that, "Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be met." The proposed Note only applies when the Main Turbine Bypass System is not being used to meet the LCO. Therefore, the change does not alter the required surveillance testing.

4.2 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Southern Nuclear Operating Company (SNC) requests an amendment to Renewed Facility Operating License Nos. DPR-57 and NPF-5 for the Edwin I. Hatch Nuclear Plant (HNP) Units 1 and 2. The proposed change {1) adds a Note to the Surveillance Requirements (SRs) of the Hatch Nuclear Plant (HNP) Unit 1 and Unit 2 Technical Specifications {TS) 3.7.7 clarifying that the SRs are not required to be met when the LCO does not require the Main Turbine Bypass System to be Operable, {2) clarifies that LCO 3.2.3, "LINEAR HEAT GENERATION RATE" also has limits for an inoperable Main Turbine Bypass System that are made applicable as specified in the Core Operating Limits Report, and (3) deletes an outdated footnote for LCO 3.2.3.

E1-3 to NL-16-1617 Basis for Proposed Change According to 10 CFR 50.92, "Issuance of amendment," paragraph (c), a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

1) Involve a significant increase in the probability or consequences of any accident previously evaluated; or

2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or

3) Involve a significant reduction in a margin of safety.

SNC has evaluated the proposed change, using the criteria in 10 CFR 50.92, and has determined that the proposed change does not involve a significant hazards consideration. The following information is provided to support a finding of no significant hazards consideration.

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change (1) adds a Note to the Surveillance Requirements (SRs) of the Hatch Nuclear Plant (HNP) Unit 1 and Unit 2 Technical Specifications {TS) 3.7.7 clarifying that the SRs are not required to be met when the LCO does not require the Main Turbine Bypass System to be Operable, (2) clarifies that LCO 3.2.3, "LINEAR HEAT GENERATION RATE" also has limits for an inoperable Main Turbine Bypass System that are made applicable as specified in the Core Operating Limits Report, and (3) deletes an outdated footnote for LCO 3.2.3. The proposed change does not affect the requirement to meet the LCO, nor does it affect the requirements to perform the SRs when the Main Turbine Bypass System is being used to meet the LCO. This change simply clarifies the existing allowance to apply the Main Turbine Bypass System inoperable limits to minimum critical power ratio (MCPR) and linear heat generation rate (LHGR) in lieu of the requirement for the Main Turbine Bypass System to be Operable. The current safety analysis evaluation is unaffected by this proposed change. The change regarding the outdated footnote has no effect on the actual TS requirements.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change (1) adds a Note to the Surveillance Requirements (SRs) of the Hatch Nuclear Plant (HNP) Unit 1 and Unit 2 Technical Specifications (TS) 3.7.7 clarifying that the SRs are not required to be met when the LCO does not require the Main Turbine Bypass System to be Operable, (2) clarifies that LCO 3.2.3, "LINEAR HEAT GENERATION RATE" also has limits for an inoperable Main Turbine Bypass System that are made applicable as specified in the Core Operating Limits Report, and (3) deletes an outdated footnote for LCO E1-4 to NL-16-1617 Basis for Proposed Change 3.2.3. This change simply clarifies the existing allowance to apply the Main Turbine Bypass System inoperable limits to minimum critical power ratio (MCPR) and linear heat generation rate (LHGR) in lieu of the requirement for the Main Turbine Bypass System to be Operable.

The change regarding the outdated footnote has no effect on the actual TS requirements.

The current *safety analysis evaluation is unaffected by these proposed changes.

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

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No The proposed change (1) adds a Note to the Surveillance Requirements (SRs) of the Hatch Nuclear Plant (HNP) Unit 1 and Unit 2 Technical Specifications (TS) 3.7.7 clarifying that the SRs are not required to be met when the LCO does not require the Main Turbine Bypass System to be Operable, (2) clarifies that LCO 3.2.3, "LINEAR HEAT GENERATION RATE" also has limits for an inoperable Main Turbine Bypass System that are made applicable as specified in the Core Operating Limits Report, and (3) deletes an outdated footnote for LCO 3.2.3. This change simply clarifies the existing allowance to apply the Main Turbine Bypass System inoperable limits to minimum critical power ratio (MCPR) and linear heat generation rate (LHGR) in lieu of the requirement for the Main Turbine Bypass System to be Operable.

The applicable safety analyses forTS 3.7.7 is unaffected by this clarification. The change regarding the outdated footnote has no effect on the actual TS requirements.

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

Based on the above evaluation, SNC concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92, paragraph (c),

and accordingly, a finding of no significant hazards consideration is justified.

4.3 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or the health and safety of the public.

5. ENVIRONMENTAL CONSIDERATION SNC has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, "Standards for Protection Against Radiation." However, the proposed amendment does not involve: (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions E1-5 to NL-16-1617 Basis for Proposed Change eligible for categorical exclusion or otherwise not requiring environmental review," paragraph (c)(9). Therefore, pursuant to 10 CFR 51.22, paragraph (b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

E1-6

Edwin I. Hatch Nuclear Plant Unit 1 and 2 Request for Addition of Surveillance Requirements Note for LCO 3.7.7 Enclosure 2 Marked-up Technical Specification (TS) and TS Bases Pages

LHGR 3.2 .3 3.2 POWER DISTRIBUTION LIMITS 3.2.3 LINEAR HEAT GENERATION RATE (LHGR) ~

LCO 3.2.3 All LHGRs shall be less than or equal to the limits specified in the COLR.

APPLICABILITY: THERMAL POWER 2:24% RTP .

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Any LHGR not within limits. A.1 Restore LHGR(s) to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months within limits.

B. Required Action and B.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion POWER to< 24% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.3.1 Verify all LHGRs are less than or equal to the Once within limits specified in the COLR. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 2:24% RTP In accordance with the Surveillance Frequency Control Program

This Specification 1s effect1*;e starting from Hatch 1/Cycle 22 HATCH UNIT 1 3.2-4 Amendment No. 266

Main Turbine Bypass System 3.7.7

3. 7 PLANT SYSTEMS 3.7.7 Main Turbine Bypass System LCO 3.7.7 The Main Turbine Bypass System shall be OPERABLE.

OR LCO 3.2.2, "MINIMUM CRITICAL POWER RATIO (MCPR)," and LCO 3.2.3. "LINEAR HEAT GENERATION RATE (LHGR)," limits for an inoperable Main Turbine Bypass System, as specified in the COLR, are made applicable.

APPLICABILITY: THERMAL POWER~ 24% RTP .

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of the LCO A.1 Satisfy the requirements 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months not met. ofthe LCO.

B. Required Action and B.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion POWER to < 24% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS

NOTE----------------------------------------------------

Not required to be met when the Main Turbine Bypass System is not required to be OPERABLE SURVEILLANCE FREQUENCY SR 3.7.7.1 Verify one complete cycle of each main turbine In accordance with bypass valve. the Surveillance Frequency Control Program SR 3.7.7.2 Perform a system functional test. In accordance with the Surveillance Frequency Control Program SR 3.7.7.3 Verify the TURBINE BYPASS SYSTEM In accordance with RESPONSE TIME is within limits. the Surveillance Frequency Control Program HATCH UNIT 1 3.7-18 Amendment No. 266

LHGR 3.2.3 3.2 POWER DISTRIBUTION LIMITS 3.2.3 LINEAR HEAT GENERATION RATE (LHGR)!:

LCO 3.2.3 All LHGRs shall be less than or equal to the limits specified in the COLR.

APPLICABILITY: THERMAL POWER~ 24% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Any LHGR not within limits. A.1 Restore LHGR(s) to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months within limits.

B. Required Action and B.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion POWER to< 24% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.3.1 Verify all LHGRs are less than or equal to the Once within limits specified in the COLR. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after

~24% RTP In accordance with the Surveillance Frequency Control Program

This Specification is effecti>Je starting from Hatch 2/Gycle 19 HATCH UNIT2 3.2-4 Amendment No. 210

Main Turbine Bypass System 3.7.7 3.7 PLANT SYSTEMS 3.7.7 Main Turbine Bypass System LCO 3.7.7 The Main Turbine Bypass System shall be OPERABLE.

OR LCO 3.2.2, "MINIMUM CRITICAL POWER RATIO (MCPR)," and LCO 3.2.3, "LINEAR HEAT GENERATION RATE (LHGR)," limits for an inoperable Main Turbine Bypass System, as specified in the COLR , are made applicable.

APPLICABILITY: THERMAL POWER~ 24% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of the LCO A.1 Satisfy the requirements 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months not met. of the LCO .

B. Required Action and B.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion POWER to< 24% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS

NOTE-----------------------------------------------------

Not required to be met when the Main Turbine Bypass System is not required to be OPERABLE SURVEILLANCE FREQUENCY SR 3.7.7.1 Verify one complete cycle of each main turbine In accordance with bypass valve. the Surveillance Frequency Control Program SR 3.7.7.2 Perform a system functional test. In accordance with the Surveillance Frequency Control Program (continued)

HATCH UNIT2 3.7-18 Amendment No. 210

Main Turbine Bypass System B 3.7.7 BASES (continued)

LCO The Main Turbine Bypass System is required to be OPERABLE to limit peak pressure in the main steam lines and maintain reactor pressure within acceptable limits during events that cause rapid pressurization, so that the Safety Limit MCPR is not exceeded. With the Main Turbine Bypass System inoperable, modifications to the MCPR limits [LCO 3.2.2, "MINIMUM CRITICAL POWER RATIO (MCPR)"] and LHGR limits [LCO 3.2,3. "LINEAR HEAT GENERATION RAJE(LHGR)"] may be applied to allow this LCO to be met. The MCPR and LHGR limit~ for the inoperable Main Turbine Bypass System ts-ar:.e_specified in the COLR. An OPERABLE Main Turbine Bypass System requires the minimum number of bypass valves, specified in the COLR, to open in response to increasing main steam line pressure. This response is within the assumptions of the applicable analysis (Ref. 2).

APPLICABILITY The Main Turbine Bypass System is required to be OPERABLE at

24% RTP to ensure that the fuel cladding integrity Safety Limit and the cladding 1% plastic strain limit are not violated during the feedwater controller failure to maximum flow demand transient. As discussed in the Bases for LCO 3.2.1, "AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)," aRG-LCO 3.2.2, and LCO 3.2.3, sufficient margin to these limits exists at< 24% RTP.

Therefore, these requirements are only necessary when operating at or above this power level.

ACTIONS If the Main Turbine Bypass System is inoperable (e.g., less than the minimum number of bypass valves specified in the COLR are operable), or the MCPR and LHGR limits for an inoperable Main Turbine Bypass System, as specified in the COLR, are not applied, the assumptions of the design basis transient analysis may not be met. Under such circumstances, prompt action should be taken to restore the Main Turbine Bypass System to OPERABLE status or adjust the MCPR limits accordingly. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is reasonable, based on the time to complete the Required Action and the low probability of an event occurring during this period requiring the Main Turbine Bypass System.

If the Main Turbine Bypass System cannot be restored to OPERABLE status or the MCPR limits for an inoperable Main Turbine Bypass System are not applied, THERMAL POWER must be reduced to (continued)

HATCH UNIT 1 B 3.7-35 REVISION 71

Main Turbine Bypass System B 3.7.7 BASES ACTIONS B.1 (continued)

< 24% RTP. As discussed in the Applicability section, operation at

< 24% RTP results in sufficient margin to the required limits, and the Main Turbine Bypass System is not required to protect fuel integrity during the turbine generator load rejection transient. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE The Surveillances are modified by a Note_ttl.at states that the REQUIREMENTS Surveillances are not required to be met when the Main Turbine Bypass System is not required to be OPEBABLE._Wben the Main Turbine Bypass System is not required to be OPERABLE. the MCPR and LHGR limits for an inoperable Main Turbine Bypass System are required to be met. Surveillances for veritving that the MCPR and LHGR limits are met are provided in LCO 3.2.2 and 3.2.3. This Note is necessary since the LCO can be met if the applic_aQI.e_thermallimits are applied . Thus. the SRs for the Main Turbine Bypass System would not be required to be met under this condition SR 3.7.7.1 Cycling each main turbine bypass valve through one complete cycle of full travel demonstrates that the valves are mechanically OPERABLE and will function when required. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.7.2 The Main Turbine Bypass System is required to actuate automatically to perform its design function. This SR demonstrates that, with the required system initiation signals, the valves will actuate to their required position. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.7.3 This SR ensures that the TURBINE BYPASS SYSTEM RESPONSE TIME is in compliance with the assumptions of the appropriate safety analysis. The response time limits are specified in Technical (continued)

HATCH UNIT 1 B 3.7-36 REVISION 69

Main Turbine Bypass System B 3.7.7 BASES (continued)

LCO The Main Turbine Bypass System is required to be OPERABLE to limit peak pressure in the main steam lines and maintain reactor pressure within acceptable limits during events that cause rapid pressurization, so that the Safety Limit MCPR is not exceeded. With the Main Turbine Bypass System inoperable, modifications to the MCPR limits [LCO 3.2.2, "MINIMUM CRITICAL POWER RATIO (MCPR)"] a.n.c!.J,HGR limits fLCO 3.2.3, "LINEAR HEAT GENERATION BATE£LHGR)"l may be applied to allow this LCO to be met. The MCPB and LHGR limit§ for the inoperable Main Turbine Bypass System areis specified in the CO LB. An OPERABLE Main Turbine Bypass System requires the minimum number of bypass valves, specified in the COLA, to open in response to increasing main steam line pressure. This response is within the assumptions of the applicable analysis (Ref. 2).

APPLICABILITY The Main Turbine Bypass System is required to be OPERABLE at

<:: 24% BTP to ensure that the fuel cladding integrity Safety Limit and the cladding 1% plastic strain limit are not violated during the feedwater controller failure to maximum flow demand transient. As discussed in the Bases for LCO 3.2.1, "AVERAGE PLANAR LINEAR HEAT GENERATION BATE (APLHGR)," aOO-LCO 3.2.2, and LCO 3.2.3. sufficient margin to these limits exists at< 24% RTP.

Therefore, these requirements are only necessary when operating at or above this power level.

ACTIONS If the Main Turbine Bypass System is inoperable (e.g., less than the minimum number of bypass valves specified in the COLA are operable), or the MCPR and LHGR limits for an inoperable Main Turbine Bypass System, as specified in the COLR, are not applied, the assumptions of the design basis transient analysis may not be met. Under such circumstances, prompt action should be taken to restore the Main Turbine Bypass System to OPERABLE status or adjust the MCPB limits accordingly. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is reasonable, based on the time to complete the Required Action and the low probability of an event occurring during this period requiring the Main Turbine Bypass System.

If the Main Turbine Bypass System cannot be restored to OPERABLE status or the MCPB limits for an inoperable Main Turbine Bypass System are not applied, THERMAL POWER must be reduced to (continued)

HATCH UNIT2 B 3.7-35 REVISION 42

Main Turbine Bypass System B 3.7.7 BASES ACTIONS B.1 (continued)

< 24% RTP. As discussed in the Applicability section, operation at

< 24% RTP results in sufficient margin to the required limits, and the Main Turbine Bypass System is not required to protect fuel integrity during the turbine generator load rejection transient. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE The Surveillances are modified by a Note that states that the REQUIREMENTS Surveillances are not required to be met when the Main Turbine Bypass System is not required to be OPERABLE. When the Main Turbine Bypass System is not required to be OPERABLE. the MCPR and LHGR limits for an inoperable Main Turbine Bypass System are required to be met. Surveillances for verifying that the MCPA and LHGR limits are met are provided in LCO 3.2.2 and 3.2.3. This Note is necessarv since the LCO can be met if the applicable thermal limits are apolied. Thus. the SRs for the Main Turbine Bypass System would not be required to be met under this condition .

SR 3.7.7.1 Cycling each main turbine bypass valve through one complete cycle of full travel demonstrates that the valves are mechanically OPERABLE and will function when required. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.7.2 The Main Turbine Bypass System is required to actuate automatically to perform its design function. This SR demonstrates that, with the required system initiation signals, the valves will actuate to their required position. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.7.3 This SR ensures that the TURBINE BYPASS SYSTEM RESPONSE TIME is in compliance with the assumptions of the appropriate safety analysis. The response time limits are specified in Technical (continued)

HATCH UNIT2 B 3.7-36 REVISION 79

Edwin I. Hatch Nuclear Plant Unit 1 and 2 Request for Addition of Surveillance Requirements Note for LCO 3.7.7 Enclosure 3 Clean Technical Specification Pages

LHGR 3.2.3 3.2 POWER DISTRIBUTION LIMITS 3.2.3 LINEAR HEAT GENERATION RATE (LHGR)

LCO 3.2.3 All LHGRs shall be less than or equal to the limits specified in the COLR.

APPLICABILITY: THERMAL POWER~ 24% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Any LHGR not within limits. A.1 Restore LHGR(s) to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months within limits.

B. Required Action and B.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion POWER to < 24% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.3.1 Verify all LHGRs are less than or equal to the Once within limits specified in the COLR. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after

~ 24% RTP In accordance with the Surveillance Frequency Control Program HATCH UNIT 1 3.2-4 Amendment No.

Main Turbine Bypass System 3.7.7

3. 7 PLANT SYSTEMS 3.7.7 Main Turbine Bypass System LCO 3.7.7 The Main Turbine Bypass System shall be OPERABLE.

OR LCO 3.2.2, "MINIMUM CRITICAL POWER RATIO (MCPR)," and LCO 3.2.3, "LINEAR HEAT GENERATION RATE (LHGR)," limits for an inoperable Main Turbine Bypass System, as specified in the COLR, are made applicable.

APPLICABILITY: THERMAL POWER~ 24% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of the LCO A.1 Satisfy the requirements 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months not met. of the LCO.

B. Required Action and B.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion POWER to< 24% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS

NOTE------------------------------------------------------------

Not required to be met when the Main Turbine Bypass System is not required to be OPERABLE SURVEILLANCE FREQUENCY SR 3.7.7.1 Verify one complete cycle of each main turbine In accordance with bypass valve. the Surveillance Frequency Control Program SR 3.7.7.2 Perform a system functional test. In accordance with the Surveillance Frequency Control Program SR 3.7.7.3 Verify the TURBINE BYPASS SYSTEM In accordance with RESPONSE TIME is within limits. the Surveillance Frequency Control Program HATCH UNIT 1 3.7-18 Amendment No.

LHGR 3.2.3 3.2 POWER DISTRIBUTION LIMITS 3.2.3 LINEAR HEAT GENERATION RATE (LHGR)

LCO 3.2.3 All LHGRs shall be less than or equal to the limits specified in the COLA.

APPLICABILITY: THERMAL POWER~ 24% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Any LHGR not within limits. A.1 Restore LHGR(s) to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months within limits.

B. Required Action and B.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion POWER to< 24% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.3.1 Verify all LHGRs are less than or equal to the Once within limits specified in the COLA. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after

~ 24% RTP In accordance with the Surveillance Frequency Control Program HATCH UNIT2 3.2-4 Amendment No.

Main Turbine Bypass System 3.7.7

3. 7 PLANT SYSTEMS 3.7.7 Main Turbine Bypass System LCO 3.7.7 The Main Turbine Bypass System shall be OPERABLE.

OR LCO 3.2.2, "MINIMUM CRITICAL POWER RATIO (MCPR)," and LCO 3.2.3, "LINEAR HEAT GENERATION RATE (LHGR)," limits for an inoperable Main Turbine Bypass System, as specified in the COLA, are made applicable.

APPLICABILITY: THERMAL POWER~ 24% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of the LCO A.1 Satisfy the requirements 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months not met. of the LCO.

B. Required Action and B.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion POWER to< 24% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS

NOTE------------------------------------------------------------

Not required to be met when the Main Turbine Bypass System is not required to be OPERABLE SURVEILLANCE FREQUENCY SR 3.7.7.1 Verify one complete cycle of each main turbine In accordance with bypass valve. the Surveillance Frequency Control Program SR 3.7.7.2 Perform a system functional test. In accordance with the Surveillance Frequency Control Program (continued)

HATCH UNIT2 3.7-18 Amendment No.

NL-16-1617, Request for Addition of Surveillance Requirements Note for LCO 3.7.7 (NL-16-1617)

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NL-16-1617, Request for Addition of Surveillance Requirements Note for LCO 3.7.7 (NL-16-1617)

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