View source for HL-2231, Application for Amends to Licenses DPR-57 & NPF-5,proposing to Revise Several Portions of TS Involving Shutdown & Refueling Operations

{{Adams
| number = ML20101S820
| issue date = 07/17/1992
| title = Application for Amends to Licenses DPR-57 & NPF-5,proposing to Revise Several Portions of TS Involving Shutdown & Refueling Operations
| author name = Beckham J
| author affiliation = GEORGIA POWER CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000321, 05000366
| license number = 
| contact person = 
| document report number = HL-2231, NUDOCS 9207200078
| package number = ML20101S823
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 23
| project = 
| stage = Request
}}

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HL-2231 003478 July 17    1992 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 PLANT HATCH - UN!TS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPT-5 REQUEST TO REVISE TECHNICAL SPEClflCATIONS:
                                   'il101LLAN&M.Jf.DKLIRG S P E C 1 F 1 C AT I ON S     ,
Gentlemen:
In accordance with the provisions of 10 CTR 50.90,                    as required by 10 CFR 50.59(c)(1), Georgia Power Company (GPC) hereby proposes changes to the Plant Hatch Units 1 and 2 Technical Specifications (TS), Appendix A to Operating Licenses DPR-57 and NPF-5.
The proposed changes involve revisions to several portions of the Plant Hatch Units 1. and 2 TS involving shutdown and refueling operations. The purpose of these revisions is to clarify existing specifications thereby preventing misinterpretation of requirements and to provide flexibility in shutdown operations by allowing these operations to be performed                                    in different ways. In addition,                   a one time only special test exception is being removed because it is no 1cnger applicable. Also, an index listing is being corrected. GPC requests these proposed changes be reviewed and approved prior to the Fall 1992 Unit 2 refueling outage currently scheduled to begin September 15, 1992.
Enclosure 1 provides a detailed cescciption of the proposed changes and the reasons for the change requcst.
Enclosure 2 details the bases for our determination the proposed changes do not involve a significant hazards consideration.
Enclosure 3 provides page change in:tructions for incorporating the proposed changes. The proposed changed TS pages for Units 1 and 2 follow Enclosure'3. The markup of the proposed changes is also included.
To allow tine for procedure revisions and orderly incorporation into copies of the TS, GPC requests the proposed amendment, once approved by the NRC,       be issued with a required implementation date to be no later tnan 60 l
days from the date of issuance of the amendment.
4207200070 920717 PDR                                                                                    bQ ADOCK 05000321 P                            pyg                                                        g
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* Georgia Power Ac k
U.S. Nuclear Regulatory Commission July 17. 1992 Page Two in accordance with the requirements of 10 CFR 50.91, a copy of this letter and all applicable enclosures will be sent to the designated state official of the Environmental Protection bivision of the Georgia Department of Natural Resources.
J. T. Beckham, Jr. states he is duly authorized to execute this oath on bthalf of Georgia Power Company, and to the best of his knowledge and belief, the f acts set forth in this letter are true.
GEORGIA POWER COMPANY By:   fI J.TWcliham, Jr.
7 Sworn to and subscribed before me this /1 day of            4As   -
1992.
jja Notary      4. Public              /hatn             "
l MCM/cr 003478 Enclosure cc: Georaia Power Company Mr. H. L. Sumner, General Manager - Nuclear Plant NORMS LS. Nuclear Reaulatory Comntission. WashinatonuE Mr. K. Jabbour, Licensing Project Manager - Hatch
                                                                                               ~
U.S. Nuclear Reaulatpry Commission. ReatplL11 Mr. S. D. Ebneter, Regional Administrator Mr. L. D. Wert, Senior Resident Inspector - Hatch S.'. ate of _Georqia Mr. J. D. Tanner, Commissioner - Department of Natural Resources 700775

1 i f I
ENCLOSURE 1                                       i PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES OPR-57, NPT-5                             i REQUEST TO REVISE TECHNICAL SPECIFICATIONS:
tiliffit ANEOUS REFUEllHG SPEClflCATIONS I
BASIS FOR CHANGE RE0VLSJ Since this submittal            involves various changes affecting several different specifications, this discussion will address each individual change separately.              l l
l EB0f0$ED CHANGE 1:
This p opn+ "r.% will revise the definition of Core Alteration in Technical     '
Specifh it W .          1.L     'v Unit I and 1.0 for Unit 2.
1.1) The M 3 mn u!'i specify the movement of incore instruments, (source range mon > tors, local power range monitors, intermediato range monitors, traversing in-core probes, or special movable detectors), including                 ,
undervessel      replacement of -there items,         is not considered a Cve       '
Alteration.
1.2) The phrase " addition, removal, relocation, or movement" is being replaced with the word " movement."
1.3)_ The phrase "or other components affecting reactivity" is being added.
BASIS FOR' PROPOSED CHANGE 1:
1.1) The purpose of the definition of Core Alterations is to                    identify operations which have the potential for adding positive reactivity to the core while the vessel head is removed and fuel is in the vessel. While              ,
such -operations are in progress, special precautions must be taken to preclude the possibility of an_ inadvertent criticality. These precautions are comprised mainly of additional safety system operability requirements.
Incore instruments are being excluded from this definition because-the amount of fissile material contained in the detectors is so small their movement does not result in any significant change in core reactivity.              '
Therefore, movement of incore instruments does not involve an increase in the probability of an inadvertent criticality and no s>ecial precautions are needed to preclude such an event.                Removing tie requirement to.
maintain operability of-additional safet) systems during incore instrument movement will provide a great deal of flexibility to the outage planning process.      Systems which were previously required to be operable during 003478 HL-2231                                     El-1

(
f          f ENCLO5URE 1 (Continued)
MISCELLANE9US RFFUELING SPECIf1 CAT 10tti BMilS_f0R CHANGE RE0 VEST incore instrument movement can now be made inoperable to perform required surveillance testing or preventative maintenance.
1.2)   Listing the specific types of " movement" is unnecessary. Removal of the redundant words " addition", " removal", and " relocation" has no impact on the meaning of the definition.
1.3) Addition of the new phrase "or other components affecting reactivity" will key 15 users into considering how a new incore operation may impact core reactivity.-
PROPOSED C8tANGE 2:
This proposed change will revise the definitions of Cold Shutdown Condition and Refuel Mode in Unit 1 TS :section 1.0, and the Operational Conditions Table 1.2 in Unit 2 TS.
2.1) The definition of Cold Shutdown Condition in Unit 1 TS will allow 'he mode switch to be placed in REFUEL per nawly proposed Specification 3.10.E.3.
2.2) The definition of Refuel Mode in Unit 1 TS will specify the head closure bolts are less than fully tensioned or the head is removed, and the mode switch may be in Shutdown or Refuel.
2.3)   In . Unit 2- Table 1.2, t' e existing footnote designated as "*" to Condition 5 will be relabeled as footnote "a" and will be applicable to all conditions. This footnote will specify in Conditions-1 through 4 the reactor; vessel head closure bolts are fully tensioned and in Condition 5 the head closure bolts are less than fully tensioned or the head is removed.
2.4)..In Unit 2 Table 1.2, " Shutdown" will be added as an allowable mode switch position for Condition 5.
2.5)   In Unit-2 Table 1.2, a new footnote, designated as       "d", will be added to allow the mode switch to be placed in Refuel              per- newly proposed Spect fication 3.10.5.
003478 HL-2231                                 El-2 p

t 8 ENCLOSURE 1 (Continued) tilSCELLAtEQUS REFUELING SPECIFICATIONS PA51S FOR CHANCE RE0 VEST BASIS FOR PROPOSED CHANGE 2:
2.1) 1he addition of this allowance is necessary to allow moving a single control rod / drive in the Cold shutdown condition (see proposed change 5 on page 7 of this enclosure).
.       2.2) This rewording will                         specify the condition of the head closure bolts corresponding to the Refuel Mode to remove any uncertainty as to exactly when the Reactor Mode changes. This will help ensure the operability requirements of the existing mode are met.
The sequence of events for entering the Refuel Mode should be as follows:
The reactor is shut down and cooled until the Cold Shutdown condition is reached. The mode switch is in Shutdown.
When the first head closure bolt is detensioned, the reactor will be in the Refuel Mode per the proposed definition of Refuel Mode.
                -    At that point, the control room operator will be notified the head closure bolts are no longer fully tensioned,                    and the mode switch may be placed in Refuel.
lhe addition of Shutdown as an allowable mode switch position for the Refuel Mode will preclude confusion by ensuring no undefined condition is entered during the normal evolution of entering the Refuel Mode. Having the mode switch in Shutdown ender these conditions will represent no reduction in safety for thL following reasons:
: 1) The reactor manual                      control   system interlocks associated with the Shutdown position are more restrictive than those                       for the Refuel position.                   Specifically, with the mode switch in the Refuel position, the one-rod-out interlock allows no more than one control rod to be withdrawn at a time. However, with the mode switch in the Shutdown position, a rod block is enforced at all times so that no control rods may be withurawn.
: 2) Specification 3.10.A.1 (Specification 3.9.1 for Unit 2) requires the mode switch to be locked in the Refuel position with the refueling interlocks operrble during Core Alterations.
003478 HL-2231                                                 El-3

t ENCLOSURE 1 (Continued)                               ,
MISCELLANE@S REFUELING SPECIFICATIONS RA_11S FOR CHANGE RE00EST 2.3)   See the above discussion for the first part of change 2.2.
2.4)   See the above discussion for the second part of change 2.2.
2.5)   The addition of this footnote is necessary to facilitate use of the new Specification 3.10.5. Revision of this section is identified later as part of Proposed Change 5. Thejustification for Proposed Change 5
* applies to the addition _of this footnote.
PROPOSED CHANGE 3:
This proposed change will revise the action statement for the residual heat removal    service water (RHRSW) syste'n shutdown cooling mode in Unit 2 Specification 3.7.1.1.
.      Existing Unit 2 Specification.3.7.1.1.b provides actions for inoperability of RHRSW    pumps and/or subsystems required to support RHR shutdown cooling subsystems. However, this specification is written such that actions will be overly conservative in some situations and inadequate in other situations. This change-will tie operability of an RHRSW subsystem directly to the operability of     ;
the RHR shutdown cooling subsystem which it supports. In addition, this specification will state only one RHRSW pump must be operable in order to consider the RHR5W subsystem operable.
EASIS FOR PROPOSED CHANGE 3:
The. design of the liatch RHRSW system includes two separate RHRSW subsystems A and B, supporting RHR subsystems A and B respectively. Each RHRSW subsystem is
     -comprised ~ of two RHRSW pumps,. a flowpath and a heat exchanger for transferring heat from the associated RHR subsystem. RHRSW subsystem A contains RHRSW pumps-A and C, and RHRSW subsystem B contains RHRSW pumps B and D. An additional feature is the ability to crosstie the RHRSW subsystems such that the pumps in one RHRSW subsystem can_ provide flow through the heat exchanger in the other RHRSW subsystem and thereby_ support the opposite RHR subsystem.              In the following discussions,-no credit is taken for this crosstie feature because
      'there; are .no operability requirements for this equipment.       However, if the crosstie feature is operable and is being used to supply RHRSW flow to support the opposite loop of RHR-in shutdown cooling, there is no need to declare the supported RHR loop inoperable for shutdown cooling because the function is teing successfully performed.
     .003478 Hi.-2231                               El-4

1 i
r ENCLOSURE 1 (Continued)                                   )
MISCELLANE0US REFUELING SPECIFICATIONS BASIS FOR CHANGE RE0VESI                                  i The existing Unit 2 Action Statement 3.7.1.1.b specifies 3ctions to be taken in Condition 5 for certain situations involving RHRSW inoperability. The action statement requires RHR shutdown cooling to be declared inoperable if up to three RHRSW pumps or one RHRSW subsystem te inoperable for greater than 7 days.
These actions are inappropriate for the following reasons.
The first problem with the current specification is the lack of required actions for situations which are moro degraded than the ones specified. This would be the case if four RHRSW pumps or both RHRSW subsystems were inoperable.
Generally, Specification 3.0.3 provides direction under circumstances which exceed those detailed in the TS. However, 9pecification 3.0.3 requires unit shutdown    assuming the subject situation occurs               during power operation.
Therefore, Specification 3.0.3 does not apply in Condition 5.              The proposed wording of this specification will alleviate this problem because it will define RHRSW subsystem operability and will delineate actions to be taken if a subsystem is inoperable. If both RHRSW subsystems are inoperable, then both RHR subsystems will be declared inoperable for shutdown cooling.            This is the most degraded situation possible.
The second problem with the current specification is the fact that inoperability of one RHRSW subsystem for greater than 7 days requires the shutdown cooling mode    of both RHR subsystems         to be declared inoperable.           Under these circumstances,   the RHR and RHRSW subsystems opposite to the inoperable RHRSW subsyster, may both be operable and fully capable of performing the required shutdown cooling function.- The proposed specification will link RHRSW subsystem operability directly to operability of the associated RHR subsystem.
The . third problem with this requirement is the inclusion of a time period (7 days) during which the RHRSW pumps or subsystem can be inoperable without declaring RHR shutdown cooling inoperable. If the RHRSW subsystem is incapable of -removing decay heat from the RHR subsystem, then the RHR subsystem is incapable- of removing decay heat from the core and must be declared . inoperable immediately. An allowable outage time for shutdown cooling is inappropriate because the reactor coolant begins to heat up immediately upon loss of shutdown cooling. The proposed specification will include no grace period. When an RHRSW subsystem is declared inoperable, the associated RHR subsystem will be considered inoperable for shutdown cooling immediately.
The fourth problem with this specification is the wording of the restoration requirement. The requirement states, "...,      restore both subsystems with at least one pump in each system to OPERABLE status... ." This implies only one operable pump is required for the subsystem to be considered operable. This conflicts with the definition of an operable subsystem as specified in the LC0 section of the specification.      However, Specification 3.9.12 for RHR shutdown 003478 HL-2231                                El-5

i
                                 -ENCLOSURE 1 (Continued)
MISCELLANE0US REFUELING SPECIFICAT10 tis BASIS FOR CHANGE REQUESI cooltng supports this interpretation because it states only one RHR pump and one RHR heat exchanger are required to be operable in order to consider the RHR system operable for shutdown cooling.       Therefore, it follows the RHRSW system would be capable of supporting the shutdown cooling function of the RHR system if-it contained one operable RHRSW pump and flowpath in the subsystem corresponding to the o>erable RHR pump. A sentence is being added to Action St1tement 3.7.1.1.b w11ch states one RHRSW pump may be              inoperable without declaring the RHRSW subsystem inoperable.
PROPOSED CHANGE 4:
This proposed change will alter the wording of Unit 2 Specification 3.9.3. This specification currently requires all control rods to be fully          inserted during Core Alterations. The proposed change will require all control rods to be fully inserted when moving fuel assemblies or startup sources in the core, rather than during all Core Alterations.
This' proposed change will also revise the wording of the bases for Specification 3.9.3. The phrase "during CORE ALTERATIONS" is being replaced with the phrase _"during fuel or startup source movement."
    }} ASIS FOR PROPOSED CHANGE 4:
Specification 3.9.3 is being revised because it is self-contradicting. Per the definition of CORE ALTERATION in TS Section 1.0, movement of reactivity controls within' the reactor pressure vessel with the vessel head removed and fuel in the vessel is considered a Core Alteration. Since a control rod is a reactivity control, movement of a control rod under . the above circumstances would qualify as a Core Alteration. Therefore, upon commencement of control rod withdrawal, Core Alterations would begin, and simultaneously all control rods would no longer be fully. inserted.       Taking this literally would result in conditions which violate Specification 3.9.3.
When the vessel head is removed, the reactor mode switch will be in either Refuel or_ Shutdown. In Refuel, the one-rod-out interlock prevents more than one control rod from being withdrawn at a time. In Shutdown, a control rod block is in effect at.all times preventing the withdrawal       of even a single control rod.
Since Specification 3.1.l', Shutdown Margin, requires the core to be subcritical by at least .38% delta k/k at all . times with the highest worth control rod withdrawn,- the above mode switch interlocks'will ensure the reactor does not become critical. Therefore it is acceptable to allow control rod withdrawal as         .
long as no other Core Alterations are taking place.
003478 HL-2231-                              El-6

e i
h L                                                            ENCLOSURE 1 (Continued) tilSCELL ANEOUS REFUELING SPECIFICATIONS -
BASIS FOR CHANGE RE0 VEST The< operations which are being specified have the potential-for adding positive reactivity to.the core. The proposed change would specif.y the Core Alterations of concern such that no positive reactivity additions could occur unless all L                           control rods are fully inserted. This will ensure no unplanned criticality occurs.
The: discussion.of Specification 3.9.3 contained in the bases section is not 1being changed.. Only the wording is being changed to match-the wording of the                         !*
specification.-
.y                                                                                                                              ;
                          -PROPOSED CHANGE J:-                                                                                -;
This proposed change will add new Unit 1 Specification-3.10.E.3, "Requirerents                    -
Lfor Withdrawal of a Control Rod in the Cold Shutdown Condition" and new Unit 2
                          ' Specification 3.10.5, " Single Control Rod Withdrawal - Cold-Shutdown", which                        .
will; permit the withdrawal of a single control rod for testing while in Cold
                       ; Shutdown (Unit 2_ Mode 4) by imposing certain restrictions.                                            ;
2in : addition, this-proposed change will-add bases for these new specifications-for both units and will include:a reference to new Unit 2. Specification 3.10.5                   ;
tand .its bases-in the Unit-2 index. The current Unit 2 Specification 3.10.5.                         a "High- Pressure Coolant Injection : System ". is being deleted along with its                     i listing.-in the index.        Also,-the title of Unit 2 .. Specification 3/4 10.2 was             :
changed byi Amendment. 121 from " Rod Sequence Control System" to " Rod Worth.
                       -Minimizer," .but the corresponding'index listing was not changed. This listing                          .
.                             is now being corrected.-                                                                        .j
                                                                                                                               )
BASIS FOR PROPOSED CHANGE 5:
t Currently,. in! Cold. Shutdown, the reactor mode switch is in th'e Shutdown i
                        - position, D and all contro1 > rods are inserted and blocked.from withdrawal. Many                     .
systems 'and functions are not. required in these conditions due to the installed                1 interlocks associated with the reactor mode switch ;in the Shutdown position.                     :
            ,                Circum' stances'will arise while in Cold Shutdown,-.however, which present the need:
                          !to withdraw' a single control rod for various tests (e.g., friction tests,
                                                                                                                               ~
control-rod timing, and coupling integrity chccks). Certain situations may also-require the removal of a control rod drive -(CRD). This proposed change would                    .
a llow single.- control -rod withdrawals and possible subsequent removals by
                        -selecting the Refuel position for the reactor mode switch.
L   '
                       ;003478 HL-2231                                   El-7                                                     '
f 4 .     -m             w.._-.--.                                              _-..._,__.__%..,     _ , . _ _ . .

y i:
A
* ENCLOSURE I (Continued)
MISLELLANEOUS REFUEljNG SPECIFICATIONS BASIS FOR CHANGE RE0VE11 With; the reactor mode switch in the Refuel position, the analyses for control rod withdrawal during refueling are applicable ar.d. provided the assumations of these analyses are satisfied in Cold Shutdown, these analyses will :ound the consequences of a postulated accident. Explicit safety analyses in the FSAR (Section 15.1.13) demonstrate the functioning of the refueling interlocks and adequate Shutdown Margin (SDM) will preclude unacceptable reactivity excursions.
                    ' Meeting. the requirements of the following LCOs will provide the same protection
                 - against inadvertent criticality which normally exists in the Refuel mode:
FUNCTION    .
Ml_].CQ       U2 LCO-
                .One-rod-out interlock.                                   3.10.A.1      3.9.1 Control rod position indication.                     NA            3.1.3.7 RPS instrumentation                                  Table 3.1-1   Table 3.3.1-1 Mode' switch in SHUTDOWN                              Scram 1       Function 11' Manual scram                                          Scram 2-      Function 12 IRM high-high flux                                   Scram 3       Function 1.a IRM inoperative-                                     Scram 3       Function 1.b
                      - APRM 151 flux                                        Scram 8       Function 2.a APRM' inoperative ..          .
Scram S       Function 2.d Electric. power _ monitoring for RPS                 3.9.D         3.8.2.7 Control rod-operability-                             3.3           3.1.3.1
:ShutdownLmargin 3.3.A         3.1.1
                  .._operationa interlocks- restrict the movement of control rods to reinforce Refueling l procedures which prevent the reactor _ from becoming critical. These
: interlocks prevent the withdrawal of more than 'one: control rod. Under these conditions, since only one control. rod can be withdrawn, the core will always be subcritical even with the' highest: worth control rod withdrawn since adequate SDH-    ;
                ? exists. LAt'the time CRD: removal-begins, thi disconnection of the position indication ~ probe will      cause the control      rod position indication LCO and, therefore, the one-rod-out interlock LCO, to fail-to be met.           At this time, a control . rod withdrawal block will be inserted to ensure no additional control rods ca'n be withdrawn and compliance with this proposed LCO is maintained.
The controlfrod scram function provides backup protection to normal refueling
    ;            -procedures anJ the: refueling interlocks (or the inserted control rod withdrawal
                ' block) Lwhich prevent inadvertent criticalities during refueling. Alternate i backup. p_rotection can be obtained by assuring a'five-by-five array of control-          ,
rods, Lcentered on the withdrawn control rod, are inserted and_ incapable of
                -withdrawal.          This alternate backup protection is required when removing a CRD because this removal renders the wi+hdrawn control rod incapable of being scrammed.
4 003478-
                >HL-2231                                      El-8

ENCLOSURE 1 (Continued)
MISCELLANEOUS RETUELING f ECIFICATIONS                                     i BASIS FOR CHANGE RE0VE11 If one or more of the referenced LCOs or requirements of this proposed LC0 are not met with the'affected control rod insertable, Action 1 restores operation                      !
consistent with normal Cold Shutdown conditions (i.e., all rods inserted and the
                . reactor. mode switch in_the Shutdowr position).                                                     1
: Required Action 1 is specified based on the assumption the control rod is being                     I
                 . withdrawn. .If the control. rod is still insertable. the action requires the-control- rod be inserted and the reactor mode switch placed in the Shutdown                       a
                 ' position. The -1 hour completion time for Action 1 provides sufficient time to
                -ncrmally-insert the control rods.
                                                                                                                     .)
                 ,1f':one-or more o.f the referenced LCOs or requirements of this proposed LCO are not' .tiet with the affected control rod not insertable, withdrawal of the control I
rod and removal of the associated CRD must be immediately suspended._ If the CRD                   !
hasL been removed 'such that the control rod is not insertable, the action requires the most expeditious action be taken to either restore the CRD and                        i insert its control _ rod, or restore compliance with this proposed LCO.                             !
                                                                                                                     =i The -other LCOs made applicable by this proposed LC0 are required to have the.                      !
aaplicable portions of-their associated surveillances met in order to . assure                    3 t11s proposed LC0'is being met. If the local array of control rods is inserted                     i e        and -disarmed while the scram function for the withdrawn' rod is not available, i
                 . periodic verification is- required to ensure the_ipossibility of criticality                       ,
remains precluded. Also, all the control             rods are verified to be inserted as           1 well     as. the r control' rod withdrawal block.       Verification that. all.the other            4 control' 1 rods; are fully inserted is required : to meet the SDM rec uirements.
Verification-_that a control rod withdrawal _. block has been insertet provides assurance that those control rods whose ' position indication instrumentation is'-                 >
inoperable are fully inserted.          The 24 hour -frequency i: acceptable because of-           ;
the- administrative-controls on-control rod withdrawals,,the protection afforded                   *
                - by 'the LCOs : involved, and hardwire interlocks _to. preclude an additionaltcontrol rod withdrawal.
The bases :being added will briefly explain' the purpose of these proposed
: specifications and how they will ensure an inadvertent criticality is prevented.-                   !
cThe current Specification 3.10.5.."High Pressure Coolant _ Injection System," is.                     ;
                 'being deleted along with-its listing in the index. This' specification includes                      '
                 -a footnote which states it is only applicab1_e from June 2-9, 1980. Since this time. period has elapsed,;this specification is no longer applicable and may be 7         Ld eleted.-
The : change l to the index _ listing-of -Specification 3/4 10.2 is strictly.an Jeditorial correction.
J 003478
                . HL-2231 -                                  El-9 ww
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ENCLOSURE 2 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:
,                                  MISCELLANEOUS REFUELING SPECIFICATIONS                                                      s 10 CFR 50.92 EVALVATION The Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists.                    A proposed amendment to an-operating license for a facility involves no significant hazards consideration                                        '
if operation of the facility in accordance with the proposed amendcent would not: (1) involve a-significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind -if accident. from any accident previously evaluated, or (3) involve a signif cant reduction in a margin of safety. Georgia Power Company has reviewed this proposed license amendment request and determined its adoption would not involvo a significant hazards consideration. The bases for this determination are de, ailed below.
Since this submittal        involves various changes affecting several different specif1 cations, this discussion will address each individual change separately.
_ jLujj for Prooosed No Sianificant Hazards Consideration Determination:
PROPOSED CHANGE 1:
This proposed change will revise the definition of Core Alteration in Technical Specifications (TS) 1.C for Unit I and 1.0 for Unit 2.
1.1) _The definition will specify the- movement of incore instruments, (source range monitors, local power range monitors, intermediate range monitors, traversing in-core probes, or special movable detectors), including undervessel     replacement of these items, is not considered a Core Alteration, 1.2) 1he phrase " addition, removal, relocation, or movement" is being replaced with the word " movement."
1.3) The phrase'"or other components affecting reactivity" is being added.
    ~
EVALUATION OF PROPOSED CHANGE 1:
1.A) The proposed mendment does not involve a signifit et increase in the probability or consequences of an accident previously evaluated.
003478-HL-2231                                E2-1
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v                                                                    ENCLOSURE 2 (Continued)                                                                      ;
p                                                                                                                                                                ;
c c
MISCELLANE0US REFUEllhG SPECIFICATIONS                                                              -
10 CFR 50.92 EVALUATION                                                                     ;
t
                             'The purpose of . the definition of Core Alterations is to identify o)erations which have the potential for adding reactivity to the core                                                          .
wille the vessel head is removed and fuel is in the vessei. While such                                                         !
o)erations are'in progress, special precautions must be taken to preclude                                                     '
tle . possibility of an inadvertent criticality. These precautions are-comprised mainly of additional safety-system operability requirements.                                                         1 The Hatch-Units 1 and 2 Final Safety Analysis Reports (FSARs) contain
'~
analyses -: for the-following refueling accidents- involving the possibility  -
1 of an' inadvertent criticality:                                                                                                 !
                                -*     Control Rod Removal Frror During Refueling                                                                               '
                                  - Unit 1-FSAR section.14.3.3.3 Unit:2 FSAR section 15.1.13-
                                  *! _ Fuel- Assembly Insertion Error During' Refueling
                                  - Unit 1:FSAR'section~14.3.3.4
                                  -- Unit 2:FSAR section 15.1.14 3
(                      The . movement'of incore instruments does not- apply to either of these analyses.because-the amount of fissile matorial contained in the detectors is so small their movement does - not. result-in any significant change in
      >                                                                                                                                                        1 core--reactivity.              -Therefore, removal of incore - instruments from the
*                            ' definition-Edoes not= involve.an* increase in the probability of occurrence L                                 or consequences of an inadvertent criticality accident.
<                                 Removal -- of the: redundant - words " addition",- " removal", 'and. " relocation"'
                             -from' the definition has no : impact on -the' meaning of the definition.
Therefore, there ._is no. impact.~ on the probability of occurrence or consequences of.any-type of accident.
                             ~ Addition of the new phrase "or other components affecting reactivitr will-key: TS users'into.considering:how a new incore' operation may impact core
                                ' reactivity        .       Since this change < concerns operations which. have not-been identified, there can,be. no effect on' previously evaluated accidents..
                              'Therefore, this change does. not involve a significant increase in the
                             - probability or consequences'of an accident previously evaluated.
1003478                                                                                                                                 .
HL-2231-                                                  E2-2
              ~C
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ENCLOSURE 2 (Continued) tilSCELLANE0QS_REEUEllNG SPECIFICATIONS t
10 CFR 50.92 EVALUATION 1.8) The_ proposed amendment does not create the possibility of a new or                i different kind of accident from any accident previously evaluated.
The amount of fissile material contained in incore instruments is so small their movement does not- result in any significant change            in core reactivity. Therefore, this type operation could not cause~an inadvertent criticality.
Removal of the redundant words " addition", " removal",     and " relocation" from the definition has no impact on the meaning of the definition.
Therefore, there is no impact on the probability of occurrence or consequences of any type of accident.
Addition of the new phrase "or other components affecting reactivity" will-key TS users into considering how a new incore operation may impact core reactivity. This change could only reduce the probability of occurrence of a new type accident by alerting the TS user to be aware of how new operations may affect core reactivity.
Therefore,   this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
1.C) The -proposed amendment does not involve a significant reduction in the
              'argin of safety.
Since the definition of Core Alteration has no impact on any safety limit or limiting safety system setting, this change has no effect on the margin of safety. Therefore,     this. change does not involve a significant
             ' reduction.in the margin of safety.                                              .
PROPOSED CHANGE 2:                                                                      :
This. proposed change will revise the definitions of-Cold Shutdown Condition and Refuel Mode in Unit-1 TS section 1.0, and the Operational Conditions Table 1.2 in Unit 2 TS.
2.1)- The definition of Cold Shutdown Condition in Unit 1 TS will allow the mode switch to be placed in Refuel per newly proposed Specification 3.10.E.3.
2.2) The definition of Refuel Mode in Unit i TS will specify the head alosure bolts .are less than fully tensioned or the head is removed, and the mode switch may be in Shutdown or Refuel.
003478 HL-2231                                 E2-3

ENCLOSURE 2 (Continued)
MISCEtt At4E0VS REFUEQ(LWilfl{AllQl{S
: 10. GL 50.92 EValVAT104 2.3)     In Unit 2 Table       1.2,   tha existing footnote designated as       "+"  to Condition 5 will be relabeled as footnote "a" and will be applicable to all Conditions. This footr.ute will specify in conditions 1 through 4 the reactor vessel head closure bolts are fully tensioned and in Ccndition 5 the head closure bolts are less than fully tensioned or the head is removed.
7.4)     In Unit 2 Table 1.2 " Shutdown" will be added as an allowable mode switch position for Condition 5.
7.5)     In Unit 2 Table 1.2, a new footnote, designated as "d", will be added to allow the mode switch to be placed in Refuel             per newly proposed Specification 3.10.5.
{ybl.1)AILQN OF PROPOSED _ CHANGE 2:
Allowing the mode switch to be placed in Refuel while in the Cold Shutdown condition is necessary to facilitate use of the new Specifications 3.10.E.3 in Unit I and 3.10.5 in Unit 2. 1hese new sections are discussed later as part of Proposed Change 5.        The evaluation for Pro)osed Change 5 applier t.o the addition of this allowance.        Pleas see page 8 of tais encicsure.
2.A) The oroposed amendment does not involve a significant increase in the proba'llity a     or consequences of an accident previously evaluated.
Specifying the reactor mcde based on the conditiot of the vessel head closure . bolts only serves to clarify exactly when certain modes are entered. This change will prevent confusion as to the ap)1icability of certain requiremt.its. This change will have no effect on tie probability of occurrence or consequences of ary type of accident.
The addition of Sh,.tdown as an allowable mode switt.h position for the Refuel Mode will preclude confmloa by ensuring no undefined condition is entered during the normal evolution of entering the Refuel Mode. Having the mode switch in Shutdown under these conditions will not increase the probability of occurrence nr consequences of an accident for the following reasons:
: 1) The reactor manual        control  system interlocks associated with the Shutdown position are more restrictive than those for the Refuel position. Specifically, with the modo switch in the Refuel position 003478 HL-2251'                                 E2-4                                          !

4 I
ENCLOSURE 2 (Continued)
M151[LLANE0VS_ REFUELING SPECIFICATlMS 10 CFR 50.92 EVALUATION t
the one-rod-out interlock allows no more than one control rod to be withdrawn at a time. However, with the modo switch in the Shutdown position a rod block is enforced at all times so that no control rods may be withdrawn.
: 2) Specification 3.10. A.1 (Specification 3.9.1 for Unit 2 requires the                                   t mode switch to be locked in the Refuel position with )the refueling                                  i interlocks operable ouring Core Alterations..
Therefore,    allowing the mode switch to be in the Shutdown position while in the Refuel mode will provide           for conditions which are at least as conservative as the conditions assumed in the accident analyses conc 9rr.ing the possibility of inadvertent criticality during refueling. Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.B) The proposed amendment does not create the possibi'ity of a new or different kind of accident from any accident previously evaluated.
Changing-    operational mode definitions will                 only         serve to clarify requirements and avoid confusion during modo changes. This change will                                    f not' affect existing operations or create any new modes of operation of any safe ty sytems. Therefore, this change does not create the possibility of                                 '
                                          .a   new or different kind of accident from any accident previously evaluated.
2.C) The . proposed amendment does not involve.a significant reduction in the marg;n ofesafety.
The proposed changes to the operational modo definitions will only enhance clarity.'    It will be easier for the TS user to determine when the reactor mode . changes and which set of operability requirements are in effect.
Some of these operability requirements concern limiting safety systems and therefore,' safety limits. By simpilfying identification of the current' reactor mode, the TS user will bo able to more easily determine limiting safety system optrability requirements. Therefore, it is more likely the                                  "
appropriate equipment will be operable and capable of fulfilling its safety function to prevent exceeding any safety liu.its. Therefore, this                                 '
change.does not involve a significant reduction in the margin of safety, n                                                                                                                                                    .
P 003478 HL-2231.                                            E2-5
                                                                                         . . . _ , . . . ~ . . , _ . .   . . - . , _ . . ~ - . ,
                                                                                                                                                 .m ,

ENCL 0SURE 2 (Continued) tRKLLLM100S REFUELINLSELU11. MUMS 19 CFR 50.92 lyALVAUp3 ER0f0FJLC1L@Kl:
This proposed change will        revise the action statement for the residual heat removal     service water (RHRSW)        system shutdown cooling   mode in Unit 2 Specification 3.7.1.1.
Existing Unit 2 Specification 3.7.1.1.b provides actions for inoperability af RHRSW     pumps and/or subsystems required to support RilR shutdown cooling subsystems.      However, this sN cification is written such that actions will be overly conservative in some situations and inadequate in other situations. This change will tie operability of a residual heat removal (RHR) shutdown cooling subsystem directly to the operabiP'" of the RHRSW subsyttem which is used to                            ,
support it. The only RHRSW subsystems which will be required to be operable will be those needed to support operable RHR shutdown cooling subsystems. In addition,    this specification will state only one RHRSW pump must be operable in order to consider the RHRSW subsystem operable.
[YALVATION OF pR0EQSED CMNGE 3:
3.A) The proposed amendment does not involve a significant increase in the                              i probability or consequences of an accident previously evaluated.                                 ;
The pur ose of the RHRSW system is to remove decay heat from the RHR system witch isay be opera +ing in one of several different modes. The mode of concern for Unit 2 Specification 3.7.1.1.b is the shutdown cooling mode in- which the RHR and RHRSW systems remove decay heat from the primary coolant to reduce and maintain the coolant tenperature below 2120F.
Unit 2 Specification 3.9.12 covers operability requirements for RHR in the
            -shutdown cooling modo.          The proposed requirements for RHRSW in the                       -
shutdown cooling mode. will ensure operability of an RHRSW subsystem capable of supporting operation of the RHR subsystem which satisfies the requirements of Specification 3.9.12. Since the RHR shutdown cooling.
specification serves to preclude a loss of shutdown cooling, and the proposed RHRSW specification will          serve to ensuio RHR is capable of performing this function, then the ) reposed change will not involve a significant     increase in the proba)ility of an accident previously evaluated. The shutdown cooling mode of RHR has not effect on- the consequences of any type accident.
3.8) The' proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
l i     003478 L
HL-2231                                  E2-6 i                                                                                                             1

ENCLOSURE 2 (Continued)
MISCELLANEOUS REFULL114G SPECIFIC 6110fd 10 CFR 50.92 EVALUAllM i                             A: dated above, the RHR system performs the shutdown cooling function and the RHRSW system supports the RHR system.                This change will ensure the availability of the RHRSW system to perform this support function. This
                               . change will introduce no new operational modes of the RHR or RHRSW systems. -Therefore, this change does not crea a the possibility of a new or different kind of accident from any accident previnusly evaluated.
3.C) The proposed amendment does not involve a significant reduction in the margin of safety.
No *afety limits or limiting safety sy' tem settings are affected by the shutdown cooling function of the RHR sys W) or the supporting function of the RHRSW system. Therefore, this change does not involve a sienificant reduction in the margin of safety.
PROPOSER _GMGLA:
This proposed change will . alter the wording of Unit 2 S >ecification 3.9.3. This specification currently requires all control              rods to ae fully inserted during Core Alteratttsas. The proposed change will require all control rods to be fully inserted when moving fuel assemblies or startup sources in the core, rather than during all Core Alterations.
                   *ihis           proposed change will also revise the wording of the bases for Specification 3.9.3. 1he phrase "during CORE ALTERATIONS" i: being replaced with the phrase "during fuel or startup source movement."
EVALUATION QE PROPOSED CHANGE f:
I 4.A) The proposed amendment does not involve a significent increase in the probability or consequences of sn accident previously evaluated.
This specification is being reworded to eliminate the self-contradictory nature of literal compliance with its present wording.                                       This new wording will   not change the intant of the specification which is preclusion of an inadvertent criticality during refueling.                   Unit 2 FSAR section 15.1.14 dis:usses a fuel assembly insertion error during refueling. This event involves loading a fuel assembly in an incorrect location with all control roos fully inserted and concludes no inadvertent criticality will occur.
003478 HL-2231                                      E2-7                                                                           .
1

l ENCLOSURE 2 (Continued) tilEEt t ANE0VS RE FUEllM_ SPEC I F IC AT I ONS 1Q_CFR 50.92 EVALUATION I
The proposed wording of the specification will ensure the assumption that all rods are fully inserted is still valid during all fuel loading, further assurance will be provided by Spec' ';ation 3.9.1 which requires the reactor mode switch to be operable and            socked in the Refuel position with the refueling interlocks operable during all Core Alterations. In                                                             ;
the Refuel mode, the refueling interlocks will prevent movement of the refueling bridge over the core if the fuel grapple is loaded with a fuel bundle and any control rod is not fully inserted.
Since the proposed specification will continue to ensure the FSAR accident analysis assum)tions are valid, this change does not involve a significant incrense in tie probability or consequences of an accident previously evaluated.
4.B) The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
This change does not affect the intent of the specification. No new modes of operation will result.              Therefore, this change does not create the possibility of a 'new or different kind of accident from any accident previously evaluated.                                                                                                              '
4.C) The proposed amendment does not involve a significant reduction in the margin.of safety.
No' safety limits or limiting safety system settings are affected by Core
* Alterations--or any other refueling activities.              Therefore,                                          this change does not involve a significant reduction in the margin of safety.
PROPOSfp CHANGE 5:-
This -proposed change will add new Unit 1 Specification 3.10.E.3, "Pequirements for' Withdrawal of a Control Rod in the Cola Shutdown Condition" and new Unit 2 Specification : 3.10.5, :" Single Control Rod Withdrawal - Cold-Shutdown". which permit the withdrawal-of a single control rod for testing while in Cold
                                                                                                                          ~
will Shutdown (Unit 2 Mode 4)=by. imposing certain restrictions.
003478
      .lil-2231                                     E2-8

                                               ~~.-(-a   -~_--.;            .  .    -  .          .-.
1 ENCLOSURE 2 (Continued)
M1SCELLANE005 REFUELING. SPECIFICATIONS 10 CFR 50.92 EVALUATION In addition, this proposed change will add bases for these new specifications                      '
for both units and will include a reference to new Unit 2 Specification 3.10.5                      '
in'the Unit 2 index.
The current Unit 2 Specification 3.10. 5, ''High Pressure Coolant injection System," is being deleted along with its listing in the index.
The title of Unit 2 Specification 3/4 10.2, as listed in the index,                   is being corrected.
EVALUATION OF PROPOSED CHANGE 5:
5.A) -The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.                           *
              'With the reactor mode switch in the Refuel position, the analyses for control    rod withdrawal during refueling are applicable and, provided the assumptions of these analyses are satisfied in Cold Shutdown, these analyses will bound the consequences of an accident. Explicit safety
* analyses    in the FSAR (Section 15.1.13) demonstrate the functioning of the refueling interlocks and adequate Shutdown Margin (SDM) will preclude unacceptable reactivity excursions.                                                        '
Meeting the requirements of the specified LCOs or implementing the specified alternate conditions, along with the specified Actions and
* Surveiliance Requirements, will provide the same- protection against
              ' inadvertent ::riticality which normally exists in the Refuel mode.                    -In. ,
               ' addition, since this operation will be taking place in the Cold Shutdown                  i condition, further protection from offrite releases wi;l be provided by the fact that the vessel head will be installed with all head-bolts fully tensioned.      Therefore, this change does not involve a significant increase in the probability or consequences of an accident'previously evaluated.
P Deletion of--the current Specification 3.10.5, "High Pressure Coolant Injection System " will have no impact whatsoever because it is stated                     ,
within the specification that it is for use during a one time test and is only applicable ~from June 2-9, 1980.         Since this time period has elapsed, this -specification is no longer applicable. Therefore, deletion of this L
specification _ does not involve a significant increase in the probability or consequences of an-accident previously evaluated.
003478 HL-2231                                    E2-9                                                    -

i
        . y ENCLOSURE 2 (Continued)
MISCELLANEOUS REFUELING SpECIFICATI0til 10 CFR 50.92 EVALUATION The correction of the title of Unit 2 Specification 3/410.2 in the index is strictly an editorial correction.       Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
5.B) The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Removal of one control rod and/or the associated control rod driva mechanism from the reactor pressure vessel is currently allowed in the Refuel mode by Unit 2 Specification 3.9.11.1. The proposed specification will. allow the same operation in the Cold Shutdown mode provided the same protection is provided against inadvertent criticality which normally exists in the-Refuel mode. Therefore, the proposed specification does not involve any new modes of operation, just performance of an existing operation in a different operational mode.       Therefore, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Deletion of the current        Specification 3.10.5, "High Pressure Coolant Injection System," will have no impact whatsoever because it is stated within the specification that it is for use during a one time test and is only applicable from June 2-9, 1980. Since this time period has elapsed, this specification is no longer applicable. Therefore, deletion of this specificatica does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The correction of the title of Unit 2 Specification 3/410.2.in the index it strictly an editorial correction.       Therefore, this change does not create the possibility of a new or different kind of accident from an.y U                   ' accident previously evaluated.
0             5.C) hhe proposed amendment does not involve a significant reduction in the margin of safety.
e This: specification does involve limiting safety system settings (LSSSs).
                    .The LSSSs which are normally required to be operable in the Refuel modo are also required to_ be operable in the Cold Shutdown mode while performing. operations per the proposed specification. These requirements-are_ intended _to afford the same protection against inadvertent criticality as - normally- exist in the Refuel mode.       By maintaining this level of protection, the margin of safety will be maintained at the same level which exists when this operation is being performed in the Refuel mode.
                    ;Therefore, -this change does not involve a significant reduction in the margin of safety.
003478 HL-2231                                E2-10

                                                ..         .        ~_ -
                                                                                                          'l i
i ENCLOSURE 2 (Continued)
HISCELLAJ1E005 REFUELING SPECIFICATIONS 10 CFR 50.92 EVALUATION Deletion of the current. Specification 3.10.5, "High Pressuro coolant Injection System," will have no impact whatsoever because it is state (
within the saecification that it is for use during a one time test and is only   applica a le from June 2-9, 1980. Since this time period has elapsed, this specification is no longer applicable. Therefore, deletion of this specification does not involve a significant reduction in the margin of safety.                                                                                  .
The correction of the title of Unit 2 Specification 3/4 10.2 in the index
                 ' is strictly an editorial :orrection.          Therefore, this change does not-involve a significant reduction in the margin of safety.
t m
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