View source for HL-2335, Application for Amends to Licenses DPR-57 & NPF-5,changing TS Figure 2.1-1 for Unit 1 & TS Figure 3/4 3-1 for Unit 2 to Reflect Correct Top of Active Fuel Reactor Pressure Vessel Water Level

{{Adams
| number = ML20114D934
| issue date = 09/02/1992
| title = Application for Amends to Licenses DPR-57 & NPF-5,changing TS Figure 2.1-1 for Unit 1 & TS Figure 3/4 3-1 for Unit 2 to Reflect Correct Top of Active Fuel Reactor Pressure Vessel Water Level
| 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-2335, NUDOCS 9209100180
| package number = ML20114D935
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 6
| project = 
| stage = Request
}}

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HL-2335 000950 September 2, 1992 U.S. Nuclear Regulatory Commission ATTN:          Document Control Desk Washington, D.C. 20555 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:
TOP OF ACTIVE FUEL RFFEREM E Gentlemen:
In accordance with the provisions of 10 CFR 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 (1S), Appendix A to Operating Licenses DPR-57 and NPF 5.
The proposed amendment corrects the reactor pressure vessel (RPV) water level reference correspoiding to the Top of Re6ctor Fuel (TAF) for both units from the value representing the TAF prior to the purchase of 8x8 fuel to the value applicable to 8x8 fuel and subsequent fuel designs.                       The correct value is 6 inches higher than the valce shown in the TS on Unit I figure 2.1-1 and Unit 2 figure B 3/4 3-1.
Enclosure 1 provides a description of the circumstances neces:itating the change request.               Enclosure 2 provides the bases for GPC's determination I
the request does not represent a significant hazards consideration.
Enclosure 3 provides page change instructions for incorporcting the                              ;
proposed change. Following the enclosures are the proposed changed TS                            '
pages followed by the markups.                                                                   !
To allow time for procedure revisions and orderly incorporation              into       l 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 than 60 days from the date of issuance of the amendment.
In accordance with the requirements of 10 CFR 50.91, the designated state official                will be sent a copy of this letter and all applicable j           enclosures.
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Get igia Power d U.S. Nuclear Regulatory Commission September 2, 1992 Page Two 4
Mr. J. T. Beckham states he is duly authorized to execute this oath on behalf of Georgia Power Company, and to the best of his knowledge and belief, the facts set furth in this letter are true.
GEORGIA POWER COMPANY 1
BY:       h                P J. T. Beckham, Jr.
Sworn to and subscribed before me this /N        day of .    ~1d 1992.
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OCV/sp                                               [NotaryPublic

==Enclosures:==
: 1. Basis for Change Request.
: 2. 10 CFR 50.92 Evaluation.
: 3. Page 7,hange Instructions followed by corresponding markups.
c: Georaia Power Company Mr. H. L. Sumner, General Manager - Nuclear Plant NORMS
.                    U.S. Nuclear Reaulatory Commission. Washinoton. D.C.
Mr. K. Jabbour, Licensing Project Manager - Hatch U.S. Nuclear Reaulatory Commission. Reaion II Mr. S. D. Ebneter, Regional-Administrator Mr. L. D. Wert, Senior Resident Inspector - Hatch State of Georata Mr. J. T.. Tanner, Commissioner - Department of Natural Resources HL-2335 000950 1
700775

4 ENCLOSURE 1 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366                                      i OPERATING LICENSES DPR 57, NPF-5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:
TOP 0F ACTIVE FUEL REFERE1CE    C BASIS FOR CHANGE REQUEST                                       ;
i PROPOSED CHANGE:
The proposed amendment revises Unit 1 TS figure 2.1-1 and Unit 2 TS figure                  l B 3/4 3-1 to reflect the correct Top of Active Fuel (TAF) reactor pressure                 4 vessel (RPV) water level.
Basis for Proposed Chance:
Recently,   an error in Unit 1 TS figure 2.1-1 and Unit 2 figure B 3/4 3-1 TAF notations was discovered. The same incorrect value also appeared in the Unit I and Unit 2 FSARs, and plant procedures. The TAF level indicated.
on the referenced figures (i.e., 352.56 inches) is correct for GE 7x7 fuel design which had a fuel length of 144 inches.               However, Plant Hatch no longer uses 7x7 fuel. Subsequent fuel designs purchased in the mid-to-late 1980s have maximum active fuel lengths of 150 inches. The top 6 inches of fuel in the 8x8 and newer fuels are made of nonenriched uranium. The TAF value presently referenced in the TS, as well as plant procedures, is still based on 144-inch length fuel and, therefore, should be reviseo to reflect the actual dimension of_ later fuel designs.
It should be noted that the correct TAF value (358.56 inches) was used in the SAFER /GESTR accident analysis.            In fact, the initiating RPV level setpoints for the emergency core cooling systems (ECCSs) assumed in the analysis are much lower than the actual plant setpoints. Therefore, use of the incorrect TAF value (352.56 inches) does not affect the present Levels-1,   2, and 3 setpoints or any other-aspect of loss of coolant accident (LOCA) analyses.
In addition to the TAF change to Unit 1 TS figure 2.1-1 and Unit 2 TS figure B 3/4 3-1, a minor editorial enhancement (removal of two extraneous tick marks) is being made. This change is purely administrative in nature.
Ht.-23 5 000950                                  El-1

1
:                                                                       ENCLOSURE 2 PLANT HATCH - UNITS 1, 2 l
NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:
TOP OF ACTIVE FUEL REFERENCE 10 CFR 50, 4 EVALUATION l
The Commission has provided standards                        in 10 CFR 50.92(c)       for determining    ,
;                        whether a signif cant hazards consideration exists.                           -A proposed amendment      I
;                        to an operating licenra for a facility- involves no significant hazards if j                        operation of the facility, in accordance with the proposed amendment, will not; i
: 1)     Involve a significant increase in the probability or consequences of an accident previously evaluated,
]
: 2) Create the possibility of a ned or different kind of accident from any accident previously evaluatcd, or
: 3)     Involve a significant reduction in a margin of safety.
Basis for orocosed no sianificant hazards consideration determination:
Georgia Power Company (GPC) ) s reviewed the proposed license amendment and
,                        determined       its    adoption             will not              involve a    significant hazards
;                        consideration based on the following:
: 1. The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The- proposed change only involves revising Unit 1 TS figure 2.1-1 and
!                             Unit 2 TS figure B 3/4 3-1 to correct the Top of Active Fuel (TAF) indicated value. The change accounts for the newer _ design fuel assemblies which contain 6 inches of nonenriched uranium at the top of the bundle, thereby making the active fuel                              length 150 inches,.as opposed to 144 inches, and the TAF boundary at 358.56 inches, as opposed to the 352.56 inches (referenced from vessel zero) currently indicated in the TS.
No changes to systems designed to mitigate the consequences of an accident are proposed.
HL-2335 000950                                                E2-1
   -_     .                        ..c     .-      - - .      - - - ,      - - ,               -  . _

ENCLOSURE 2 (Continued)
REQUEST TO REVISE TECHNICAL SPECIFICATIONS:
TOP 0F ACTIVE FUEL REFEEEE l
10 CFR 50.92 EVALVATION i
j                    The proposed change does not affect any previously analyzed accident, because all SAFER /GESTR accident-analyses were performed using the correct fuel length and TAF value. The same analyses also assumed the RPV levels at which the emergency core cooling systems (ECCSs) would initiate in response to these design basis events are much lower than the actual plant setpoints. Thus, raising the TAF boundary by 6 inches does not affect or require a change to accident analyses, since the analyses utilized the correct fuel length and TAF boundary.
ECCS RPV level setpoints will not be affected by the proposed change,                 i since the analyres used the correct TAF value and assumed initiating                 !
setpoints that are much lower than the actual plant settings.                The     !
proposed change will merely bring the TS            in agreement with the actual      l plant configuration.                                                                  l In summary, the proposed change does not involve any physical changes
!                     to the plant which would increase the probability of occurrence of a loss of coolant accident (LOCA).               The consequences of previously analyzed LOCAs are not increased, because no changes are being proposed to systems designed to mitigate the consequences of LOCAs, and previous accident analyses have already been performed, considering the correct TAF number.
The minor editorial change is strictly an aesthetic enhancement which does not affect the design or operation of any_ plant equipment or system.
: 2.         The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
: a. The proposed change only involves changing the TS to reflect the actual plant configuration and making an insignificant editorial change,
: b. No physical changes to the plant are proposed.
: c. No changes     involving _ operating systems or equipment outside of their intended design are proposed.
HL-2335 000950                                            E2-2

ENCLOSURE 2 (Continued)
REQUEST TO REVISE TECHNICAL SPECIFICATIONS:
TOP OF ACTIVE FUEL Rf;EERQNSE 10 CFR 50.92 EVAIDATION Thus,   no new modes of operation are introduced, and the possibility of p                 occurrence of a different type of event from any previously evaluated is not created.
: 3. The proposed event does not involve a significant reduction in the margin of safety.
The SAFER /GESTR accident analyses under which Plant Hatch is currently licensed used the correct fuel le'agtn and TAF_ boundary. In addition, the RPV level ECCS initiating setpoints were assumed to be much lower      )
than TS or actual plant setpoints. Therefore, tia margin of safety is
,                 not affected, since the proposed change only achieves consistency between the TS and the actuhl plant configuration. Neither the accident analyses nor the ECCS RPV level setpoints will change.             ,
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HL-2335 000950                               E2-3
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