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Application for Amends to Licenses DPR-57 & NPF-5,modifying Various Intrumentation Surveillance Requirements Re Channel Functional Test Frequency & Reactor Protection Sys & Control Rod Block
	ML20029A827
Person / Time
Site:	Hatch
Issue date:	02/26/1991
From:	Hairston W; GEORGIA POWER CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20029A828	List: ML20029A827; ML20029A833;
References
	HL-1453, NUDOCS 9103040333
	Download: ML20029A827 (34)
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W. O H66tSton, lH w ,e r.r.we NAkW OW H1 a L HL 1453 001166 February 26, 1991 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 EDWIN 1. HATCH NUCLEAR PLANT - UNITS 1, 2 NRC DOCKETS 50 321, 50 366 OPERATING LICENSES DPR 57, HPF 5 REQUEST 10 REVISE TECHNICAL. SPECIFICATIONS:

lliST RUM ENT AT 10LSEy11t L AN C E R[DU I REM E N T S 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 (TS). Appendix A to Operating Licenses OPR-57 and NPF 5.

The proposed changes modi fy various instrumentation surveillance requirements for both Hatch units. Specifically, notes _have been added to the TS allowing instrumentation channels to be removed from service for required surveillance testing and not be considtred inoperable relative to TS required actions. Also, the functional test intervals on selected instrumentation will be extended, based on NRC approved methodology. To accomplish these objectMes, the following TS changes have been included in this proposed amendment:

1.- The channel functional test frequency of various Emergency Core Cooling System (ECCS) and isolation actuation instrumentation has been changed from monthly to quarterly. Also, a 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months allowable outage time (A0T) for surveillance and a 12-hour A0T for repair have been provided, as long as the associated instrument function

, is still available. This change is consisten; with the NRC-approved Boiling Water Reactor Owners' Group (BWROG) Technical Specification Improvement (TSI) methodology as issued in GE Topical Reports NEDC-30936P A and NEDC-31677P A (References 1 and 2).

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Georglit Ponel U.S. Nuclear Regulatory Comission February 26, 1991 page Two

2. Selected instrumentation tables in the Unit 1 15 have been reformatted to more closely resemble the Unt' 215 and the existing BWR.4 Standard lechnicai Specifications (STS).

3. Changes to other instrumentation channel specifications are also proposed to provide a 2 , 4 , or 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months A01 in which an instrument can be inoperable so that 15 surveillances can be performed without entering LCO Action Statements.

4. Hinor changes to the Reactor protection System (RpS) and control rod block instrumentation surveillances are proposed. The NRC recently approved the application of the DVROG 151 methodology to this instrumentation in Unit 1 15 Amendment 163 and Unit 2 15 Amenument 100.

S. Hinor editorial changes to various 15 pages are ilso proposed.

Enclosure 1 provides detailed descriptions of the proposed changes and the circumstances necessitating the change request. Encloshre 2 details the bases for our determination that the proposed changes fo not involve significant hazards considerations. Enclosure 3 provides page change instructions for incorporating the revised paans. The proposed changed 15 pages, along with a marked up copy of tia current 1S pages, follow inclosure 3.

To allow time for procedural revisions and orderly incorporation into copies of the TS, GpC requests the proposed amendment, once approved by the NRC, be issued with an effective date to be no later than 60 days from the date of issuance of the amendment.

In accordance with the requirements of 10 CfR 50.91, a copy of this letter and all applicable enclosures will be sont to Mr. L. Barrett of the Environmental protection Ulvision of the Georgia Department of Natural Resources.

IIL 1453 001166 l l

l

Georgist l'oWel l

U. S. Nuclear Regulatory Commission February 26 1991 Page lhree Mr. W. G. Hairston, 111 states he is Senior Vice President of Georgia Power Company and is authorized to execute this oath on behalf of Georgia Power Company, and to the best of his knowledge and belief, the facts set forth in this letter are true.

GEORGIA POWER COMPANY gy. _ tv' lb /b.. JL -W-W. G. Hairston, 111 Sworn to and subscribed before me this M day of d 4 u w 4 1991.

J (2- fty,hy--

GKM/cr WY coMMisstDN DNR[s JANUARY 17,1993 Referenen:

1. NIDC-30936P-A, "BWR Owners' Group Technical Specification Improvement Methodology (With Demonstration for BWR ECCS Actuation Instrumentation), June 1987.

2. liEDC-31677P-A,

Technical Specification Analysis for BWR ! solation Actuation Instrumentation," July 1990.

Enclosures:

1. Basis for Change Request

2. 10 CFR 50.92 Evaluation

3. Page Change Instructions c: Georaia Power Company Mr. H. L. Sumner, General Manager Plant Hatch Mr. J. D. Heidt, Engineering and Licensing - Plant Hatch NORMS U. S. Nuclear Reaglatory Commission. Washington. D. C.

Mr. K. Jabbour, licensing Project Manager - Hatch U. S. Nuclear Reaulatory Commission. Region _11 Mr. S. D. Ebneter, Regional Administrator Mr. L. D. Wert, Senior Resident inspector Hatch State of Georah Mr. L. Barrett, Commissioner - Department of Natural Resources l

HL-1453 001166

. n HL 1453 001166 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 EDWIN 1. HATCH NUCLEAR PLANT - UNITS 1, 2 NRC DOCKETS 50 321, 50 366 OPERATING LICENSES DPR 57, NPF 5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVEILLANCE RE0VIREMENTS Gentlemen: -

In accordance with the provisions of 10 CFR 50.90, as requirej 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 Eicenses DPR 57 and NPF 5.

The proposed changes modify various instrumentation surveillance requirements for both Hatch units, Specifically, notes have been added to the TS allowing instrumentation channels to be removed from service for required surveillance testing and not be considered inoperable relative to TS required actions. Also, the functional test intervals on selected instrumentat:on will be extended, based on NRC approved methodology. To accomplish t%se objectives, the following TS changes have been included in this proposed amendment:

1. The channel functional test frequency of various Emergency Core Cooling System (ECCS) and isolation actuation instrumentation has been changed from monthly to quarterly. Also, a 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months allowable outage time (A0T) for surveillance and a 12-hour A0T for repair have been provided, as long as the associated instrument function is still available. This change is consistent with the NRC approved Boiling Water Reactor Owners' Group (BWROG) Technical Specification Improvement (TSI) methodology as issued in GE Topical Reports NEDC 30936P A and NEDC 31677P A (References 1 and 2).

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2. Selected instrumentation tables in the Unit 1 TS have been reformatted to more closely resemble the Unit 2 TS and the existing BWR 4 Standard Technical Specifications (STS).

3. Changes to other instrumentation channel specifications are also proposed to provide a 2 , 4 , or 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months A0T in which an instrument i can be inoperable so that TS surveillances can be performed without entering LCO Action Statements.

4. Minor changes to the Reactor Protection Systes,(RPS) and control rod block instrumentation surveillances are proposed. The NRC recently approved the application of the BWROG TSI methodology to this instrumentation in Unit 1 TS Amendment 163 and Unit 2 TS

[ Amendment 100.

5. Minor editorial changes to various TS pages are also proposed.

Enclosure 1 provides detailed descriptions of the proposed changes and the circumstances necessitating the change request. Enclosure 2 details the bases for our determination that the proposed changes do not involve significant hazards considerations. Enclosure 3 provides page change instructions for incorporating the revised pages. The proposed changed 15 pages, along with a marked up copy of the current TS pages, follow Enclosure 3.

To allow time for procedural revisions and orderly incorporation into copies of the TS, GPC requests the proposed amendment, once approved by the NRC, be issued with an effective date to be no later than 60 days from the

, date of issuance of the amendment.

^

In accordance with the requirements of 10 CFR 50.91, a copy of this letter and all applicable enclosures will be sent to Mr. L. Barrett of the Environmental Protection Olvision of the Georgia Department of Natural Resources.

HL 1453 001166

U. S. Nuclear Regulatory Commission Page Three I Mr. W. G. Hairston, 111 states he is Senior Vice President of Georgia l Power Company and is authorized to execute this oath on behalf of Georgia F

Power Company, and to the best of his knowledge and belief, the facts set I s forth in this letter are true.

GEORGIA POWER COMPANY BY:

W. G.'Hairston, 111 i

Sworn to and subscribed before me this day of 1991.

Notary Public GKM/cr

References:

1. NEDC-30936P-A, 'BWR Owners' Group Technical Specification Improvement Methodology (With Demonstration for BWR ECCS Actuation Instrumentation), June 1987.

2. NEDC 31677P-A, " Technical Specification Analysis for BWR isolation Actuation Instrumentation," July 1990. j

Enclosures:

1. Basis for Change Request

2. 10 CFR 50.92 Evaluation

3. Page Change Instructions c: Georaia Power Comoany Mr. H. L. Sumner, General Manager - Plant Hatch Mr. J. D. Heidt, Engineering and Licensing - Plant Hatch NORMS U. S. Nuclear Reaulatory Commission. Washinaton. D. C.

Mr. K. Jabbour, Licensing Project Manager Hatch U. S. Nuclear Reculatory Commission. Reaion 11 Mr. S. D. Ebneter, Regional Administrator Mr. L. D. Wert, Senior Resident inspector Hatch '

' State of Georaia Mr. L. _ Barrett, Commissioner Department of Natural- Resources HL 1453 001166-

ENCLOSURE 1 EDWIN 1. HATCH NUCLEAR PLANT - UNITS 1, 2 NRC DOCKETS 50 321, 50 366 OPERATING LICENSES DPR 57, NPF 5 RE0 VEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVElltANCE RE0VIREMENTS Basis FOR CHANGE RE0VESI PROPOSED CHANGE ONE:

This proposed change revises the Emergency core and isolation actuation instrumentation channel functional CoolingSystem(ECCS)from test interval monthly to quarterly. The affected Technical Specifications (TS) instrumentation for Units 1 and 2 is listed in Tables 1 and 2 of this enclosure. For instrumentation whose calibration is already quarterly, the channel functional test was changed to 'N/A', since the channel calibration encompasses the channel functional test. -

This_ proposed change also provides a 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months allowable outage time (A0T) for surveillance testing with one or more channels of one subsystem removed from service. Tlia proposed 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months A0T for surveillance has been included (either added in a new footnote or revised in an existing footnote) in the ,

following tables and specifications:

Unit 1 - Tables 3'.2 1 through 3.2 6 and Table 3.2 9.

Unit 2 - Tables 3.3.2 1, 3.3.3 1, and 3.3.4 1.

In both units, the added or revised notes read as follows:

A channel may be removed from service for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for required surveillance testing and not be considered ino)erable provided sufficient channels are available to ensure tie trip .

function. I The above note allows the- TS Actions to be suspended or waived for a specified period of time. Since entering the Actions is not necessary, cascading the TS required actions also will not be required. For example, if the Core Spray (CS) system is in a 7 day limited condition for operation (t.00) (Unit 2 TS3.5.3.1) and a channel functional test is due on an instrument in the residual heat removal (RHR)- system (Unit 2 Table 3.3.3 1), application of this note will permit GPC to continue in the 7 day LCO- for CS and not declare the instrument or the associated RHR loop inoperable. -Therefore, GPC would not be required to enter Unit 2 TS 3.0.3,

.which requires reactor shutdown during the period of time in which the-instrument surveillance is being performed.

001166 HL-1453 El-1

ENCLOSURE 1(Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVEILLANCE RE0VIREMENTS BASIS FOR CHANGE.RE0 VEST Certain channel trip functions are designed such that the removal of one trip function from service renders the required system trip function inoperable, based on design considerations, specific notes have been tailored for these conditions as follows:

1. For Reactor Vessel Water level 8 Trip: Unit 1 Tables 3.2 2 and 3,2 3, and Unit -2 Table 3.3.3 1, and for High Pressure Coolant Injection (HPCI) and Reactor Core Isolution Cooling (RCIC) Pump Discharge Flow -

Low and High: Unit 1 Tables 3.2+2 and 3.2 3:

While performing surveillance during times when this equipment is required to be OPERAB'.E. the : Action Statement should be entered since sufficient channels will not be available to ensure the trip function.

2. -For Scram Discharge Volume Control Rod Block: L Unit 1 Table 3.2 7-and Unit 2 Table.3.3.5 1:

A [The) channel may-be removed from service for up to 5

= hours for required surveillance- testing -and not -be considered inoperable. Withdrawal of control rods is not i permitted during required surveillance testing. ;

Next. Unit 1 TS. Tables 3.2 1, 3.2-2, 3.2-3, 3.2 4, 3.2-5, and 3.2 6 and' Unit 2 Specifications 3.3 2, 3.3 3, and 3.3 4 have been revised to provide-a 12-hour.A0T for instrument repair, provided the instrument trip function in 'the remaining channel / trip system is still available. In Unit 1 Table 3.2 1 -and Unit 2 TS 3.3.2, the Action Statement regarding inoperable channels on one trip system has been revised to read as follows:

With the number of OPERABLE channels- less than required by the Minimum OPERABLE Channels- per -Trip System requirement for one trip system, either

1. Place theinoperablechannel(s)'in the tripped !

condition-within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR

2. Take- the, ACTION required by Table 3.3.2-1.-

(Table 3.21 for Unit 1)

The provisions of Specification 3.0.4 are not applicable. l (Specification-- 3.0.4 is not-contained in the Unit 1-TS.)

001166 a HL-1453 El-2 1

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ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPEClflCATIONS:

INSTRUMENTATION SURVEILLANCE RE0VIREMENTS BASIS FOR CHANGE RE0 VEST In addition, in Unit 1 Table 3.2 1, an A0T for restoring an inoperable ,

single channel in lieu of tripping that channel has been established at 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months when tripping the channel would cause the trip function to occur. ,

Unit 1 TS Bases Section 3.2 and Unit.2 T5 Bases Section 3/4.3 have been revised appropriately to reflect the above changes.

Finally, in accordance with General Electric (GE) Topical Report NEDC 31677P A (Reference 1), this proposed change revises the daily channel checks for the isolation actuation instrumentation for both units to "once per shift" in order to establish consistency with the GE BWR 4 Standard Technical Specifications (STS), as well as with all channel checks.

Basis for Proposed Chance One:

This proposed change results from GE Topical Reports NEDC 30936P A (Reference 2) and NEDC 31677P A (Reference 1). The subject reports provide a probabilistic basis for extending ECCS and isolation actuatior instrumentation surveillance intervals. The generic analyses provided in these repor,, indicate the pro)osed interval extension (frommonthlyto quarterly) can be enacted wit 1out- negatively affecting the-functional capability or reliability of the systems. An NRC Safety Evaluation Report (SER) generically endorsing the methodology and changes provided-in the referenced reports is provided at the beginning of each report. Note that the NRC has already approved similar changes for RPS and rod block instrumentation in Unit 1 TS Amendment 163.and Unit 2 TS Amendment 100.

GPC and GE have reviewed the generic analyses and determined they are applicable to Plant Hatch Units 1 and 2. GPC has also reviewed the setpoint calculations associated with the affected instruments and determined- the existing calculations will not be affected by changing the channel functional test interval from monthly to quarterly, in the case of the Reactor Building and refueling floor radiation isolation actuation instrumentation (Unit 1 Table 4.2 1 and Unit 2 Table 4.3.2 1), I the setpoints are-field determined. GPC has reviewed the operating history of these instruments and Jetermined the instrument drift is small enough to justify a quarterly. channel functional test frequency.

I i

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001166 I HL-1453 El 3

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ENCLOSURE 1(Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVEILLANCE RE0VIREMENTS Basis FOR CHANGE RE0 VEST Also, the safety relief valve (SRV) tailpipe pressure switches have setpoints that were developed as part of the environmental qualification program; these setpoints are not field adjustable. Since the switches are located in containment, the only tests conducted during operation involve circuit integrity. Therefore, the setpoints are not a consideration in changing the channel functional test frequency from monthly to quarterly.

As noted in Tables 1 and 2 of this enclosure, many of the subject instruments whose channel functional checks are proposed to be changed from '

monthly to quarterly are in the Analog Transmitter Trip System (ATTS . As documented in GPC's letters to the NRC dated July 24, 1985 andJanuar)y23, 1984, ATTS setpoints are calculated using the methodology of Regulatory Guide 1.105 and are designed for a quarterly channel functional test interval. Also, the setpoint calculations for ATTS generally assume a channel functional test interval of 6 months. Since the initial installation of ATTS in 1984, the trip units, which have an assumed 6 month channel functional test frequency in the setpoint calculations, have shown very little drift and few failures. Before approving similar changes for the Reactor Protection System (RPS) instrumentation tables, the NRC staff reviewed actual ATTS surveillance test data from Plant Hatch. -

The referenced GE Topical Reports also provide the basis for including in

'the Plant Hatch TS a 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months A0T for surveillance testing and a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months A0T for repair. For clarity, GPC has made some editorial revisions to the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months A0T note )rovided in the GE Topical Reports; the intent of the note has not been c1anged. GPC has revised the isolation actuation Action Statement for operation with a channel inoperable to achieve consistency with the Action Statement revisions provided in NEDC 31677P A. GPC has also elected -to use more conservative A0Ts for repair (forECCS and isolation actuation instrumentation) than were justified in the GE Topical Reports the A0T proposed for (References 1and 2).

the Units 1 and 2 TS is 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .With one trip system With inoperable, both trip systems-inoperable, the A0T will remain I hour. This allows for consistency with the RPS instrumentation Action Statements approved for Plant Hatch. '

-The 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months " waiver":of TS Actions has been applied to most instruments that perform a trip function.: However, some tri) functions are designed such that the removal-- of one trip function /ciannel could render the trip function inoperable. GPC has added special notes'for this instrumentation.

Specifically, notes for surveillance testing have been created for the ECCS 001166 HL-1453- El-4

- _ -~ _ _ _ _ _ _ _ _ _ . ._ _ _ _ __ ,_ -_ _._ __

ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS: .

INSTRUMENTATION SURVElllANCE RLQUIREMENTS BASIS FOR CHANGE RE00EST reactor vessel water level 8, the control rod block scram discharge volume, and the Unit 1 HPCI and RCIC pump discharge flow high and low trip functions. For HPCI and RCIC, the reactor vessel water level 8 trip .

function shown in the ECCS tables is a two out of two trip logic. When one instrument is removed from service for required surveillances, the required trip function may not be available. Therefore, a proposed note has been '

added requiring the Action statement (LCO) be entered during surveillance testing of this instrumentation.

The HPCI and RCIC pump discharge flow high and low trip functions control the opening and closing of the associated system's minimum flow valve. For each system, only one instrument controls this function. During periods of required surveillance, this function may be degraded. Therefore, GPC has elected to also enter the LCO Action Statement for these instruments.

The control rod block scram discharge volume trip function has only a single channel and one trip system. T1e function is to prevent control rod withdrawal with high scram discharge volume level. Therefore, a note has been added, allowing required surveillances to be performed without entering an LCO, provided no control rods are withdrawn during-this activity.

The proposed addition of the note to Unit 1 Table 3.2-1 establishes a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months A0T for restoring an inoperable single channel in lieu of. tripping -

that channel (when tri> ping the channel would cause the trio function to ~

occur). Also, daily c1annel checks were changed to "once per shift" to establish consistency with the GE -Topical Reports. These changes are consistent with the current Unit 2 TS and the existing GE BWR-4 STS.

As a point of note, the Unit I surveillance tables use the term " instrument functional test." Although GPC is not proposing a title change in every Unit I table at this time, the current philosophy used in the Unit 2 15 and the existing GE BWR 4 STS relative to the channel functinnal test will be applied to surveillance-frequencies in the Unit 1 TS tables.

Approval of the proposed changes will result in consistent and accurate ECCS and isolation actuation instrumentation surveillance requirements for both Hatch units.

001166 HL-1453 El 5

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ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPEClflCATIONS:

INSTRUMENTATION SURVEILLANCE RE0VIREMENTS BASIS FOR CHANGE RE0 VEST PROPOSED CHANGE TWO:

This proposed change moves the instrumentation, which initiates isolation of HPCI, RCIC, and the Low Pressure Coolant injection (LPCI) mode of RHR, from Plant Hatch Unit 1 LCO TS Tables 3.2 2, 3.2 3, and 3.2 5 (and their corresponding survelliance tables) to Unit 1 LC0 Table 3.2 1 and surveillance table 4.2 1. This permits the application of consistent Action Statements to the isolation actuation instrumentation. This change is consistent with the GE BWR 4 STS and the Plant Hatch Unit 2 15. The specific instruments being moved are listed in Table 3 of this enclosure.

Also, for clarity, Unit 1 T M es 3.2 1 and 4.2 1 have been renamed to indicate the isolation actuation function, and the Table of Contents has been revised and reorganized to reflect these changes.

Basis for Pronosed Chance Two:

The equipment identified above is more appropriately termed isolation actuation instrumentation and is stated as such in both the GE BWR 4 STS and the Plant Hatch Unit 2 TS. Based on the results of the reliability studies presented in GE Topical Reports NEDC 30936P A (Reference 2) and NEDC 31677P A (Reference 1), and the differences in instroment functions, the Action Statements for the ECCS and the isolation actuation instrumentation are different. By separating these instruments into the appropriate sections, the Action Statements can be more appropriately applied in the Unit 1 TS.

The only Action Statement in the Unit 1 TS undergoing significant revision as a result of this change is the Action relating to the reactor steam dome pressure instrument providing both a low pressure signal to allow operation of the shutdown cooling mode and a low pressure permissive, in conjunction with a containment isolation signal, to close the RHR injection valves, in current Unit 1 Tables 3.2-1 and 3.2 5, Actions are provided in the event the reactor steam dome pressure instrument is inoperable. Table 3.2 1 requires the shutdown cooling mode be isolated, and Table 3.2-5 requires the LPCI system be declared inoperable if the instrument is inoperable. In relocating the reactor steam dome pressure instrument to only an isolation actuation table (as in the Plant Hatch Unit 2 TS and the GE BWR-4 STS), GPC proposes the following Unit 2 Action Statement be adopted:

Close the shutdown cooling supply isolation valves unless reactor steam dome pressure s 145 psig.

001166 HL 1453 El 6

ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SVRVEILLANCE RE0VIREMENTS l

BASIS FOR CHANGE RE00111 The revised Action Statement is being proposed, since the inoperability of the reactor steam dome pressure instrument will not directly impact the operability of the LPCI system. This change is consistent with the Plant Hatch Unit 2 TS and the GE BWR 4 STS, l

001166 HL-1453 El-7

ENCLOSURE 1 (Continued)

(EQUEST TO REVISE TECHNICAL SPEClfitATIONS:

JNSTRUMENTATION SURVElllANCE RE0VIREMENTS BASIS FOR CHANGE RE0 VEST PROPOSED CHANGE THR((:

This proposed change adds the following note to certain instrumentation tables and specifications in the Plant Hatch Units,1 and 2 TSt A -channel may be removed from service for up to ( ) hours for '

required surveillance testing and not be considered inoperable, provided sufficient channels are available to ensure the trip function. ,

l To avoid confusion in implementing this note, the tables that provide only monitoring functions do not include the phrase 'provided sufficient channels are available to ensure the trip function."

The amount of time- provided in the note is either 2, 4, or 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months depending on the normal- amount of time it requires to perform the associated surveillance. The following tables and specifications have been revised:

-Unit 1 Unit 2 T 3.2-8 S 4.1.3.5 T 3.2 10 T 3.3.6.1 1

'T 3.2 11 1 3.3.6.2 1 T 3.2 12 T 3.3.6.3 1 T 3.2 13 T 3.3.6.4 1 T 3.2 14 S 4.3.6.5 S 3.14.1 T 3.3.6.7-1 T 3.14.2 1 T 3.3.6.9 1 S 4.6 H.1.e 1 3.3.6.10 1 S 4.6.H.2 T 3.3.8 1 S'4.7,0,1 T 3.3.9.1 1 1 3.3.9.2 1 4 S 4.4.2.1 S 4.4.2.2 S 4.4.3.1 +

S 4.5.3.1 5 4.5.4.1 S 4.6.2.1

, S 4.6.3.4 S 4.9.2 T 3.3.3 1, item Sa LEGEND:

T --Table S - Specification 001166 i HL-1453 El-8

ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVEllltdiCE REQUIREMENTS BASIS FOR CHANGE RE0 VEST P

Basis for Proposed Chanae Three:

The Plant Hatch TS provide channel functional test and channel calibration frequencies. When performing the surveillances, the TS require the j instruments to be 'out of service

for a period of time. In order to L

assure the instrumentation is not removed from service for an excessive amount of time for surveillance, an A0T of 2, 4 or 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months has been established after discussions with Plant Hatch site personnel concerning the amount of time necessary to perform the surveillance.

The surveillances were developed to ensure the availability of instrumentation to perform its design function. Therefore, providing L reasonable A0Ts in which to perform the surveillances supports instrumentation in the performance of its design function. This proposed TS change also provides conditions of operation necessary to preserve the ability of the system to perform its intended trip function, even during periods when instrument channels may be out of service, it should be noted that monitoring instrumentation does not provide input to any trip function necessary in the initial stages of an accident or transient. Therefore, it is not necessary to assure the monitoring function is preserved during the brief time intervals of required surveillances. Since many of these monitoring instruments only have a single channel, the portion of the note requiring that sufficient channels be available to support the trip function has been deleted, in addition, GPC's nuclear steam sup)1y system (NSSS) vendor, GE, has reviewed the addition of the note for tie instruments not included in the ECCS and isolation actuation instrumentation systems and determined these systems are not part of the primary success path of the design basis analysis / transient analysis. Therefore, the bases for the A0T for these systems can be established based on the lower safety significance of these systems.

001166 HL 1453 El-9 i

ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INS 1RUMENTA110N SURVElllANCE RE0VIREMENTS k BASIS FOR CHANGE RE0 VEST PROPOSED CHANGE FOUR:

This proposed change makes minor changes to the reactor protection system (RPS) and the control rod block instrumentation surveillances to further incorporate improvements presented in GE Topical Report NEDC 30851P A (Reference 3) and Supplement 1 (Reference 4). NEDC 30851P was previously approved by the NRC for Plant Hatch specific applications in Amendment 170 for Unit I and Amendment 100 for Unit 2. Specifically, for the Unit 1 15, notes are proposed to be revised or added to Tables 3.1 1 and 3.2 7 to allow a channel to be made inoperable for surveillance purposes without placing the channel in the tripped condition for 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , in the Unit 2 TS, tie 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months note has been included in Table 3.3.5 1 and Specification 4.1.4.3. In addition, in Ur.it-1 Table 4.2 7 and Unit 2 Table 4.3.51, the channel functional test requirement for the average power range monitor (APRM) - downscale instrument was changed from monthly to quarterly. Also, the Unit 1 Bases for Specification 4.1 was revised to reflect the current information used to establish the surveillances.

Basis for Pr.ggesed Chance Four:

The proposed change to incorporate the surveillance interval and A0T extensions into the TS is provided in the previously discussed GE Topical Reports (References 3 and 4), which have been generically endorsed by-specific NRC SERs. The GE reports provide a probabilistic basis for extending RPS surveillance and, in the case of Plant Hatch Unit 1, equipment A01. The methodology shows the requested interval extensions can be enacted 'without negatively affecting the. functional capability or reliability of.the RPS. GPC i;as previously submitted documentation to the NRC to demonstrate Plant Hatch is enveloped by these generic reports, as stated in GPC's submittal to the NRC dated March 27, 1986. These changes were inadvertently omitted from the March 27 submittal.

Setpoint calculations for the APRM instruments do not use the functional test frequency in its analyses. Only drift associated with a calibration interval is employed, i Approval of Proposed Change Four will result in consistent and correct RPS and control rod block instrumentation surveillance requirements- for both l Hatch units.

001166 HL-1453 El 10 l

,, ]

ENCLOSURE 1(Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVEILLANCE REQUIREMENTS BASIS FOR CHANGE RE0 VEST PROPOSED CHANGE FIVE:

This proposed change incorporetes mirar editorial corrections made to various TS for both Plant natch units. These proposed corrections ,

include:

1. Unit 1 Tables 3.2 5 and 4.2 5. Since the reactor vessel steam dome pressure. - low pennissive instrument is being deleted from ,

these tables, the remaining two reactor vessel steam don;o pressure low instruments are being uniquely identified. '

2. Unit 1. Tables 4.2 1 and 4.2 2 (note d), and Tables 4.2 8 at,d 4.2 10 (note e). These notes, which concern instrument functions) test minimum frequency-to-be performed initially once per month with an interval -of not less than 1 month or more than 3 months, have been deleted from the proposed amendment'.

3. Unit 1 Specification 4.9.A 7.b.2. Due to redundancy, this TS has been-deleted from the proposed amendment.

4..~ Unit 2 S)ecification 4.3.1.1. The word " FUNCTION" has been changed to

'FUNCT104AL" in referencing a channel functional test.

5. Unit 2 Specification 4.3.1.3. _The word "were" found in the last sentence of this paragraph has been changed to "where".

-6. Unit _ 2 page 3/4 3 1. In the . footnote, second line, the word

' conditions" has been changed to ' condition *.

7. Unit 2 Table 3.3.5 1. For Trip Function, item 5.a. Water Level--

High, the number 'l' has been added under the column entitled Minimum Number of OPERABLE Channels Per Trip function.

8. Unit '2 Table 3.3.6.2 1. For instrument number 3 b (Reactnr Building 185' Level), the number "l* has been added under the column entitled Minimum Instruments OPERABLE.

9. Unit - 2 Table 3.3.6.4-1. For instrument number 2, the word "shround"

has.been replaced with the word " shroud".

10. Unit 1 Tables 3.2 2, item 11, and 3.2 3, item 10. The minimim number of - operable channels per trip system has been -' changed from 1 to 2 to reflect actual- logic arrangement.

001166-HL 1453 El-ll

,=.- - -, .. .- .

i ENCLOSVRE 1 (Continued)

REQUE5s TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVEILLANCE REOUIREMENTS S. ASIS FOR CHANGE RE00EST B.uls for Proposed Chance Five:

The base > for the proposed changes described above are as follows:

1. The remaining two reactor vessel steam dome pressure - low instruments are being uniquely identified for clarity (as proposed instrument numbers 3 and 4 in the tables).

2.. Since notes d and e are archaic with respect to the TS, they have been deleted from the proposed amendment. The test frequency will

= remain once per month, unless otherwise identified in this proposed i amendment.

3. - Since the functional testing requirements for the subject relays of the logic systems are already fully required by Unit 1 Tables 4.212 and '4.2 13, the specification should not have to be ' restated.

Therefore, it has been deleted from the proposed amendment.

4. The term " CHANNEL FUNCTION TEST" is not defined in the Unit 2 TS; therefore, this is purely an editorial error.

5. Inputting the word "were" was a typographical error and, therefore.

changing it to 'where" is purely an editorial revision.

6. Inputting the word "corditions" was a typographical error in that one inoperable channel in one trip system is logically placed in a singic i

. tripped condition. Deleting the "$" from " conditions" is purely an sditorial change.

7. There is a single Minimum OPERABLE Channel per trip function for this particular instrument. The number "1" was inadvertently omitted and, therefore, adding the number is purely an editorial revision.

8. There is a single Minimum Instrument OPERABLE for instrument 3.b.

This number- was inadvertently omitted from the table; therefore adding the number "l" is purely an editorial change.

9. Inputting the word "shround" was a typographical error and, therefore, changing it to " shroud" is purely an editorial change.

10. The actual logic design arrangement is a two out-of two. This is a

~ typographical error in that the actual plant logic has not changed.

001166 HL-1453 El-12

ENCLOSURE 1(Continued)

REQUEST TO REVISE TECHNICAL SPEClflCATIONS:

INSTRUMENTATION SURVElllANCE RE0VIREMENTS BASIS FOR CHANGE REQUEST

REFERENCES:

1. NEDC-31677P-A,

Technical Specification improvement Analysis for BWR lsolation Actuation Instrumentation,' July 1990.

2. NEDC 30936P-A, *BWR Owners' Group Technical Specification Improvement Methodology (With Demonstration for BWR ECCS -Actuation Instrumentation)," June 1987.

3.-HEDC-30851P-A, *. Technical Specification Improvement Analyses for BWR Reactor Protection System," March 1988.

4.- NEDC 30851P A, Supplement 1, " Technical Specification Im)rovement Analyses for BWR Control Rod Block Instrumentation," Octo>er 1988.

001166 HL-1453 El-13

ENCLOSURE 1(Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVEILLANCE REQUIREMENTS BASIS FOR CHANGE RE0VESI t

TABLE 1(SHEET 10F2)

UNIT 1 INSTRUMENTATION WITH REVISED SURVEILLANCE FREQUENCIES jsolation Actuation Instrumentation TS Location

1. Reactor Yessel Water Level 3* T 4.2-1

2. Reactor Vessel Water Level 2* T 4.2 1- .

3. Reactor Vessel Water Level 1* T 4.2 1 4 Reactor Vessel Steam Dome Pressure - Low *# T 4.2 1 & 4.2 5

6. Drywell Pressure

T 4.2-1

6. Main Steam Line Pressure Low

T 4.2 1

7. Main Steam Line flow

T 4.2 1

8. Main Steam Line Tunnel Temp

T 4.2 1

9. RWCU Differential Flow

7 4.2-1

10. RWCU Area Temperature

T 4.2 1

11. RWCU Area Ventilation Diff Temp

1 4.2-1

12. Condenser Vacuum T 4.2 1

,13. Drywell Radiation T 4.2-1

14. HPCI Emergency Area Cooler Amb Temp *# T 4.2 1

15. HPCI Steam Supply Pressure *# T 4.2-1

16. HPCI Steam Line Diff Pressure *# T 4.2-1

17. HPCI Turbine Exhaust Diaphragm Pressure *# T 4.2-1 o

18. HPCI Suppression Chamber Area Amb Temp *# T 4.2 1

19. HPCI Supp Chamber Area Diff Air Temp *# T 4.2 1

20. RCIC Emergency Area Cooler Amb lemp*# T 4.2-1

-21. RCIC Steam Supply Pressure *# T 4.2-1

22. ~RCIC Steam Line Diff Pressure (Flow)*# T 4.2-1 3

23. -RCIC Turbine Exhaust Diaphragm Pressure *#- T 4.2 1

24. RCIC Supp Chamber Area Amb Temp *# T 4.2 25.-- RCIC Supp Chamber Area Diff Air Temp *# T 4.2 1 ECCS Instrumentation TS Location

1. Reactor Vessel Water Level 2* T 4.2 2, 4.2 3, & 4.2 9

2. Drywell Pressure

T 4.2 2, 4.2-4, 4.2-5, &

, 4.2 6

3. HPCI-Turbine Exhaust Pressure

T 4.2 2

4. HPCI Pump Suction Pressure

T 4.2 2

ATTS Instrumentation

Moved from existing ECCS tables. (See Proposed Change Two.)-

001166 HL-1453- El-14

o 4 ENCLOSURE 1 RL@'EST TO REVISE TECHNICAL SPECIFICATIONS: ,

INSTRUMENTATION SURVEILLANCE RE0VIREMENTS l

BASIS FOR CHANGE RE0 VEST TABLE 1 (SHEET 2 0F 2)

UNIT 1 INSTRUMENTATION WITH REVISED SURVEILLANCE FREQUENCIES Effi instrumentation (Continued) TS Location 5.- Re3ctor Vessel Water Level 8* T 4.2 2 & 4.2 3

6. HPCI Pump Discharge Flow

1 4.2 2

7. HPCI Condensate Storage Tank Level T 4.2 2

8. HPC.t Sup)ression Chamber Water Level

T 4.2 2

8. RCIC Tur'ine a Exhaust Pressure

T 4.2-3

9. RCIC Pump Suction Pressure

T 4.2 3

10. RCIC-Pump Discharge Flow

T 4.2 3

11. RCIC Condensate Storage Tank Level T 4.2 3

12. RCIC Suppression Pool Water Level T 4.2 3 3

13. Reactor Vessel Water Level 3* T 4.2-4

14. Reactor Vessel Water Level 1* T 4.2 4, 4.2 5 & 4.2 6

15. Rx Vessel Stm Dome Press Viv Closure' T 4.2 5

16. RHR Pump Discharge Pressure

T 4.2 4

17. -CS Pump Discharge Pressure

T 4.2 4

18. Reactor Vessel Steam Dome Press + Inj* T 4.2 5 & 4.2 6

19. Reactor Shroud Water Level 0* T 4.2 5

20. RHR (LPCI) Pump Flow

T 4.2 5 -

21. CS Pump Discharge Flow

T 4.2 6

22. Filled Discharge Pipes Level Switches S 4.5.H.4 LEGEND:

T & Table :

E S < Specification ,

ATTS Instrumentation 001166 HL-1453 0 15

O ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPEclflCATIONS:

INSTRUMENTATION SURVEILLANCE RLQUIREMENTS BASIS FOR CHANGE RE0 VEST TABLE 2 (SHEET 1 0F 2)

UNIT 2 INSTRUMENTATION WITH REVISE 0 SURVEILLANCE FREQUENCIES Isolation Actuation Instrumentat.120 TS Location

1. Reactor Yessel Water Level 3* T 4.3.2 1

2. Reactor Vessel Water Level 2* T 4.3.2 1

3. Reactor Vessel Water Level 1* T 4.3.2-1 &

4.3.6.7 1

4. Drywell Pressure High* T 4.3.2 1 &

4.3.6.7 1

5. Main Steam Line Prest.ure Low

T 4.3.2 1

6. Main Steam Line flow - High* T 4.3.2 1 &

4.3.6.7-1

7. Main Steam L!.no Tannel Temp - High* T 4.3.2 1

8. Condenser Vacuum Low T 4.3.2 1

9. Drywell Radiation High T 4.3.2 1

10. Reactor Bldg Exhaust Radiation - High T 4.3.2 1

11. Refueling Floor Exh Radiation Higi T 4.3.2 1

12. RWCU Diff flow High* T 4.3.2 1

13. RWCU Area Temp High T 4.3.2 1 14, RWCU Area Diff Tenp High* T 4.3.2 1

15. HPCI Steam Line flow - High* T 4.3.2 1

16. HPCI Steam Supply Pressure Low

T 4.3.2 1

17. HPCI Turbine Exh Diaphragm Press - High* T 4.3.2 1

18. HPCI Pipe Penetration Rm Temp - High* T 4.3.2 1

19. HPCI Supp Pool Area Amb Temp - High* T 4.3.2 1 1

20. HPCI Supp Pool Area Diff Temp High* T 4.3.2 1

21. RCIC Supp Pool Area \mb Temp - High* T 4.3.2-1

22. RCIC Supp Pool Area Olff Temp - High* T 4.3.2 1

23. RCIC Steam line flow - High* T 4.3.2 1

24. RCIC Steam Supply Pressure Low

T 4.3.2 1

25. RCIC Turbine Exh Diaphragm Press - High* T 4.3.2 1

26. Reactor Steam Dome Pressure High* T 4.3.2 1

27. HPCI Emerg Area Cooler Temp - High* T 4.3.2 1

28. RCIC Emerg Area Cooler Temp - High* T 4.3.2 1

29. Turbine Bldg Area Temp - High T 4.3.2 1 ATIS Instrumentation 001166 HL-1453 El 16

=

o ENCLOSURE 1 (Continued) )

REQUES110 REVISC TECHNICAL SPECIFICATIONS: -

INSTRUMENTATION SURVEILLANCE RE0VIREMENTS BAllt FOR CHANGE RE0 VEST TABLE 2 (SHEET 2 0F 2) i UNIT 2 INSTRUMENTATION WITH REVISED SURVEILLANCE FREQUENCIES ECCS Instrumentation TS Location

-1 Reactor Vessel Water Level 1* T 4.3.3 1

2. Drywell_ Pressure High T 4.3.3 1 ,

3. ReactorStmDomePressure-(ow(Closure)* T 4.3.3 1 i

4. Reactor Shroud Water Level.O T 4.3.3 1

5. Reac Stm Dome Pressure Low T 4.3.3 1 Reactor Vessel Water Level 2*(Injection)*

6.. T 4.3.3 1 &

~

4.3.4 1

7. HPCI Condensate Storage Tank Level Low T 4.3.3 1 .

8. . HPCI Supp Chamber Water Level High* T 4.3.3 1

9. Reactor Vessel Water level 8* T 4.3.3-1

10. Reactor Vessel Water Level 3* . _ T 4.3.3 1

11. CS Pump Discharge Pressure High* T 4.3.3 1

- 12. RHR Pump Discharge Pressure High* T 4.3.3 1

- 13. RCIC Condensate Storage Tank Level Low T 4.3.4 1 ,

- 14. RCIC'Supp. Chamber Water L u el - High T 4.3.4 1 i

LEGEND:

- T - Table S Specification

ATTS. Instrumentation 001166-HL-1453- El 17 ep-ev- S - - 9,w-w>- g,.p.,.ww,_y,,,,,,c.%,,_,seg9,p.gwm,%w,,wy,,. -.ppy,,,, gy-w w g ,v.-*,y y.-m*rgw,,p. g-49 Wear % % e-w-We--i6-9.+eT"+yw37--ew-

- ~ . - - . . - - . . - - . - - . ~ . . - - . - - - - - . - - . . . - - . - .

j< .

)-e- ,,

ENCLOSURE 1-(Continued) ,

REQUEST TO REVISE TECHNICAL SPEClflCATIONS:

INSTRUMENTATION SURVEILLANCE RE0VIREMENTS BASIS FOR CHANGE RE0 VEST

-TABLE 3 i

UNIT 1 ISOLATION ACTUATION INSTRUMENTATION Current Table

Instrument Location

HPCI Emergency Area Cooler Ambient Temp 3.2 2 HPCI Steam Supply Pressure 3.2 2 HPCI Steam Line Differential Pressure 3.2 2 HPCI: Turbine-Exhaust Diaphragm Pressure- 3.2 2 HPCI Suppression Chamber Area Ambient Temp 3.2 2 HPCI Suppression Chamber Area Diff Air Temp 3.2 2 RCIC Emergency Area Cooler Ambient Temp 3.2-3 RCIC Steam Supply Pressure 3.2 3 RCIC Steam Line Diff Pressure 3.2 3

'RCIC Turbine Exhaust Diaphragm Pressure 3.2 3 RCIC Suppression Chamber Area Ambient Temp 3.2 3 L RCIC'Suparession Chambei>LArea Diff Air Temp '

3.2 3 Reactor lessel. Steam Dome Pressure 3.2 5 t

+

LC0 table identified only. Same change noted on SR tables and associated Bases.1 t

001166-

- HL-'1453 El 18 ,

.--~:-% , , ,,*m,,,+_.--,--*.~.-.----,, . - . ~ , . . . , - , . , , , ,,,,,,,,,,..,,,w,-.y.-,,w,--,-.m.,y,-.--.......--.c,,,.-,

. ,- ,-,---.+, .--~w w ,,,.w

l 8

ENCLOSURE 2 EDWIN 1 HATCH NUCLEAR PLANT UNITS 1,2 NRC DOCKET 50 321 AND 50-366 I OPERATING LICENSES OPR 57 AND NPT 5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS

'WSTRUMENTATION SURVEILLANCE REQUIREMENTS 10 CFR 50.92 EVALVATION .

PROPOSED CHANGE ONE:

As discussed in Enclosure 1, this pro >osed change revises the ECCS and isolation actuation instrumentation c1annel functional test frequencies-

. from monthly to quarterly. This change also provides for extended A0Ts for i surveillance (6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ) and repair (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ), with one or more channels of one subsystem removed from service. The affected instrumentation for Units 1 and 2-is supplied in Tables 1 and 2, respectively, of Enclosure 1.

Basis for Proposed Chanae One:

GeorgiaPowerCompany(GPC)hasreviewedtheproposedchangeanddetermined it does not involve a significant hazards consideration based on the following: y

1. This: change does not involve a significant increase in the probability

or consequ6nces of an' accident, since-the change results from GT,

' Topical Reports NEDC 30936P A and NEDC 31677P A, which provide a.

_probabilistic buis for extending ECCS and- isolation actuation instrumentation. surveillance intervals. 'These reports have been generically endorsed by the NRC. Adoption: of these enhancements will provide a more consistent and c.orrect system of ECCS and isolation-actuation surveillances for both Plant Hatch units. GPC has reviewed.

Plant- Hatch's specific design and determined the GE Topical _ Reports -

envelope the Plant' Hatch design. Therefore, the proposed change does 4 not- involve a-significant increase in the probability or consequences-of an accident.

2. The possibility of. a different kind of aceident from any analyzed-previously is not created by this change, sinc! no change-is being made to degrade the design, operation,. or maintenance of the plant and a new mode of failure is not created.

3. -The' proposed change does-not , involve a significant reduction in a-margin of _ safety, since the_ referenced GE Topical Reports provide ..

results indicating the requested interval extensions will not J

negatively affect the functional capability or reliability - of the affected systems. Also, GPC .has determined existing setpoint calculations for the affected instrumentation will not be affected by these changes.

001166 HL-1453 E2 1 l

4 i ENCLOSURE 2 (Continued) 4 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVElllANCE RE0VIREMENTS 10 CFR 50.92 EVALUATION PROPOSED CHANGE TWO:

As discussed in Enclosure 1, this proposed change moves the instrumentation, which initiates isolation of H)Cl, RCIC, and the Low Pressure Coolant Injection (LPCI). mode of RHR, from Phnt Hatch Unit 1 LCO TS Tables 3.2 2, 3.2-3, and 3.2 5 (and their corresponding surveillance tables) to Unit 1 LCO Table 3.2 1 and surveillance Table 4.2 1. Also, for clarity, Unit 1 Tables 3.2 1 and 4.2 1 have been renamed to indicate the isolation actuation function, and the Table of Contents has been revised and reorganized te reflect these changes.

Basis for Pronosed Chance IE2

4 Georgia Power Company has reviewed the proposed change and determined it does not-involve a significant hazards consideration based on the following:

1. The change does not involve a significant increase in the probability or consequences of an accident, since the change is consistent with the GE BWR 4 STS and the Plant Hatch Unit 2 TS No physical change to the facility or its operating parameters is being made. This change will clarify the identification of the isniation actuation instrumentation.

2.- The proposed change does-not create the possibility of a different kind of accident from any analyzed previously, since moving the instrumentation which initiates-isolation of the ECCS systems does not degrade the design, operation, or maintenance of the plant and a new mode of failure is not created.

3. Margins of safety are not significantly reduced by the proposed change, since moving tho'affected instrumentation to Unit 1 Table 3.21 will result in a more ap)ropriate applicaticn of the Action Statements.

Also,- the proposed c1ange will result in the Plant Hatch Unit 1 TS Action Statements being more consistent with the GE BWR 4 STS and the Plant Hatch Unit 3 TS. Therefore, incorporating this change will not significantly reduce any margin of safety 001166 :

HL-1453 E2 2 i

I

... 1;a . , - . . , -

. , - - . _. _ a ..a -. _ _ . - . . . . _ . _...

O ENCLOSURE 2(Continued)

REQUEST TO REVISE TECHNICAL SPEClf! CATIONS:

INSTRUMENTATION SVRVEILLANCE RE0VIREMENTS 10 CFR 50.92 EVALVATIOS PROPOSED CHANGE THREE: j This proposed change adds the following note to certain instrumentation tables and specifications in both units of the Plant Hatch TS:

A channel may be removed from service for up to hours for I required surveillance testing and not be considered () inoperable, i provided sufficient channels are available to ensure the required function.

As discussed in Enclosure 1, the amount of time provided in the note depends on the normal amount of time required to perform the associated maintenance. The proposed revised tables and specifications are listed in Enclosure 1.

Basis for proposed Chance Threr:

Georgia Power Company has reviewed the proposed change and determined it does not involve a significant hazards consideration based on the following:

1. The )roposed change does not involve a significant increase in the proba)ility or consequences of an accident, because the proposed surveillances are already-necessary to comply with TS, and adoption of this change merely provides for a reasonable A0T for the surveillance to be performed. Removal of this instrumentation from service for surveillance has been shown to have no effect on the probability of an accident and an insignificant effect on the consequenec; of an accident. For these reasons, the response of the plant to previously evaluated accidents will remain unchanged.

2. The proposed change does not create the possibility of a new or different kind of accident from any previously evaluated, since no change is being made to degrade the design, operation, or maintenance of the plant. No new modes of failure are created.

3. Margins of safety are not significantly reduced, since the proposed change maintains reasonable A0Ts for the instrumentation to perform design functions. In addition, the proposed change provides for conditions of operation which will preserve'the ability of the system to perform its intended function even during periods when instrument channels may be out of service for maintenance. Therefore, the proposed change does not reduce any margin of safety.

001166 HL 1453 E2 3

i ENCLOSURE 2 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVElllANCE RE0VIREMENTS 10 CFR 50.92 EVALVATION PROPOSED CHANGE FOUR:

As discussed in Enclosure 1, minor changes to the RPS and the control rod block instrumentation surveillances have been proposed in order to further incorporate the improvements presented in GE Tcpical Report NEDC-30851P-A i and Supplement I to NEDC 30851P A.

Sn it for Proposed Chance Four:

Georgia Power Company has reviewed the-proposed change-and determined it aucs not involve a significant hazards consideration based on the following:

1. The proposed change does not involve a significant increase in the probability or consequences ~ of an accident, since the change is bounded by -the NRC SER for methodology of NEDC-30851P A and its Supplement 1.

In addition, due to less frequent testing of the RPS, there are fewer g challenges to the safeguards system. This conservatively results in a- 4 decrease in core damage frequency. Also, since the cumulative effect of instrumentation tests does result in'some radiation exposure, an increase in the required surveillance intervals would represent a savings.in potential exposure.

2. The possibility of a different kind of accident from any analyzed-previously is not created, since the RPS and the control rod block functions and reliabilities are not degraded by this change. Also, no new-modes of plant operation-are involved.

3. Margins of safety are not significantly reduced, since the change has been evaluated and found acceptable by the NRC, and is bounded by the generic SER.

001166 HL-1453 E2-4

i "

ENCLOSURE 2 (Continued)-

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVElllANCE RE0VIREMENTS =

10 CFR 50.92 EVALUATION PROPOSED CHANGE FIVEi

- This proposed change will incorporate minor editorial corrections made to various -TS for both Plant Hatch units.

B3 sis-for Proposed Chance 5:

Georgia Power Company has reviewed the proposed change and determined it does' not involve a significent hazards considerations based on the ,

following:

i 1.--This change does not involve a significant increase in the probability or _ consequences of an accident, sir,ce the plant analytical limits will remain unchanged. The changes are only editorial in nature and do not constitute any technical change to the TS.

2.: The. possibility of a different kind of accident from any analyzed previously- is not created by this change, since no system function or reliability is being degraded. No new modes of plant operation are involved.

3. The proposed change does not involve a significant reduction in a margin of safety, since the change is editorialiin nature. Safety analysis assumptions and. equipment performance are not changed:in any )

way.-

.'t 001166 HL-1453 E2-5

- _- ~ - . - .- . . . - . . - - . _ - .

ENCLOSURE 3 EDWIN 1. HATCH NUCLEAR PLANT - UNITS 1, 2 NRC DOCKETS 50-321, 50 366 OPERATING LICENSES DPR 57, NPF-5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SVRVElllANCE RE0VIREMENTS pAGE CHANGE INSTRUCTIONS The proposed changes to the Plant Hatch Units 1 and 2 Technical Specifications will be incorporated as follows:

PjLqq Inst ructior:

UNIT 1 i Replace

-vii Replace .

viii- Replace

-3.1-6 Replace 3.1-15 Replace 3.l'-16 Replace 3.1 17 Replace 3.1-18 . Repl ace Figure 4.1-1 Replace 3.2-1 Replace 3.2-2 Replace .,

.3.2-3a Add 3.2-3b Add 3.2-4 Replace 3.2-5 Replace 3.2-6L Replace 3.2-7 Replace 3.2 Replace 3.2-9a Replace 3.2-10 Replace 3.2-11 Replace 3.2-12 Replace 3.2-13 Replace 3.2-14 Replace 3.2-15 Replace 3.2-16 - Repl ace -

3.2-16a Replace 3.2-17 Replace 3.2 18 Replace 3.2 19 Replace 3.2-20. -Replace 3.2-21 Replace.

3.2-22 Replace C 66

h A53 E3-1

r 4

.: 1

-ENCLOSURE 3 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVEILLANCE RE0VIREMENTS PAGE CHANGE INSTRUCTIONS Egg Instruction UNIT 1 3.2-22a Replace 3.2 23a Replace 3.2 23b Replace 3.2-23c Replace 3.2-23d Replace 3.2-24 Replaco 3.2 25 Replace 3.2-26 Replace 3.2-27 Replace 3.2-28 Replace i 3.2 29 Replace 3.2-30 Replace i 3.2-31 Replace 3.2-33 Replace 3.2-35 Replace 3.2 38 Replace 3.2-40 Replace 3.2-42 Replace 3.2-43 Replace 3.2-45 Replace 3.2-46 Replace 3,2 47 Replace 3.2-50 Replace-3.2-52 Replace !

3.2-53 Replace 3.2-54 Replace i 3.2 Replace -

3.2-56 Replace

-3.2 Replace 3.2-57a- Add 3.2-57b Add !

3.2-60: : Replace 3.2-69 _ Replace 3.2-70 Replace 3.2-71 ' Discard Figure 4.2-1 Discard 3.5-11 Replace 3.6-9 Replace 3.6-9a Replace 3.7 Replace 3.9-4' Replace 001166 HL-1453 E3-2 L-

m.

'l? e _.s ENCLOSURE 3 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTR 0MENTAT10N SURVEILLANCE RE0VIREMENTS- ,

PAGE CHANGE INSTRUCTIONS EAge Instruction UNIT 1 3.14 1- Replace -l 3.14 7 Replace 3.14 8 Rep 1 ace .

3.14 .Replaco

-i

?

< 001166-

HL-1453- E3-3

_ l 8'

ENCLOSURE 3 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVEllLANCE RE0VIREMENTS PAGE CHANGE INSTRUCTIONS UNIT 2 18 e 3/4 1-17 Replace 3/4 3-1 Replace 3/4 3 Replace 1 3/4 3-10 Replace 3/4 3-15 Replace 3/4 3 21 Replace 3/4 3 22 Replace '

3/4 3-23 Replace 3/4 3 24 Replace 3/4 3 26 Replace

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3/4 3-41 Replace !

3/4 3-44 Replace

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3/4 3-58d' Replace !

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3/4 4-4a Replace 3/4 4-5 Replace.

3/4 5-6 Replace

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ENCLOSURE 3 (Continued)

LREQUEST-T0 REVISE TECHNICAL-SPECIFICATIONS:

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ML20029A827: Difference between revisions

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