Text

Application for Amends to Licenses DPR-57 & NPF-5,modifying Instrumentation SRs by Adding Action Statements Which Allow Instruments Channels to Be Inoperable for Required Surveillance Testing W/O More Restrictive Actions
	ML20092B838
Person / Time
Site:	Hatch
Issue date:	02/04/1992
From:	Beckham J; GEORGIA POWER CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20092B841	List: HL-1453, Application for Amends to Licenses DPR-57 & NPF-5,modifying Instrumentation SRs by Adding Action Statements Which Allow Instruments Channels to Be Inoperable for Required Surveillance Testing W/O More Restrictive Actions; ML20092B848;
References
	HL-1453, TAC-M79919, TAC-M79920, NUDOCS 9202110155
	Download: ML20092B838 (35)
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HL 1453 001166 rebruary 4, 1992 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 SURVElllANCE RE0VIREMENTS s' NRC TAC Nos. H79919 and M7991Q Gantlemen:

In accordance with the provisions of 10 CFR 50.90, as required by 10 CFR the Plant Hatch (Units 1 and 2 Technical Specifications (TS), Appendix A to50.5 Operating Licenses DPR-57 and NPF 5. These changes are the result of extensive discussions with NRC staff personnel and supercedes our submittal of February 26, 1991 in its entirety.

The pioposed changes modify various instrumentation surveillance requirements for both Hatch units. Specifically, ACTION statements have been added which allow instrument channels to be inoperable for required surveillance testing without initiating more restrictive actions. Also, the functional test intervals on selected instrumentation will be extended, based on NRC-approved methodology. To accomplish these objectives,the following T5 changes have been included in this proposed amendment:

1. The channel functional test frequency of various Emergency Core Cooling System (ECCS), control rod block and isolation actuation instrumentation has been changed from monthly to quarterly. Also, a 6-hour allowable outage time (A0T) for surveillance and a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months A0T for repair have been provided in the action statements. 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, NEDC-30851P A, NEDC-31677P-A (References 1, 2 and 3), and GENE-770-06-1 (Reference 5).

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U.S. Nuclear Regulatory Connission February 4 1992 Page Two

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 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 TS surveillances can be performed without entering LCO Action statements.

4. The channel functional test frequency of the Reactor Protection System (RPS) instrumentation surveillances are also proposed to be changed from monthly to quarterly with a 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months A0T for required surveillance testing.

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 TS pages, along with a marked-up copy of the current IS pages, follow Enclosure 3.

To allow time for procedural revisionr 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 S0.91, a copy of this letter and all applicable enclosures will be sent to Mr. L. Barrett of the Environmental Protection Division of the Georgia Department of Natural Resources.

x HL-1453 001166 1

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U. S. Nuclear Regulatory Commission February 4, 1992 Page Three Mr. J. T. Beckham, Jr. states he is Vice President of Georgia Power )

Company and is authorized to execute this oath on behalf of Georgia Power i Company, and to the best of his knowledge and belief, the facts set forth ;

in this letter are true.

GEORGIA POWER COMPANY ,

, gy: I

, J.1. Beckham, Jr/

SworntoandsubscribedbeforamethisEdddayofhuv4iA4o 1992.

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References:

1. NEDC-30936P-A, "6WR Owners' Group Technical Specification improvement <

Methodology (With Demonstration for BWR ECCS Actuation Instrumentation)", June 1987.

2. NEDC 30851P-A, " Technical Specification Improvement Analysis for BWR Reactor Protection System", March 1988.

l

3. NEDC-31677P-A, " Technical Specification Analysis for BWR ! solation Actuation Instrumentation", July 1990.

4. HEDC-30851P-A. Suonlement 1, " Technical Specification Improvement '

Analysis for BWR Control Rod Block Instrumentation",.0ctober 1988.

+

5. . GENE-770-06-1, " Bases for Changes to Surveillance Test Interva!s and Allowed Out-0f-Service Times for Selected Instrumentation Technical

-Specifications", February 1991.-

Enclosures:

1. Basis for Change Request

2. 10 CFR S0.92 Evaltiation s

3. Page Change Instructions f

HL-1453 001166 -

U. S. Nuclear Regulatory Comission February 4, 1992 Page Four c: Georoia Power Company Mr. H. L. Sumner, General Manager Plant Hatch NORMS U. S. Nuclear Reaulatory Comission. Washinoton. D. C.

Mr. K. Jabbour, Licensing Project Manager - Hatch

0. S. Nuclear Reaulatory Comission. Reaion 11 Hr. S. D. Ebneter, Regional Administrator Mr. L. D. Wert, Senior Resident inspector - Hatch State of Geqrgi1 Mr. L. Barrett, Comissioner - Department of Natural Resources llL-1453 001166

ENCLOSURE 1 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 REOUjREMENTS DASIS FOR CHANGE RE0 VEST PROPOSED CHANGE ONE:

This pro >osed change revises the Emergency Core Cooling System (ECCS),

rod bloc ( and isolation actuation instrumentation channel functional test interval from monthly to quarterly. The affected Technical Specifications (TS) instrumentation for Units 1 and 2 is listed in Tables I 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 functirial 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. The proposed 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months A01 for surveillance has been included (either added in a new footnote, revised in an existing footnote, or added as an Action statement) in the following tables and specifications:

Unit 1 - Tables 3.2-1 through 3.2 7 and Table 3.2-9 Unit 2 - Specifications: 3.1.4.3, 3.3.2, 3.3.3, 3.3.4 and 3.3.5.

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

One instrument chanitel may be inoperable for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to perform required Surveillances prior to entering other applicable Actions.

001166 HL-1453 El-1

ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

1RSTRUMENTATION SVRVEILLANCE RE0VIREMENTS BASIS F03 CHANGE RE0 VEST Next. Unit 1 TS Table 3.2-1 and Unit 2 Specification 3.3.2 have been revised to provide a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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 Specification 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 the ino)erable channel (s) in the tripped condition wit 1in 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 3.2-1 for Unit 1)

The provisions of Specification 3.0.4 are not applicable.

[ Specification 3.0.4 is not contained in the Unit 1 TS.)

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 TS Bases Section 3/4.3 (forRPS) have been revised appropriately to reflect the above changes.

Finally, in accordance with General Electric Topical Report NEDC 31677P A (Reference 3), this proposed change isesrev(GE) 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 i

Technical Specifications (STS), as well as with all channel checks, i

001166 HL-1453 El-2

ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNIC /.L SPECIFICATIONS:

INSTRUMENTATION SVRVEILLANCE RE0VIREMENTS BASIS FOR CHANGE RE0 VEST Hasis for Proposed Chanae One:

This pro)osed change is justified based on information contained in GE Topical leportsNEDC30936PA(Reference 1),NE00-30851PA, Supplement 1 (Reference 4), NEDC-31677P A (Reference 3), and GENE-770 06-1 (Reference 5). The subject reports provtde a probabilistic basis for extending ECCS, rod block. isolation actuation and other instrumentation surveillance intervals. . The generic analyses provided in these reports indicate the pro >osed interval extension (from monthly to quarterly) can be enacted l witicut negatively affecting the functional capability or reliability of i the_ systems. An NRC Safety Evaluation Report (SER) generically endorsing .

the methodology and changes provided in the referenced reports is provided l at the beginning of each report, except for the GENE-770-06-1 report. '

Preparation by the NRC of the SERs for the GENE 770-06 1 report is currently in progress. 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 isolation actuation instrumentation for the Reacte Building radiation, refueling floor radiation and Control Room inlet radiation (Unit 1 Table 4.2 8 and Unit 2 Table 4.3.2-1), the setpoints are field determined. GPC has reviewed the operating history of these instruments and determined the instrument drift is small enough to justify a quarterly channel functional test frequency.

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.

There were several instruments of low significance that were not included in the GE Topical reports. The following discussion describes those 001166 HL-1453 El-3

ENCLOSURE I (Continued)

REQUEST TO REVISE TECHNICAL SPEClf!CA110NS:

INSTRUMENTATION SURVEILLANCE RE0VIREMENTS BASIS FOR CHANGE REMil instruments and includes bases to justify a change to a quarterly channel functional test frequency.

1. Drywell Radiation High (Units 1 & 2)

The logic for this instrumentation is one out of one for each isolation valve (two redundant isolation valvesareprovided).

In addition, the instrumentation does not trip until a relatively high radiation level exists in the drywell. The valves are normally closed during plant operation and are opened only during drywell purge and vent. The probability of having a ,

high radiation level when an isolation valve is open is very '

lows therefore, this situation was not explicitly modeled.

Because of the relatively low significance of this instrumentation, the functional test frequencies can be changed from monthly to quarterly.

2. Reactor Shroud Water Level (Level 0) (Units 1 & 2)

This instrumentation prevents diversion of some LP01 flow to containment spray (a manually initiated function) whnn the vessel water level is low (Level 0). The level 0 trip can be bypassed if failure occurs. Therefore, the effect of failure of the Level 0 signal has a negligible effect on the overall ECCS unavailability and was not explicitly modeled. Because of the relatively low significance of this instrumentation, the functional test frequencies can be changed from monthly to quarterly.

3. HPCI and RCIC Pump Suction Pressure - Low (Unit 1)

This instrumentation provides HPCI and RCIC turbine protection for Unit 1. Two redundant valves exist for HPCI and RCIC. The logic of the instrumentation is two out of two; the valve trias HPCI or RCIC turbine on low suction pressure. Based on t ie above, the effect of failure of the pump suction signal has a negligible effect on the overall ECCS unavailability and was therefore not explicitly modeled. Because of the relatively low significance of this instrumentation, the functional test frequencies can be changed from monthly to quarterly.

001166 HL-1453 El-4

[NCLOSURE1(Continued)

REQUEST TO REVISE TECHNICAL SPEClflCATIONS: )

INSTRUMENTATlBUiUM[jlLANCE RE0VIREMENTS i Basis FOR CHANGE RE00111

4. HPCI and RCIC Pump Discharge flow +High/ Low (Unit 1)

With this instrumentation, failure in HPCI Lor RCIC) minimum flow bypass line would be detected dur<ng turbine pump functional test. The effect of failure of the pump discharge flow signal was >reviously analyzed as part of the pump failure.

Because of_ t 1e relatively low significance of this instrumentation, the functional test frequencies can be changed from monthly to quarterly.

5. filled Discharge Pipes Level Switches of HPCI, RCIC, CS and LPCI (Unit 1 Only)

Currently, filled discharge pipes are checked during CS and LPCI pump tests. Level switches perform only a monitoring function and therefore do not have a significant effect on the overall ECCS unavailability. Because of the relatively low significance of this instrumentation, the functional test frequencies can be changed 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 (AT15). As documented in GPC letters to the NRC dated July 24, 1985 and January 23, 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 interv41 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 AT15 surveillance test data from Plant Hatch. The referenced GE Tsalcal 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 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months A0T for repair, for clarity, GPC has made some editorial revisions to the w A0T note provided in the GE Topical Reports: the intent of the note et been changed. GPC has revised the isolation actuation Action

, sent for operation with a channel inoperable to achieve consistency 001166 HL 1453 El-5

ENCLOSVP.E1(Continued)

REQUEST 10 REVISE TECHNICAL SPEClflCATIONS:

I NST RUMENT AT ION SURVE ll L A4LLELQQl RE ME NT S MSIS FOR CHtME RE0VESI with the Action Statement revisions provided in NEDC 31677P A. With one trip system inoperable, the A0T proposed for the Units 1 and 2 TS is 12 l hours. With both trip systems inoperable, the A0T will remain I hour.

This allows for consistency with the RPS instrumentation Action Statements approved for Plant Hatch. In addition to the proposed 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months A0T note, Unit 1 Table 3.2-7 Notes and Unit 2 Table 3.3.5 1 Notes for Control Rod Withdrawal Block Instrumentation contains an additional note. For Unit 1, the following note has been added, " Withdrawal of control rods is not permitted during required surveillance testing" for Unit 2, the following note has been added, ' Control rods cannot be withdrawn during channel functional testing and/or channel calibration." These notes are provided to assure that no control rods are withdrawn while allowing the required surveillances to be performed.

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 trip functions are designed such 1 that the removal of one trip system / channel could render the trip function inoperable. Previous conversations with the NRC staff resulted in an additional justification for this proposed note for those instruments that are included in the GE GENE and To)1 cal Reports since it does not contain a provision for providing one operaale channel in the same trip system for monitoring pur>oses. Justification for not using a provision of this kind is based on 11e instrumentation trip initiating logic and design. The following exemples for HPCI discuss this fact:

1. In the case of the HPC1 Pump Hinimum flow valve open signal (one out-of one logic), there is only one channel in the trip system; by design, this system is not single failure proof. However, other plant systems are available for high pressure transients.

2.An We example of initiating logic is the HPCI Reactor Water Level 8 Lete lignal (two-out-of-two logic). In this case, the single failure crit - 4 ic not maintained since these instruments of HPCI were not agh 11y designed as such. Both channels in "

to ce ze in order for the trip function to initth,histe.system Therefore, have if w ' channel is out for testing, the other channel is providing no s) sten trip capability.

001166 HL 1453 El-6

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ENCLOSURE 1 l (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUNENTATION SURVEILLANCE ELQ41REBENIS BASIS FOR CHANGE REQUEST

3. A third example is with #he HPCI Low Steam Line Pressure isolation ,

trip signal (two out ot two per division). Even though the )rovision !

can be applied, it has little meaning. In addition to tie other !

in the same trip system monitoring the parameter, the other channel trip system continues to hth monitor the parameter and provide a :

trip. The channel in the same trip system is providing no system trip capability and its monitoring function is alreedy be< ng performed by i the other trip system.

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

Approval of the proposed changes will result in consistent and accurate ;

rod block and isolation actuation instrumentation surveillance ECCS, requirements for.both Hatch units. !

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.001166 4 HL-1453- El-7 ,

L 1 . . .

ENCLOSVRE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPEClflCATIONS:

INSTRUMENTATION SUM EILLANCE RE0VIREMENTS flASIS FOR CHANGE RM[11 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 surveillance tables) to Unkt 1 LCO Table 3.2 1 and surveillance table 4.2-1. This permits the application of consistent Action Statements to the isolation actuation instrumentation. 1his change is consistent with the GE BWR 4 STS and the Plant Hatch Unit 2 TS. The specific instruments being moved are listed in Table 3 of this enclosure.

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 to reflect these changes.

Basis for Provo3rd Chance Twn:

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 HEDC 30936P A (Reference 1) and NEDC 31677P A (Reference 3), and the differences in instrument function .

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 001166 HL 1453 El-8

ENCLOSURE 1 (Continued) ;

REQUEST TO REVISE TECHNICAL SPECIFICATIONS: I INSTRUMENTATION SURVEILLANCE REQUIREMENTS f BASIS FOR CHANGE RE0 VEST actuation table (as in the Plant Hatch Unit 2 TS and the GE BWR.4 STS), GPC propose; the fol10 wing Unit 2 Action Statement be adopted: l Close the shutdown cooling supply isolation valves unless reactor i a

steam dome pressure 1145 psig. ;

The revised Action Statement is being proposed, since the inoperability of the reactor steam dome pressure instrument will not directly impact the 1 operability of the LPCI system. This change is consistent with the Plant Hatch Unit 2 TS and the GE BWR 4 STS.

PROPOSED CHANGE THREE: :

1 This proposed change' adds the following note (as in the case of ECCS, rod ;

block and isolation actuation instrumentation as discussed in Proposed Change One)to certain instrumentation tables and specifications in the '

Plant Hatch Units 1 and 2 TS:

One instrument channel may be. inoperable for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to perform required Surveillances prior to entering other applicable Actions.

3 1

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ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPECiflCATIONS:

INSTRUMENTATION SURVEILLANCE RE0VIREM[HIS MS11JOR CMNGE RMV111 ,

The following tables and specifications have been revised:

Unit 1 Unit 2 1 3.2 8 5 3.1.3.5 T 3.2-10 5 3.3.6.1 T 3.2 11 S 3.3.6.2 T 3.2 12 S 3.3.6.3 T 3.2-14 S 3.3.6.4 S 3.14.1 S 3.3.6.5 T 3.14.2 1 S 3.3.6.7 S 4.6.H.l.e S 3.3.6.9 S 4.6.H.2 S 3.3.6.10 S 3.3.8 5 3.3.9.1 S 3.3.9.2 S 3.4.2.1 S 3.4.2.2 S 3.4.3.1 S 3.5.3.1 ,

S 3.5.4.1 S 3.6.2.1 5 3.9.2 LEEWQ:

T - Table S = Specification Basis for Proposed Chance Three:

The Plant Hatch TS provide channel functional test and channel calibration frequencies. When performing the surveillances, the TS require the instruments to be "out of service" for a period of time. In order to assure the instrumentation is not removed from service for an excessive amount of time for surveillance, an A0T of 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.

i l 001166 l HL-1453 El-10

EHCLOSURE 1 (Cont m ed)

REQUEST TO REVISE TECHNICAL SPEClf! CATIONS:

INSTRUMENTATION SURVEILLANCE REQUIREMENTS Mils _f_0R CHANGE REQUEST The surveillances were developed to ensure the availability of instrumentation to perform its design function. Therefore, providing a reasonable A0T in which to perform the surveillances supports instrumentation in the performance of its design function. This instrumentation has generally less safety importance than the ECCS, RPS and isolation actuation instrumentation previously reviewed by GE and generically approved by the NRC. Since surveillances are required by the Technical Specifications and LCOs generally have extended time action statements, it is appropriate to have 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months A0Ts for thic instrumentation.

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, in addition, GPC's nuclear *:,am 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 3rimary success path of the design basis analysis / transient analysis. Tierefore, the bases for the A0T for these systems can be estabitshed based on the lower safety significance of these systems.

PROPOSED CHANGE FOUR:

This proposed change makes minor changes to the reactor protection system (RPS) instrumentation surveillances to further incorporate improvements presented in GE Topical Re) ort NEDC-30851P A (Reference 2). NEDC-30851P was previously approved by tie NRC for Plant Hatch specific applications in Amendment 170 for Unit I and Amendment 100 for Unit 2. In both units, the proposed note reads as follows:

One instrument channel may be inoperable for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to perform required surveillances prior to entering other applicable ACTIONS, provided at least one OPERABLE channel in the same trip system is monitoring that parameter.

l 001166 HL-1453 El-ll

I ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHN' 't. SPEClflCATIONS:

INSTRUMENTATION SURVElltnaCE RE0VIREMENTS MSIS FOR CHANGE RE0 VEST Specifically, for the Unit 1 TS, notes are )roposed to be added to Tables 3.1-1 to allow a channel to be made inoperaale 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, the 6-hour note has oeen included in Specification 3.3.1. Also, the Unit 1 Bases for Specification 4.2 was revised to reflect the curr*nt information used to establish the surveillances, bsis for Proposed 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 2 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 A0T. The methodology shows the requested interval extensions can be enacted without negatively affecting the functional capability or reliability of the RPS. GPC has 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.

Approval of Proposed Change Four will result in consistent and correct RPS instrumentation surveillance requirements for both Hatch units.

001166 HL-1453 El-12

ENCLOSURE 1(Continued)

REQUEST 10 REVISE TECHNICAL LPECIFICATIONS:

INS 1RUMENTATION S RYEILLANCE RE0VIREMENTS BASIS FOR CHANGE RE0 VEST ERQjh)liED CHANGE FIVE:

This proposed change incorporates minor editorial corrections made to various TS for both Plant Ha'ch units. These proposed corrections include: l l

1. Unit 1 Tables 3.2-5 and 4.2-5. Since the reactor vessel steam dome pressure -

low permissive instrument is being deleted from I these tables, the remaining two reactor vessel steam dome pressure-low i instruments are being uniquely identified.

2. Unit 1 Tables 4.?-l and 4.2-2 (note d), and Tables 4.2-8 and 4.2-10 (note e). These notes, which concern instrument functional 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 bten deleted from the proposed amendment.

4. Unit 2 Specification 4.3.1.1. The word "FUNC110N" has been changed to

" FUNCTIONAL" in referer;ing a channel functional test.

5. Unit 2 Spectitcation 4.3.1.3. Th; word "were" found in the last sentence of this paragranh has been changed to "where'.

6. Unit 2 page 3/4 ?- 'n the footnote, second line, the word

" conditions" has beu err a to " condition".

7. Unit 2 Table 3.3.5-1. for Trip Function, ttem 5.a. Water Level -

High, the number "1" has been added under the column entitled Minimum Number of OPERABLE Channels Per Trip Function,

8. Unit 2 Table 3.5.6.2-1. For instrument number 3.b (Reactor Building 185' Level), the number "1" 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".

001166 HL-1453 El-13

ENCLOSUREl-(Continued)

, REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVEILLANCE RE0VIREMENTS BASIS FOR CHANGE RE0 VEST

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

11. -Unit 1 Specification 3,6.H.l.a. In reference note "*** at bottom of page, the word "Reflief" has been replaced with the word " Relief".

12. Unit 1 Table 4.2-10 Reference Number 3. The word *Particlates" under the Instrument descriptior column has be replaced. with the -word "Particulates".

13. Unit 1 Table 3.2-4. Previous submittal (August 30,. 1990) to NRC-included this page with a : revision to note b (Amendment 170). This

-package reinstates the note as it read in Amendment 170, after the mte was inadvertently changed by a subsequent-amendment (No. 173).

n i ic.r Pronosed Chance Five: I

'he bu 45 for-the proposed changes described above are as follows:

L TN remaining two reactor vessel steam dome pressure-- low instruments.

are being uni'uely identified for clarity (as proposed instrument numbers 3 and 4 thetables). ,

2. Since notes d and e- are archaic wh respect to the TS, they have been

, deleted from the proposed amendment.- The test-frequency will remain i once per month,-unless otherwise identified in this proposed amendut.

3. Sir h- functional testing requirements for the subject relays of t' ic systems are already fully required by Unit 1 Tables 4.2-12 a , ,, -13, the specification should not have to be- restated.

T arar re, 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.

l'

'001166 HL-1453 El-14

ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVE!LLANCE RL0VIREMENTS BASIS FOR CHANGE RE0 VEST

6. Inputting the word " conditions" was a typographical error in that one inoperable channel in one trip system is logica113 placed in a single

-tripped condition. Deleting the "s" from " conditions" is purely an editorial 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 "1" 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.

11. Inputting the word "Reflief" was a typographical error and, therefore, changing it to " Relief" is purely an editorial change.

12. Inputting the word "Particlates" was a typographical error and, therefore. changing it to "Particulates" is purely an editorial change.

13. Previous submittal on August 30, 1990 to the NRC contained this page with a modification to note b (Amendment 170). However, on October 9, 1990, GPC issued another submittal (Amendment 173) to the NRC which inadvertently used the note b that existed previous to Amendment 170.

In this submittal, GPC is using the correct version of note b (as it existed after Amendment 170); therefore, this correction is an editorial change.

001166 HL-1453 El-15

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

u i

i ENCLOSURE-1 (Continued)

' REQUEST- TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVEILLANCE RE0VIREMENTS. .

BASIS FOR CHANGE RE0 VEST' 1

REFERENCES:

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

2.- NEDC-30851P-A, ~ " Technical Specification Improvement Analyses ' for BWR

-Reactor Protection System," March 1988.

3. NEDC-31677P-A, " Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation," July 199G.

' 4.- .NEDC-30851P-A, Supplement .1 " Technical Specification Improvement

- Analyses for BWR Control Rod Block Instrumentation," October 1988.

5.- GENE-770-06-1,:" Bases for Changes to Surveillance Test Intervals and

. Allowed Out-0f-Service Times for Selected Instrumentation Technical :

Specifications", February 1991.

l:

p 001166 HL-1453 El-16 l

ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICA!. SPECIFICATIONS:

INSTRUMENTATION SURVEILLANCE REOUIREMENTS MSIS FOR CHANGE RE0MESl J TABLE 1(SHEET 10F2)

UNIT 1 INSTRUMENTATION WITH REVISED SURVEILLANCE FREQUENCIES i

Isolation Actuation Instrumentation TS Location !

1. Reactor Vessel Water f.evel 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

5. 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

T 4.2-1

10. RWCU Area Temperature

T 4.2-1

11. RWCU Area Ventilation Diff Temp

T 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 Steae 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

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 Temp *# T 4.2-1

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

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

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

24. RCIC Supp Chamber Area Amb Temp *# T 4.2-1

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-17

l l

ENCLOSURE 1 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SVRVEllLANCE RE0VIREMENTS BASIS FOR CHANGE RE0 VEST TABLE 1 (SHEET 2 0F 2)

UNIT 1 INSTRUHEN1ATION WITH REVISED SURVEILLANCE FREQUENCIES ECCS Instrumentation (Continued) TS location

5. Reactor Vessel Water Level B* T 4.2-2 & 4.2-3

6. HPCI Pump Discharge Flow

T 4.2-2

7. HPCI Condensate Storage Tank Level T 4.2-2

8. HPCI Suppression Chamber Water Level

T 4.2-2

8. RCIC Turbine Exhaust Pressure

T 4.2-3

9. RCIC Pump Suction Pressure

T 4.2-3

10. i'CIC Pump Discharge Flow

T 4.2-3

11. RCIC Condensato Storage Tank Level T 4.2-3

12. RCiC Suppression Pool Water Level T 4.2-3

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

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

15. Rx Vessel Stm Dome Press - Viv Closuro* 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 Control Rod Block APRH - Downscale T 4.2-7 LEGEND:

T = Table S - Specification

ATTS Instrumentation 001166 HL-1453 El-18

ENCLOSURE 1 (Continued)

REQUEST TO REVISE 1ECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVElllANCE RE0VIREMENTS BASIS FOR CHANGE RE0 VEST TABLE 2 (SHEET 1 0F 2)

UNIT 2 INSTRUMENTATION WITH REVISED SURVEILLANCE FREQUENCIES isolation Actuation Instrumentatioji TS Location l

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

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 Pressure - 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 Line Tunnel-Temp - High* T 4.3.2-1

8. Condenser Vacuum - Low I 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 - High T 4.3.2-1

12. RWCUDiffFlow-High* T 4.3.2-1

13. RWCU Area Temp High T 4.3.2-1 i

14. RWCU Area Diff Temp - High* T 4.3.2-1 l

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

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

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

22. RCIC Supp Pool Area Diff 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-19

l ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVEILLANCE REQUIREMENTS BASIS FOR CHANGE RE0VESI TABLE 2 (SHEET 2 0F 2)

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. Reactor Stm Dome Pressure - Low (Closure)* T 4.3.3-1

4. Reactor Shroud Water Level 0* T 4.3.3-1

5. Reac Stm Dome Pressure - Low (Injection)* T 4.3.3-1

6. Reactor Vessel Water Level 2* 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 Level - High T 4.3.4-1 Control Rod Block, APRM - Downscale T 4.3.5-1 LEGEND:

T = Table S - Specification

ATTS Instrumentation 001166 HL-1453 El-20

ENCLOSURE I (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVEILLANCE RE0VIREMENTS BASIS FOR CHANGE RE0 VEST TABLE 3 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 l 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 RCIC Suppression Chamber Area Diff Air Temp 3.2-3 Reactor Vessel Steam Dome Pressure 3.2-5

LCO table identified only. Same change noted on SR tables and associated Base 3.

l I

001166 HL-1453 El-21

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

INSTRUMENTATION S'JRVEllLANCE RE0VIREMENTS 10 CFR 50.92 EVALUATION PROPOSED CHANGE ONE:

As discussed in Enclosure 1, this proposed change revises the ECCS, rod block and isolation actuation instrumentation channel functional test frequencies from monthly to quarterly. This change also provides for extended A0Ts for 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 Proonsed Chance One:

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

1. This change does not involve a significant increase in the probability or consequences of an accident. GE Topical Reports NEDC-30936P-A, NEDC-30851P-A (Supplement 1), NEDC-31677P-A and GENE-770-06-1 provide a probabilistic basis for extending ECCS, rod block and isolation actuation instrumentation surveillance intervals. These reports have been generically endorsed by the NRC, except for the GENE-770-06-1 report, which is still under NRC review. Adoption of these enhancements will provide a more consistent and correct system of ECCS, i rod block 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 not involve a significant increase in the probability or consequences of an accident.

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

l 001166 HL-1453 E2-1

ENCLOSURE 2 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVEILLANCE RE0VIREMENTS 10 CFR 50.92 EVALUATION

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 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.

PROPOSED CHAtME_D[Q:

As discussed in Enclosure 1, 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 LC0 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 to reflect these changes.

Basis for Procosed Chanae Two: )

Georgia Power Company has reviewed the proposed change and determined it does not involve a significant hazards consideration based on the j 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 isolation 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 the affected instrumentation to Unit 1 Table 3.2-1 will result in a more appropriate application of the Action Statements.

001166 HL-1453 E2-2

ENCLOSURE 2 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVEILLANCE RE0VIREMENTS 10 CFR 50.92 EVALUATION Also, the proposed change 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 2 TS. Therefore, incorporating this change will not significantly reduce any margin of safety.

[$QPOSED CHANGE THREE:

This proposed change adds the followina note to certain instrumentation tables and specifications (as in the case of ECCS, rod block and isolation actuation instrumentation as discussed in Proposed Change One in Enclosure

1) in both units of the Plant Hatch TS:

One instrument channel may be inoperable for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to perform required Surveillances prior to entering other applicable Actions.

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 Procosed Chane d hree:

Georgia Power Company has reviewed the proposed change and determined it does 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, because the proposed surveillances are already necessary to comply with TS, and adoption of this change merely prevides 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 consequences 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.

001166 HL-1453 E2-3

l l

ENCLOSURE 2 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVElllANCE RE0VIREMENTS 10 CFR 50.92 EVALUATION

3. Margins of safety are ..ot 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.

PROPOSED CHANGE FOUR:

As discussed in Enclosure 1, minor changes to the RPS instrumentation surveillances have been proposed in order to further incorporate the improvements presented in GE Topical Report NEDC-30851P-A.

Basis for Proposed Chance Four:

Georgia Power Company has reviewed the proposed change and determined it does not involvt 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. In addition, due to less frequent testing of the RPS, there are fewer challenges to the safeguards system. This conservatively results in a 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 savir.gs in potential exposure.

2. The possibility of a different kind of accident from any analyzed previously is not created, since the RPS 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 i 1

HL-1453 E2-4

. ENCLOSURE 2 (Continued)

REQUEST TO REVISE TECHNICAL-SPECIFICATIONS:

INSTRUMENTATION SURVEILLANCE RE0VIREMENTS 10 CFR 50.92 EVALVATION PROPOSED CHANGE-FIVE:

This proposed change willLincorporate minor editorial corrections made to various;TS for both Plant Hatch units.

Basis for Proposed Chanae 5:

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

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

or consequences of an accident, since 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.

The1 proposed change does not . involve a significant reduction in a 3.

margin- of safety,- since the change is editorial in nature. Safety analysis assumptions and equipment performance are not changed in any way.

1-4 l

l L

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 SURVEILLANCE RE0VIREMENTS PAGE CllANGE INSTRUCTIONS The proposed changes to the Plant Hatch Units 1 and 2 Technical Specifications will be incorporated as follows:

Eagg Instruction UNIT 1 i Replace vii Replace viii Repl ace 3.1-6 Replace 3.1-15 Replace 3.1-16 Replace 3.1-17 Replace 3,1-18 Replace Figure 4.1-I Replace 3.2-1 Replace 3.2-2 Rep 1 ace 3.2-3a Add 3.2-3b Add 3.2-4 Replace 3.2-5 Replace 3.2-6 Replace 3.2-7 Replace 3.2-8 Replace 3.2-9 Repla:e 3.2-9a Replace 3.2-10 Replace 3.2-11 Replace 3.2-14 Replace 3.2-16a Replace 3.2-17 Replace 3.2-19 Replace 3.2-20 Replace 3.2-21 Replace 001166 HL-1453 E3-1

ENCLOSURE 3 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS: l INSTRUMENTATION SURVEILLANCE RE0VIREMENTS l PAGE CHANGE INSTRUCTIONS Eggg Instruction ,

UNIT 1 3.2-23 Replace 3.2-23a Replace 3.2-23b Replace l 3.2-23c Replace 1 3.2-23d Replace !

3.2-24 Replace 3.2-25 Replace 3.2-25a Add 3.2-26 Replace 3.2-27 Replace 3.2-28 Replace 3.2-29 Replace 3.2-30 Replace 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 3.2-49c Replace 3.2-50 Replace 3.2-52 Replace 3.2-52a Adci 3.2-52b Add 3.2-53 Replace 3.2-54 Replace 3.2-55 Replace 3.2-56 Rr. place 3.2-57 Replace 3.2-60 Replace 3.2-69 Replace 3.2-70 Replace 001166 HL-1453 E3-2

ENCLOSURE 3 (Continued)

REQUEST TO REVISE TECHNICAL-SPECIFICATIONS:

INSTRUMENTATION SURVEILLANCE RE0VIREMENTS EAGE_(UANCE INSTRUCTIONS l Eggg Instruction UNIT 1 3.2-71 Replace Figure 4.2-1 Replace 3.5-11 Replace 3.6-9 Replace 3.6 9a Replace 3,9-4 Replace 3.14-1 Replace 3.14-9 Replace 3.14-10 Replace i

I l

l l

1 001166 HL-1453 E3-3

ENCLOSURE 3 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVEILLANCE REQVIREMENTS PAGE CHANGE INSTRUCTIONS Eitgg Instructiga UNIT 2 3/4 1-8 Replace 3/4 1-17 Replace 3/4 3-1 Replace 3/4 3-5 Replace 3/4 3-Sa Add 3/4 3-9 Replace 3/4 3-9a Add 3/4 3-15 Replace 3/4 3-15a Add 3/4 3-21 Replace 3/4 3-22 Replace 3/4 3-23 Replace 3/4 3-24 Replace 3/4 3-31 Replace 3/4 3-32 Replace 3/4 3-33 Replace 3/4 3-34 Replace 3/4 3-36 Replace 3/4 3-37 Replace 3/4 3-38 Replace 3/4 3-39 Replace 3/4 3-41 Replace 3/4 3 43 Replace 3/4 3-47 Replace 3/4 3-50 Replace i

3/4 3-53 Replace 3/4 3-54 Replace 3/4 3-56 Replace 3/4 3-56a Add 3/4 3-58 Replace 3/4 3-58b Replace l 3/4 3-58d -Replace 3/4 3-60a Replace 3/4 3-60f Replace 3/4 3-63 Replace 3/4 3-66 Replace 3/4 3-66a Replace l

001166 HL-1453 E3-4 l

ENCLOSURE 3 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUMENTATION SURVEILLANCE REQUIREMENTS PAGE CHANGE INSTRUCTIONS Rigg Instruction UNIT 2 3/4 3-70 Replace i 3/4 3-72 Replace 1 3/4 3-75 Replace !

3/4 4-4 Replace l 3/4 4 4a Replace i 3/4 4-5 Replace ,

3/4 5-4 Replace 3/4 5-10 Replace 3/4 6-12 Replace 3/4 9-3 Replace B 3/4 3 1 Replace l

001166 HL-1453 E3-5

v t e Letter Sequence Request
TAC:M79919, (Open) TAC:M79920, (Open)
Initiation Request, Request Acceptance... Administration Questions Answers Results Approval... Other:
MONTHYEAR1992-12-21 [Table View]

HL-1453, Application for Amends to Licenses DPR-57 & NPF-5,modifying Instrumentation SRs by Adding Action Statements Which Allow Instruments Channels to Be Inoperable for Required Surveillance Testing W/O More Restrictive Actions

Text

References:

Enclosures:

REFERENCES:

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