View source for PY-CEI-NRR-0935, Application for Amend to License NPF-58,revising Tech Specs 2.1.2,3.2.1,3.2.2 & 3.2.3 Re Safety Limit Min Critical Power Ratio & Associated Power Distribution Limits for Fuel to Be Loaded Into Core for Second Cycle.Fee Paid

{{Adams
| number = ML20195K236
| issue date = 11/28/1988
| title = Application for Amend to License NPF-58,revising Tech Specs 2.1.2,3.2.1,3.2.2 & 3.2.3 Re Safety Limit Min Critical Power Ratio & Associated Power Distribution Limits for Fuel to Be Loaded Into Core for Second Cycle.Fee Paid
| author name = Kaplan A
| author affiliation = CLEVELAND ELECTRIC ILLUMINATING CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF ADMINISTRATION &amp; RESOURCES MANAGEMENT (ARM)
| docket = 05000440
| license number = 
| contact person = 
| document report number = PY-CEI-NRR-0935, PY-CEI-NRR-935, NUDOCS 8812050169
| package number = ML19295G771
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 11
| project = 
| stage = Request
}}

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{{#Wiki_filter:THE CLEVELAND ELECTRIC ILLUMIN ATING COMPANY PO BOX 97 s   PERAY, OHIO 44081 s    TELEPHONE (216) 259 3737 s  AOCr4ESS *o CENTE9 ::tOAu Serving The Best icc,thn in the Natum PERRY NUCLEAR POWER PLANT Al Kaplan VICE PRESOtNT wemn e.                                          November 28, 1988 PY-CEI/NRR-0935 L U.S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555 Perry Nuclear Pover Plant Docket No. 50-440 Technical Specification Change Request - Reload Submittal Centlement The Cleveland Electric Illuminating Company (CEI) hereby requests Amendment of Facility Operating License NPF-58 for the Perry Nuclear Power Plant, Unit 1.
In accordance with the requirements of 10 CFR 170.12 a check in the amount of
       $150.00 is enclosed. In accordance with requirements of 10 CFR 50.91(b)(1), a copy of this request for amendment has been sent to the State of Ohio as indicated below.
This amendment requests revision of Technical Specification Sections 2.1.2, 3.2.1, 3.2.2 and 3.2.3.      These specifications require changes to the Safety Limit Minimun Critical Power Ratio and associated Power Distribution Limits for                        f the fuel to be loaded into the core for the second cycle.         In addition, changes to the associated Bases are being made for consistency with the second cycle analysis. These are included for your information, although not a formal part of the Technical Specifications (as described in 10 CFR 50.36).
Attachment 1 provides the Summary, Description of Changes, Significant Hazards                          '
and Environmental Impact Considerations. Attachment 2 provides a summary listing of the proposed Technical Specification and Bases changes for the first reload. Attachment 3 is a copy of the marked up Technical Specification pages.
Attachment 4 is a copy of the marked up Bases pages.
Enclosure 1 provides the Supplemental Reload Licensing Submittal for the Perry Nuclear Power Plant Unit 1 (23A5948 Revision 1) Reload 1, Cycle 2 which provides a description of the core and summarizes the results of the transient analyses.
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8812050169 sultas                                                                      e PDR P
ADOCK or;ocopo                                                                ;fl / MJ:-0 l eDc                                                                pctt q/;ess

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PY-CEI/NRR-0935 L Page 2 of 2 l
Enclosure 2 provides Supplement 1 (23A5948AA) to the above Supplemental Reload Licensing Submittal which contains fuel bundle descriptions and the Maximum i  Average Planar Linear Heat Generation Rates for the new fuel to be loaded into the core for the upcoming cycle. This information is considered by General Electric (GE) Company to be proprietary information. Pursuant to 10 CFR 2.790 it is requested that the information contained in this enclosure be withheld from public disclosure.
Should you have any questions, please feel free to call.
Ver   ruly yours, 18  ,
Al Kaplan               /
Vice President Nuclear Group AK/sc Attachments / Enclosures              Enclosure 2 contains 10 CFR 2.790 material to be withheld f rom public disclosure. Upon separation of Enclosure 2, this letter and it's attachments are decontrolled.
I cc:   K. Connaughton T. Colburn
 ,       J. Harris (State of Ohio) l

a GENERAL ELECTRIC C0MPANY AFFIDAVIT I, P. W. Marriott, being duly sworn, depose and state as follows:
: 1. I am Manager, Licensing and Consulting Services, General Electric Company, and have been delegated the function of reviewing the information described in paragraph 2 which is sought to be withheld and have been authorized to apply for its withholding.
: 2. The information sought to be withheld is contained in "Supplement 1 to the Supplemental Reload Licensing Submittal for Perry Nuclear Power Plant Unit 1, Reload 1 Cycle   2," 23A5948AA, November 1988.
: 3. In designating material as proprietary, General Electric utilizes the def-inition of proprietary information and trade secrets set forth in the American Law Institute's Restatement of Torts, Section 757. This definition provides:
            "A trade secret may consist of any formula, pattern, device or compilation of information which is used in one's business and which gives him an opportunity to obtain an advantage over competitors who do not know or use it.... A substantial element of secrecy must exist, so that, except by the use of improper means, there would be difficulty in acquiring information.... Some factors to be considered in determining whether given information is one's trade secret are: (1) the extent to which the information is known outside of his business; (2) the extent to which it is known by employees and others involved in his business; (3) the extent of measures taken by him to guard the secrecy of the information; (4) the value of the information to him and to his competitors; (5) the amount of effort or money expanded by him in developing the information; (6) the ease or difficulty with the which the information eculd be properly acquired or duplicated by others."
4    Some examples of categories of inforration which fit into the definition of proprietary information are:
: a. Information that discloses a process, method or apparatus where prevention of its use by General Electric's competitors without license from General Electric constitutes a competitive economic advantage over other companies;
: b. Information consisting of supporting data and analyses, including test data, relative to a process, method or apparatus, the application of which provide a competitive economic advantage,    e.g., by optimization or improved marketability;

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: c. Information which if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality or licensing of a similar product;
: d. Information which reveals cost or price information, production capacities, budget levels or commercial strategies of General Electric, its customers or suppliers;
: e. Information which reveals aspects of past, present or future General Electric customer-funded development plans and programs of potential commercial value to General Electric:
: f. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection;
: g. Information which General Electric must treat as proprietary according to agreements with other parties.
: 5. Initial approval of proprietary treatment of a document is typically made by the Subsection manager of the originating component, the person who is most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within the Company is limited on a "need to know" basis and such documents are clearly identified as proprietary.
: 6. The procedure for approval of external release of such a document typically require; review by the Subsection Manager, Project Manager, Principal Sciencist or other equivalent authority, by the Subsection Manager ef the cognizant Marketing function (or delegate) and by the Legal Operation for technical content. competitive effect and determination of the accuracy of the proprietary designation in accordance with the standards enumerated above. Disclosures outside General Electric are generally limited to l        regulatory bodies, customers and potential customers and their agents, suppliers and licensees then only with appropriate protection by applicable regulatory provisions or proprietary agreements.
)     7. The document mentioned in paragraph 2 above has been evaluated in accordance l        with the above criteria and procedures and has been found to contain l        information which is proprietary and which is customarily held in confidence i
by General Electric.
: 8. Th information to the best of my knowledge and belief has consistently been held in confidence by the General Electric Company, no public disclosure has been made, and it is not available in public sources. All disclosures to I        th.rd parties have been made pursuant to regulatory provisions of proprietary agreements which provide for maintenance of the information in confidence.
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: 9. Public disclosure of the information sought to be withheld is likely to cause substantial harm to the competitive position of the General Electric Company and deprive or reduce the availability of profit making opporttinities becau.
it would provide other parties, including competitors, with valuable informatlon.
STATE OF CALIFORNIA COUNTY OF SANTA CLARA
                                ) ss:
                                )
P. W. Marriott, being duly sworn, deposes and says:
That he has read the foregoing affidavit and the matters stated therein are true and correct to the best of his knowledge, information, and belief.
Executed at San Jose, California, this 28. day of a/ov q vr4                 , 19,88 ,
f Lf P. W V.arriott General Electric Company Subscribed and sworn before me this3 d y of //nuaI1< 198Z.
(sw             k'I Y      /
NOTARY fUBLIC, STATE OF CALIF 0PJIIA
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ATTACHMENT 1

==SUMMARY==
, DESCRIPTION OF CHANGES, SIGNIFICANT HAZARDS AND ENVIRONMENTAL IMPACT CONSIDERATIONS 1
l L.

Attachssnt 1               !
PY-CEI/NRR-0935 L Page 1 of 6 i                                                                                               C SLRetARY This proposed amendment is requested to reflect the characteristics of the new fuel to be loaded into the core for Cycle 2 operation. This amendment updates the fuel cladding integrity Safety Limit Minimum Critical Power Ratio (MCPR) in Technical Specification Section 2.1.2 and the fuel and core thermal limits in Sections 3/4.2 - Power Distribution Limits. Operating flexibility options such as Maximum Extended Operating Domain (MEOD), Partial Feedvater Heating (PFH) and Increased Core Flov (ICF) are included within the safety analyses and are discussed belov. Results of e sulpment performance identified during the Startup Test Program vere factored into the analyses. Additionally, the Bases of the Technical Specifications are updated to be consistent with the reload analyses and generalized to reflect a more extensive reference to the General Electric reload licensing topical report: General Electric Standard Application for Reactor Fuel - GESTAR II: NEDE-24011-P-A and US (hereafter referred to as GESTAE).
The replacement reactor fuel is of the GE8X8EB extended burnup fuel design.
4 This fuel design as described in GESTAR has been revieved and approved by the
,        NRC for generic applications and extended burnup operations.
The Technical Specification changes specifically related to Cycle 2 reload fuel operating limits and analyses are as follows:
: 1. Increase the Safety Limit Minimum Critical Power Ratio (MCPR) from 1.06 to 1.07 to account for the additional uncertainties in a reload core. (2.1.2-Safety Limit Thermal Pover, High Pressure and High Flov)
: 2. Addition of lattice dependent Maximum Average Planar Linear Heat a                 Generation Rates (MAPLHGR) limits for the reload fuel. (3.2.1-Average Planar Linear Heat Generation Rate) i              3. Elimination of parametric curves (A-A' and B-B') from the MCPR Figure l                  (3.2.2-2). Curve C-C' from the analyses nov applies to all moEes of l                 operation vith either 100'F feedvater temperature reduction during the i                  cycle or 170'F temperature reduction beyond the end of cycle - in the all rods out condition. (3.2.2-Hinimum Critical Power Ratio)
!              4. Addition of a Linear Heat Generation Rate (LHGR) limit specific to the GE8X8EB fuel.     (3.2.3-Linear Heat Generation Rate) l         The results of the reload safety analyses also reflect advanced analysis methods and correlations, operating flexibility options applied to the second cycle, and startup test results.
!         The reload analyses vere performed by General Electric (GE) using their advanced computer modeling methods. These methods are known as GEHINI, and may be used in lieu of the older GENESIS methods. Additionally, an improved GE thermal correlation GEXL-Plus was applied to PNPP for the first time (GEXL vas used for the initial core). Both of the correlations have received NRC approval and are described in GESTAR.

At tachm:;nt 1 PY-CEI/NRR-0935 L Page 2 of 6 The impact of the new fuel type upon Emergency Core Cooling Systems (ECCS) analysis was evaluated with the SAFE /REFLOOD LOCA analysis methodology.
Application of this method is described in GESTAR and has received NRC reviev and approval. Results from analysis of the postulated plant design basis LOCA vith this new fuel type, der strates that PNPP conforms with the ECCS and Peak Cladding Temperature (tvr) acceptance criteria of 10 CFR 50.46 and Appendix K.
The reload analyses considered the effects of several modes of operation / initial conditions which were either continued from first cycle or vere adjusted to incorporate startup test results and other plant operational considerations. Performance of the analyses utilizing these initial conditions ensures that the resulting core operational limits specified in this submittal vill maintain normal operation of the plant within conservative boundaries.
Expanded operating domains and modes of operation vere considered for this cycle with the performance of transients at the bounding conditions within the Maximum Extended Operating Domain, analysis with feedvater heater (s) out-of-service, feedvater temperature reduction, safety / relief valves out-of-service, increased core flov, and Single Loop Operation (SLO).
(Technical Specification changes for SLO not applied for as yet).
The transient analyses vere performed with a feedvater runout capacity of 143%
nuclear boiler rated (NBR), versus the initial cycle value of 130% assumed in Chapter 15 of the USAR, since the reactor feedpumps de:aonstrated greater capacity during startup testing than originally assumed. During the first cycle the high speed stops on the reactor feedpump turbines vere set so that in combination, runout was restricted to 130% NBR. Turbine bypass valve capacity was assumed to be 25% NBR in the transient analyses to conservatively bound actual capacity. Transient and ECCS analyses vere performed considering the effects of revised reactor vater level (1,2,3 and 8) limits in order to support future adoption of the results of the Instrument Setpoint Methodology Group (ISMG) efforts. (These limits could therefore be instituted [following NRC approval of the ISMG methodology) vithout impacting the reload safety analyses since they were included as inputs and their effects have been evaluated herein).
Control cell Core (CCC) loading and operating strategy vill be employed for the second cycle. The BVR/6 Generic Rod Vithdraval Error analysis has been shown to be applicable to control cell core operation within the General Electric Standard Safety Analysis Report - GESSAR-II, Revision 21, and has received NRC approval.
Even though the main turbine vill be converted from full to partial arc admission for the second cycle, the analyses vere performed with full are admission since it is more conservative.
In summary, the above items merely changed some of the initial conditions applied to the reload transient analyses. Various fuel and core operating limits are established to bound normal and transient operations to ensure core conditions are maintained within the scope of the accident analyses. Analysis vith NRC approved methods (described within GESTAR) demonstrated, with the above assumptions, that adequate safety margins vere still maintained.
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Attachmant 1 PY-CEI/NRR-0935 L Page 3 of 6                        [
i                                        MSCRIPTIONOFCHANGES GESTAR presents generic information relative to the various GE fuel designs and analyses of the General Electric Boiling Vater Reactors (GE BVRs) for i                                        which GE provides fuel. The report consists of a description of the fuel design and fuel mechanical, nuclear and thermal hydraulic analyses bases. A United States Supplement to this report provides the plant specific                               f'
  <                                         information and safety analyses methodology used to determine reactor limits.
This report provides core and fuel related information that is independent of 2
a plant specific application. In Table S-1-1 (Applicable Reactors) of the US Supplement, Perry 1 vas specifically identified as applicable for the                             ,
information provided in this report. The generic information contained in this document is supplemented by plant and cycle-unique information and analytical results. This cycle-unique information (presented in the Supplemental Reload Licensing Submittal: Enclosure 1) includes a listing of                      ;
the fuel to be loaded in the core and safety analysis results. Together the Supplemental Reload Licensing Submittal and GESTAR completely describe the                       !
reactor fuel, core design and safety analyses.                                                   i A.       Safety Limit MCPR for Reload Cores                                                       !
Operating limits are specified to maintain adequate margin to the onset of the transition boiling (from nucleate to film boiling). The critical power ratio (CPR) is defined as the ratio of the critical power (bundle power at which some point within the fuel assembly experiences onset of                  {
transition boiling) to the operating bundle pover. The critical power is                 !
determined at the same mass flux, inlet temperature, and pressure which                  !
exists at the specified reactor condition. Thermal margin is expressed in                i terms of the minimum critical pover ratio (HCPR), whieS corresponds to the smallest CPR. The safety and normal MCPR operating limits are derived                    t from this basis.
The plant-unique MCPR operating limit is established to ensure that the                  i Fuel Cladding Integrity Safety Limit for the plant is not exceeded for any               -
moderate frequency transient. This operating requirement is obtained by                  [
j addition of the maximum delta CPR value for the most limiting transient 4                                                    (including any imposed adjustment factors) from the most limiting conditions postulated to occur at the plant to the fuel cladding integrity               I
!                                                    safety limit. The results of the analyses shov that at least 99.9% of the fuel rods in the core are expected to avoid boiling transition if the MCPR               l l                                                    is maintained equal to or greater than this value. The Safety Limit MCPR has been increased from 1.06 to 1.07 to account for the increased uncertainties that normally occur in the second and subsequent cycles.
l B. HAPLHGRs for the GE8X8EB Fuel f
The average planar linear heat generation rate (APLHGR) is applicable to s               '
;                                                    specific planar height and is equal to the sum of the LHGRs for all of the fuel rods in the specified bundle at the specified height divided by the                i
!                                                    number of fuel rods in the fuel bundle. The MAPLHGR is the most limiting                 i l                                                    value for APLHGR for a given bundle type such that thermal limits are not
!                                                    exceeded. 10 CFR 50.46 establishes acceptance criteria for the fuel and l

Attachmtnt 1 PY-CEI/NRR-0935 L Page 4 of o Emergency Core Cooling Systems (ECCS). HAPLHGR limits are 6:stablisin ensure that the acceptance criteria are met.
For this cycle the natural uranium bundles are being totally removed and two new GE8X8EB fuel types are introduced. The applicable fuel thermal limit, MAPLHGR, is presented as a function of lattice type as there are several different fuel lattices per bundle. The APLHGRs for each type of fuel are monitored agahat the corresponding fuel lattice MAPLHGR (developed from the NRC cpproved fuel lattices described in GESTAR) over the exposure history of the fuel. The fuel lattice MAPLHGRs are proprietary. In order not to breach the proprietary nature of the fuel designs, GE and the NRC have agreed that only the limiting enriched fuel lattice MAPLHGR curve is necessary vithin Technical Specifications for fuel with multiple lattices (see GESTAR). During normal operation, when hand calculations are required, the fuel is monitored against its limiting lattice MAPLHGR specified in the Technical Specifications.
Supplement 1 to the Supplemental Reload Licensing Submittal (Enclosure 2) vill be avai?able to the control roor. operator to supply information on the axial location of each lattice and the composite MAPLHGR, as a function of exposure for each reload bundle, in accordance with the NRC's SER for Amendment 19 of GESTAR.
This amendment adds two limiting lattice MAPLHGR curves for the tvo new GE8X8EB fuel types and deletes the MAPLHGR curve for the natural uranium bundles.
C. Revision of Minimum Critical Power Ratio MCPRp Curve The current set of MCPR parametric curves specify the power 4 pendent MCPR limit at reduced fEedvater temperatures for various core average exposures and core flows. From the results of the reload analyses it was found for the second cycle that curves A-A' and B-B' could be eliminated.
Thermal margin vill be maintained in all cases assuming curve C-C' as the limit. Curve C-C' applies for operation during the cycle at all core flovs and core average exposures for a reduction in feedvater temperature of up to 100'F. For operation beyond the end of cycle (core average exposure beyond end of cycle - all rods out condition) curve C-C' also applies at all core flovs for a reduction in feedvater temperature of up to 170'F. Therefore, curves A-A' and B-B' are being deleted from the Technical Specifications and the C-C' designation is being removed.
D. LHGhs for the GE8X8EB Fuel The linear heat generation rate (LHGR) is the heat generation per unit length of fuel rod. It is the integral of the heat flux over the heat transfer area associated with the unit length. The nev GE8X8EB fuel bundles have a higher LHGR limit than the initial core. Therefore, the linear heat generation rate specification must be revised to allov for this fuel type. The design and analysis of this fuel is described within GESTAR and its application has been approved on a generic basis by the NRC.

Attachmsnt 1 PY-CEI/NRR-0935 L Page 5 of 6 SIGNIFICANT HAZARDS EVALUATION                                                                      .
The standards used to arrive at a determination that a request for amendment requires no significant hazards consideration are included in the Commission's Regulations, 10 CFR 50.92 (c), which states that the operation of the facility in accordance v!?h the proposed amendment vould not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. CEI has reviewed the proposed changas with respect to these three factors.
: 1. The proposed changes do not involve a significant increase in the consequences of an accident previously evaluated because MCPR, LHGR, and HAPLHGR core operating limits are provided to establish bounds on normal reactor operr.tions which ensure core conditions are maintained within the assumptions and scope of accident analyses. New HAPLHGR curves and LHGR and MCPR limits are provided to reflect changes in the reactor fuel ecnfiguration                          ,
and design assumptions. Operation within these limits vill assure the consequences of affected transicnts and accidents vill remain within the results and bounds of the safety analyses. HAPLHGR and MCPR curves / limits vere generated using analytical methods previously approved by the NRC.
The Safety Limit MCPR is determined using a statistical model that combines                            l uncertainties in operating parameters with uncertainties used to calculate the critical power. For reload cores, some of the uncertainties used in the determination of the Safety Limit MCPR are larger than for initial cores. The higher Safety Limit MCPR for reload cores accounts for these increased uncertainties. The Safety Limit MCPR for reload cores has received previous NRC approval and is documented within the USAR and in GESTAR.
The critical power ratios in the transient analyses were calculated using the improved critical pover correlation, GEXL-Plus. This correlation has been                             ;
approved by the NRC (docketed in GESTAR). Its predecessor GEXL vas used for                       l the initial core.                                                                                     [
t The LHGR litait for GE8X8EB fuel vas calculated using the GESTR-MECHANICAL code (a fuel rod thermal-mechanical performance model accepted by the NRC in                              1 GESTAR). Results from GESTR-MECHANICAL demonstrate that compliance with the new LHGR limit (in concert vith appropriate MAPLHCR curves) vill further l
i ensure fuel design basis criteria are satisfied for GEByBEB fuel.
l            Extended operating domains and modes of operation have been analyzed by GE l            (using NRC approved methods) to determine applicable operating restrictions.
GE demonstrated that the consequences of changes to the allovable operating region are bounded by the proposed values for HCFR and MAPLHGR.             Furthermore,             ,
the probability of an accident is not increased because operation in the
 !           expanded region does not significantly alter the normal operation of the                             I equipment, for which failures have been previously analyzed.
r
,                                                                                                                 i 1

Attachmant 1 PY-CEI/NRR-0935 L      '
Page 6 of 6 L
: 2. The proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated because proposed MCPR,     :
i         MAPLHGR, and LHGR limits do not directly affect the operation or function of       f any system or component but instead set fuel or core thermal limits so that        ,
operation within these limits vill maintain the analyzed margins of safety.
The Safety Limit MCPR vas adjusted in the conservative direction because of calculational uncertainties associated with reload cores to maintain the           >
margin of safety. HAPLHGR limits are provided for each bundle type to ensure   ,
that the requirements of 10 CFR 50.46 and Appendix K are maintained. The           j limits are results of the reload transient and ECCS analyses and are designed       '
to maintain the same margins of safety. Therefore, this change does not create the possibility of an accident different than previously evaluated.
 ;         Expanded operating regions represent changes to the core power and flov            l j          distribution, but do not significantly affeet the operation or function of any system or component. Operating limits vere established by analyses to bound
!          all combinations of specified expanded operating domains and equipment out of      ;
service within acceptable analyzed conditions to ensure fuel integrity and ECCS criteria. Consequently, there is no significant impact on or addition to      !
any system or equipment whose failure could initit.te an accident.                 ;
i
: 3. The proposed changes do not involve a significant reduction in the margin     !
of safety because all of the proposed changes have been analyzed to the same       !
i          governing criteria as before and demonstrate that the consequences of              l
.          transients or accidents are not increased beyond those already evaluated by        [
t the NRC for PNPP.                                                                  ,
The Safety Limit MCPR is set at the point at which no fuel damage is expected      i to occur as discussed in GESTAR. The Safety Limit HCPR is combined with the        l most limiting transient change to the critical power ratio to establish the operating limit MCPR. The Safety Limit MCPR and the change resulting from the most limiting transient have been calculated by methods described in GESTAR.
These methods have received previous NRC approval.                                 l HAPLHGRs are determined by analysis to ensure the acceptance criteria of            i 10 CFR 50.46 are met and establish the margins of safety for fuel and the          !
ECCS. Calculations using NRC approved models described in GESTAR yield              l results within these acceptance criteria.                                           '
Furthermore, the fuel used in Cycle 2 is very similar to that used in the previous cycle and the core vill be operated using NRC approved methods.            j ENVIRONMFETAL IMPACT Cleveland Electric Illuminating has revieved the proposed technical Specification change against the criteria of 10 CFR 51.22 for environmental considerations. As shovn abova, the proposed change does not involved a significant hazards considera don, nor increase the types and amounts of effluents that may be released offsite, nor significantly increase individual      ,
or cumulative occupational radiation exposures. Based on the foregoing, CEI concludes that the proposed Technical Specification change meets the criteria      !
given in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statement.}}