ELV-00302, Application for Amends to Licenses NPF-68 & NPF-81,deleting Temporary Footnotes Which No Longer Applicable After Initial Entry of Unit 2 Into Mode 2

Application for Amends to Licenses NPF-68 & NPF-81,deleting Temporary Footnotes Which No Longer Applicable After Initial Entry of Unit 2 Into Mode 2

ML20248J082
Person / Time
Site:	Vogtle
Issue date:	04/05/1989
From:	Hairston W GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20248J085	List: ELV-00302, Application for Amends to Licenses NPF-68 & NPF-81,deleting Temporary Footnotes Which No Longer Applicable After Initial Entry of Unit 2 Into Mode 2 ML20248J099
References
ELV-00302, ELV-302, NUDOCS 8904140310
Download: ML20248J082 (5)

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Sarme V:ce Pres &rl 1 'l Nclear Ogudons 'l ELV-00302 April 5.1989 ' 0152e U. S. Nuclear Regulatory Commission ATTN: Document. Control Desk Washington, D. C. 20555 PLANT V0GTLE UNITS 1, 2 -'

NRC DOCKETS 50-424, 50-425~

0PERATING LICENSES NPF-68, NPF-81 REQUEST TO REVISE TECHNICAL SPECIFICATIONS

, DELETION OF TEMPORARY FOOTNOTES Gentlemen:

r In accordance with 10 CFR 50.90-and 10 CFri.50.59, Georgia Power Company hereby proposes to amend _~' the Vogtle Electric Generating Piant Unit 1 and Unit 2 m  : Technical Specifications, Appendix A tc_ Operating Licenses NPF-68 and NPF-81.

The proposed amendment, deletes footnotes which are no longer applicable after the -initial entry of ' Unit 3 . 2 into Mode 2. Enclosure 1 provides a detailed description: of the proposed changes and the basis' for the changes. Enclosure 2 provides our 10 CFR 50.92 evaluation showing that the proposed changes do not l invol ve - significant hazards considerations. Enclosure ~ 3 provides instructions for incorporation .of the. proposed amendment into the Technical Specifications and includes the proposed revised pages.

ALcopy of f this letter and -- all. applicable enclosures will be 'sent to the designated state ' official in accordance with 10 CFR 50.91.

' Mr.. W. G. Hairston, III. states that he is a Senior Vice President ofiGeorgia I

.p ".. 3 Power Company and is authorized to execute this oath on behalf of Georgia

. Power Company, and that', to the best of his knowledge and belief, the facts set forth in this letter and enclosures are true, i

vE8; j f.( -Q t wo 1 .

GEORGIA POWER COMPANY

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4 By: It I.

• a ~.uA j@ ' W. G. Hai rston,III

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.$4 Sworn to and subscribed before me this [I,_ day of April,1989.

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. r. Not,4ry Public l

/ JH(MMSBO!EXHRES DEC.15,1992 -

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i-e GeorgiaPdwer d U S. Nuclear Regulat'ory Commission ELV-00302 Page two.

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Enclosures:

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1. Basis for Proposed Change i

2. -10 CFR 50.92 Evaluation

3. Instructions and Revised P.ssn.

c(w): Georgia Pot er Compar" Mr. P. D. Rice

'Mr. C. K. McCoy Mr. J. P. Kane  :

Mr. G. Bockhold, Jr. 1 NORMS j U. S. Nuclear Regulatory Commission Mr. S. Ebneter, RegTnal Administrator  !

Mr.-J. B. Hopkins, Lf censing Project Manager, NRR (2 copies)

Mr. J. F. Rogge, Senior Resident Insper. tor, Vogtle State of Georgia Mr. J. L. Ledbetter, Commissioner, Department of Natural Resources t

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ENCLOSURE 1 PLANT V0GTLE - UNITS 1, 2 NRC DOCKETS 50-424, 50-425 OPERATING LICENSES NPF-68, NPF-81 REQUEST TO REVISE TECHNICAL SPECIFICATIONS BASIS FOR PROPOSED CHANGE PROPOSED CHANGE Delete Footnote "*" from Tables 3.3-4 and 4.3-3 and from Specifications 3.3.3.6, 3.4.4, 3.7.1.2, 3.7.7. and 3.9.1.

BASIS The subject footnotes are included in the Unit 1 and Unit 2 Technical Specifications which were issued with the Unit 2 low power operating license.

These footnotes delay the applicability of certain requirements to Unit 2 during initial fuel load and during initial operation in Modes 3 and 4. After the initial. entry of Unit 2 into Mode 2, these footnotes will no longer be applicable. In order to avoid confusion which could be caused by the presence of these footnotes during future startups, GPC proposes to delete the "C. footnotes from the Technical Specifications.

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i ENCLOSURE 2 PLANT V0GTLE - UNITS 1, 2 NRC DOCKETS 50-424, 50-425 GPERATING LICENSES NPF-68, NPF-81 REQUEST TO REVISE TECHNICAL SPECIFICATIONS 10 CFR 50.92~ EVALUATION Pursuant to 10 CFR 50.92, Georgia Power Company has evaluated the attached

)roposed amendment to the Vogtle Units 1 and 2 Technical Specifications and las determined that operation of the facility in accordance with the proposed amendment would iiot involve significant hazards considerations. The basis for this determination is as follows:

BACKGROUND Georgia Power Company letter GN-1423 dated January, 17, 1988, contained requests to add footnotes to certain Technical Specifications (Radiation and Accident Monitoring for RE-0005 and RE-0006, PORV's, Auxiliary Feedwater System, and Piping Penetration HVAC) which would delay applicability for Unit 2 until its initial entry into Mode 2. In addition, the letter requested that during initial fuel load, the boron concentration limitation for the Unit 2 refueling canal not be applicable provided that the canal water level was verified to be below the Reactor Vessel Flange elevation. ,

The requests for the radiation monitors, the PORV's and piping penetration HVAC were made on the basis that the absence of fission products (and hence the lack of potential radiological consequences of an accident) made the requirements of the particular specifications unnecessary prior to initial criticality. The request for the Auxiliary Feedwater System was made on the basis that prior to initial entry into Mode 2 there is no decay heat.

The delays in applicability allow testing and adjustments to systems without undue hardships.

The request for the refueling canal boron concentration was made on the basis that reactivity control is not a concern for movement of new fuel through the transfer tube.

Unit 2 has completed initial fuel loading and initial entry into Mode 2. In order to prevent confusion with respect to initial entries into Mode 2 after refueling and to remove footnotes that are no longer applicable, Georgia Power Company is proposing to remove the footnotes regardino initial applicability from Table 3.3-4, Table 4.3-3, Specifications 3. 3. 3. 6, 3.4.4, 3. 7.1. 2, 3. 7. 7 and 3.9.1 l

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> ENCLOSURE 2 (CONT'D) .

P.EQUEST T0 REVISE TECHNICAL SPECIFICATIONS 10 CFR 50.92 EVALUATION ANALYSIS

GPC has reviewed the proposed amendment with respect to the requirements of 10 CFR 50.92 and has _ determined that the change does not involve significant haza'rds considerations. In support of this conclusion the following analysis is provided:

1. The proposed change does not involve a . significant increase.' in . the probability or consequences of an accident previously evaluated. The removal of footnotes from the Technical Specifications does not affect any equipment involved in 'the initiation of previously evaluated accidents. The probability of such accidents is therefore not -increased. The operation of the PORV's, Auxiliary Feedwater System, Piping Penetration HVAC System, and Radiation Monitors 3 RE-0005 and RE-0006 are not affected by removal _of the applicability H footnotes. Therefore, the consequences of an accident which' would rely on this equipment are not increased.

2. The proposed change does - not create the possibility of a new or different kind of accident from any accident previously. evaluated.

The change does not introduce any new equipment into the plant or require existing equipment to operate in a different manner from which it was designed to operate. Since a new failure mode -is not introduced by the change, a new or different kind of accident could not result.

3. The proposed change does not involve a significant reduction in a margin of safety. The change does not affect safety limits or limiting safety system settings.- The bases for the affected Technical Specifications are not affected by removing the ini t.ial applicability footnotes; therefore, margins of safety are not reduced.

1 CONCLUSION B'ased on the preceding analysis, GPC has determined that the proposed changes to the Technical Specifications do not involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident

- previously evaluated, or involve a significant reduction in a margin of safety. Georgia Power Company therefcre concludes that the proposed changes meet the requirements of 10 CFR 50.92(c) and do not involve significant hazards considerations.

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