ELV-03832, Application for Amends to Licenses NPF-68 & NPF-81,revising TS SR 4.5.2.b by Changing Frequency for Verifying That ECCS Piping Is Full of Water from Once Per 31 Days to Once Per 6 Months

Application for Amends to Licenses NPF-68 & NPF-81,revising TS SR 4.5.2.b by Changing Frequency for Verifying That ECCS Piping Is Full of Water from Once Per 31 Days to Once Per 6 Months

ML20105C796
Person / Time
Site:	Vogtle
Issue date:	09/17/1992
From:	Mccoy C GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20105C799	List: ELV-03832, Application for Amends to Licenses NPF-68 & NPF-81,revising TS SR 4.5.2.b by Changing Frequency for Verifying That ECCS Piping Is Full of Water from Once Per 31 Days to Once Per 6 Months ML20105C803
References
ELV-03832, ELV-3832, NUDOCS 9209220451
Download: ML20105C796 (7)

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• rn September 17, 1992 Docket Nos. 50-424 ELV-03832 50-425 U. S. Nuclear Regulatory Commission ATTH: Document Control Desk Washington, D. C. 20555 Gentlemen VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNICAL SPECIFICATIONS EHEQQ1'NCY OF ECCS VENT 11Lrt In accordance with the provisions of 10 CFR 50.90 and 10 CFR 50.59, Georgia Power Company (GPC) horeby proposes to amend the Vogtle Electric Generating Plant (VEGP) Unit I and Unit

? Technical Specifications, Appendix A to Operating Licenses PPF-68 and NPP-81.

This amendment revises surveillanco requirement 4.5.2.b by changing the frequency for verifying that the emergency core cooling system (ECCS) piping is full of water from onco por 31 days to once per 6 months. This request is consistent with the results of the monthly surveillances that have boon rerformed since the Technical Specification went into effect and which have not indicated any accumulation of air in the ECCS piping.

Georgia Power Company requests that this revision to the Technical Specifications be approved by February 26, 1993.

Tho proposed changes and bases for the changes aro described in onclosure 1 to this letter. Enclosuro 2 provides an ovaluation pursuant to 10 CFR 50.92 showing that the proposed changes do not involve significant hazards considerations. Instructions for incorporation of the proposed changes into the Technical Specifications and a markup of the affected pages are provided in onclosure 3.

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Geolgialinver Are k U. S. Nuclear Regulatory Commission EIN-03 8 3 2 Page 2 In accordance with 10 CFR 50.91, the designated state official will be cent a copy of this letter and all enclosures.

Mr. C. K. McCoy states that he is a vice president of Georgia 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.

GEORGIA POWER COMPANY By: / 1 C. K. McCoy/

Sworn to and subscribed before me this /7' f y of .

irlfa vfl 1992.

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Enclosures:

1. Basis for Proposed Change

2. 10 CFR 50.92 Evaluation

3. Instruction for Incorporation and Revised Pages c(w): Georetia Power CompM1y Mr. W. B. Shipman Mr. M. Shoibani NORMS

1) . S. Nuclear Regnlatory Cgmmission Mr. S. D. Ebneter, Regional Administrator Mr. D. S. Hood, Licensing Project Manager, NRR Mr. B. R. Bonser, Senior Resident Inspector, Vogtle

$ tate Qf Georgia Mr. J. D. Tanner, Commissioner, Dept. of Natural Resources a wn

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ENCLOSURE 1 VOGTLE ELECTRIC GENERATING PLANT -

REQUEST TO REVISE TECHNICAL SPECIFICATIONS FREQUENCY OF ECCS VENTING BASIS FOR PROPOSlQ_CllMiqE Pronosed Change The proposed change will roviso the frequency of venting the '

emergency core cooling system (ECCS) piping from once por 31 days '

to once por 6 months by changing Specification 4.5.2.b to road as follows:

"b. verifying the following:

1). At least onco por six months that the ECCS piping is full of water by venting the ECCS pump casings and accessible dischargo piping high points, and 2). At least once por 31 days that each valvo (manual, power-operated, or automatic) in the flow path that is not locked, scaled, or otherwiso secured in position, is in its correct position."

The requirement for verification that valvos are in their correct position is unaffected.

HAB1H The monthly venting of the ECCS piping required by Specification 4.5.2.b has boon performed in excess of 100 times betwoon the two VEGP units. Hinotoon Unit 1 points and seventoon Unit 2 points are vented por this surveillance. A review of records from previous surveillances indicates that the ECCS piping has always-boon verified to be full of water. As a means of confirming those historical results, a survey of the personnel who have performed the survoitlance was conducted. No porsonnel could-recall observing any accumulation of air in performing this

- surveillance. Procedural requirements exist to ensure the ECCS piping is filled and vented following maintenance on the associated systems. Additionally, the VEGP design is such that there are no high points in the ECCS piping that are above the water level of the aligned water source. This ensures that the ECCS piping will remain full after it is filled and vented.

Therefore, based on the design of the piping and the hietorical results of the surveillance, GPC has concluded that the monthly venting of the ECCS piping is excessive.

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ENCLOSURE 1 (CONTINUED) i VOCTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNICAL SPECIFICATIONS .

FREQUENCY OF ECCS VENTING BASIS FOR PROPOSED CHANGE In addition, the performance of the monthly venting of the ECCS piping is a labor intensive undertaking and results in unnecessary personnel exposure to radiation. (Approximately 0.5 rom of exposure was attributed to this surveillance during 1991.)-

Currently, 13 of the combined 36 vent points are located in areas designated as high radiation areas (2 100 mrom por hour). The other vont points are located in areas designated as radiation areas (2 2.5 mrem per hour). Several of tne same areas are also currently designated as contaminated areas. Due to radiological concerns associated with the venting of the involved systems, escort by a Health Physics technician is required for the venting of all points. The actual venting is performed by Operations Department personnol. However, Maintenance support is required '.

for the removal and reinstallation of blind-flanges for five Unit 1 points and four Unit 2 points. Additionally, the reinstallation of one of the blind flanges requires the verification of a Quality control inspector. Thernfore, the performance of the surveillance requires extensive personnel effort within radiological control areas and is contrary to ALARA principles.

For the above reasons, Georgia Power Company is requesting that the frequency of this verification be extended to once per.6 months.

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, ENCLOSURE 2 VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNICAL SPECIFICATIONS FREQUENCY OF ECCS VENTING 10 CFR 50 192 EVALUATIOl{  ;

Pursuant to 10 CPR 50.92, Georgia power Company has ovaluated the proposed revision to the Technical Specifications and hat determined that-operation of the facility in accordance with the proposed amendment would not involve any significant hazards  !

considorations.

BackaroMDd Technical Specification 4.5.2.b requires verification that the omorgency core cooling system piping is full of water once por 31 days by venting accessible pump casings and dischargo piping high points. This surveillance has boon conducted routinely sinco the Technical Specification became offectivo in 1987..

Georgia Power Company experience in conducting this survoillanco has found insignificant or no quantities of air in the ECCS system. The donign of the syrtom is such that thoro.aro no high points that are above the water level of the water source to which the system is aligned. Thorofore, the system will remain full by following the venting procedures that are conducted prior to returning the ECCS system to service after an outage. Under such circumstancos, a monthly verification of full piping is unnecessary, and a longer surveillanco frequency is justified.

Analysis Prior to returning an inoperablo ECCS system to servico following maintenanco or repairs that could have allowed air to enter the system, plant proceduros-require that the system be filled and vented. This process involves opening various vont valvos on system high points until water is observed.  ;

The results of the monthly surveillancou conducto'd in accordanco with Specification 4.5.2.b have boon reviewed, This included a survey of the plant personnel who performed tho verifications.

This survey datormined that all of the routino survoillances have indicated no or insignificant amounts of air in the ECCS piping.

The cafety injection (SI) pumps and residual-heat removal (RHR).

pumps are normally aligned to the refueling water storage tank (RWST). The bottom of the RWST is at an olevation of about 220 '

ft. This is well above the highest of the ECCS high point vents

- for the RHR and SI systems, which are at an olevation_of about 216 ft. The centrifugal charging pumps are r.ormally aligned to the volume control tank, the bottom of which-is at an olevation E2-1

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4 ENCLOSURE 2 (CONTINUED)

VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECl!NICAL SPECIFICATIONS PREQUENCY OF ECCC VENTING 10 CFR 50.92 EVALUATION of about 196 ft. The high point vents used for the contrifugal-charging pumps are ut an olovation of approximately 153 ft.

Thorofore, the configuration of the system is such that piping will remain filled.

Plant procedures require that those systems be filled and vented prior to returning them to operablo status following any activity which could have allowed air to entor the system. Following this initial filling proceduro, the positivo head of the volumo control tank and the RWST will assure that the lines remain  ;

filled. Thorofore, subcoquent opening of the vents will continue to confi:n the prostnce of water. Experience from previoun curvoillances confirms that no algnificant accumulation of noncombustibio ganos has occurred.

CODElMai2D Based on the abovo considorations, GPC has csncluded the following concerning 10 CFR 50.92.

3. Tho proponed revision to the Technical Specifications doon not involvo a algnificant increano in the probability or consequences of an accident previously evaluated because tho <

designs of the systoma assure that the ECCS piping romains full. Thorofore, extending tho-survwillanco frequency will not significantly affoot the probability that the ECCS syctem will perform an designed.

2. The proposed revision to the Technical Specifications does not create the possibility of a now or different kind of accident from any accident previously evaluated because it does not involvo any physical modification to the plant or any changos in the ECCS system's ability to perform as designed. The frequency of verifying that the ECCS piping la filled in unrelated to the types of accidents or events-that could be expected to occur.

3. The proposed revision to the Technical Specifications does not involve a significant reduction in a margin of safety becauno the design of the syntom is such that the linos are maintained-full by the clovation of the RWST or volume control tank (VCT), and the resulta of previous surveillances have indicated that air will not accumulato in those linos betwoon curveillances.

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ENCLOSURE 2 (CONTINUED)

VOGTLE ELECTRIC GENERATING PLANT REQUEST TO-REVISE TECHNICAL SPECIFICATIONS FREQUENCY OF ECCS VENTING 10 CFR 53.92 EVALUATION

'esed upon the preceding information, it has been determined that che proposed Technical specifications revision does not involve a significant hazardo consideration as defined by 10 CFR 50.92(c).

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