Text

Application for Amends to Licenses DPR-57 & NPF-5 Revising Tech Specs Re Generic Ltr 88-01, NRC Position on IGSCC Austenitic Stainless Steel Piping
	ML20071A747
Person / Time
Site:	Hatch
Issue date:	04/12/1991
From:	Beckham J; GEORGIA POWER CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20071A749	List: HL-1446, Application for Amends to Licenses DPR-57 & NPF-5 Revising Tech Specs Re Generic Ltr 88-01, NRC Position on IGSCC Austenitic Stainless Steel Piping; ML20071A751;
References
	GL-88-01, GL-88-1, HL-1446, NUDOCS 9104170071
	Download: ML20071A747 (9)
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HL-1446 001312 April 12, 1991 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 PLANT HATCH - UNITS 1, 2 NRC 00CKETS 50-321, 50-366 OPERATING LICENSES OPR-57, NPF-5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

GENERI.C_ LETTER 88-01 Gentlemen:

In accordance with the provisions of 10 CFR 50.90, as required by 10 CFR 50,59(c)(1), Georgia Power Company (GPC) hereby proposes changes to the Plant Hatch Units 1 and 2 Technical Specifications (TS), Appendix A to operating Licenses OPR-57 and NPF-5, respectively.

The proposed amendment incorporates changes to the Plant Hatch Units 1 and 2 TS recommended in the NRC's February 16, 1990 Safety Evaluation Report addressing GPC's response to Generic Letter 88-01, "NRC Position on IGSCC Austenitic Stainless Steel Piping " Specifically, the amendment 1) modifies the TS regarding Plant Hatch's ISI program to include a statement of compliance with the NRC Staff position on inspections and 2) revises the reactor coolant system (RCS) leakage monitorin'1 requirements.

Enclosure 1 provides detailed descriptions of the proposed TS changes and circumstances necessitating the change request. Enclosure 2 details the bases for our determination the TS proposed changes do not involve significant hazards considerations. Enclosure 3 provides page change instructions for incorporating the Vait 1 and Unit 2 proposed changes. The proposed changed TS pages for Unit I and Unit 2 follow Enclosure 3. Also included in Enclosure 3 are markups of the proposed Unit I and Unit 2 TS pages.

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

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GeorgiaPower d U.S. Nuclear Regulatory Commission April 12, 1991 Page Two in accordance with the requirements of 10 CFR 50.91, a copy of- this letter and all applicable enclosures will be sent to Mr. J..D. Tanner of.

the Environmental Protection Division of. the Georgia Department of Natural ;

Resources.

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 _ -

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

GEORGIA POWER COMPANY-BY: ~/

J. T. Beckham, Jr.'

Sworn to and subscribed before me this lllAday of IhAll '1991.

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Enclosures:

1. '_ Bases for Change Request

2. 10 CFR 50.92 Evaluation

3. Page Change Instructions-c: Georaia Power Company Mr. H. L. Sumner, General Manager - Nuclear Plant Mr. J. D. Heidt, Manager Engineering and~ Licensing - Hatch:

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l U.S.' Nuclear Reaulatory Commission. Washinoton. D.C.

l Mr. K. Jabbour, Licensing Project Manager - Hatch U.S. Nuclear Reaulatory Commission. Reaton II l Mr. S. D. Ebneter, Regional-Administrator l

Mr. L. D..Wert, Senior Resident Inspector - Hatch State of Georaia Mr. J._ D. Tanner, Commissioner - Department 'of Natural' Resources rwm

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ENCLOSURE 1 PLANT HATCH - UNITS 1, 2 NRC 00CKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

GENERIC LETTER 88 BASIS FOR CHANGE REQUEST PROPOSED CHANGE ONE:

This proposed change revises the Unit 2 reactor coolant system (RCS) leakage monitoring Technical Specifications (TS) requirements to reflect-the latest NRC -positions. Unit-2 TS 3/4.4.3 -has -been modified to incorporate the requirements of an NRC Confirmatory Order dated July 8, 1983 and an NRC Safety Evaluation Report (SER). dated February-16, 1990.

Specifically, limiting conditions for operation (LCOs)-and. surveillance requirements (SRs) associated with Unit 2 TS 3.4.3.1 (Leakage Detection Systems) and 3.4.3.2 (Operational Leakage) have 'been modified to reflect the Confirmatory Order, except where superseded by-the February 16,- 1990 SER.

Basis for Proposed Chanae One:

The Confirmatory Order modified the ACTION statement associated with Unit-~2 TS 3.4.3.1 on leakage detection system operability. The= Order required grab samples De taken every 4 hears (instead of every 24Lhours) when either the primary containment atmospheric particulate radioactivity monitoring systeni or the primary containment gaseous radioactivity monitoring system is inoperable for up to 30 days. Subsequent to'the order, the February-16, 1990 SER modified the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months sample -time as follows:

. . . the staff has concluded that taking '[ reactor coolant system]_

RCS leakage measurements overy 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months _ creates an unnecessary -

administrative hardship. 1Thus, RCS leakage measurementsLmay be taken every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ..."

Accordino!f, this change will require the samples be taken every 8_ hours.

Similarly, channel or sensor, checks on the leakage detection systems-(SRs 4.4.3.1.a and 4.4.3.1.b) will be performed lat least once'per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

Similar_ changes-are proposed for the SRs _ associated with RCS operational -

_ leakage (SRs 4.4.3.2.a and 4.4.3.2.b). The revised TS require monitoring floor and equipment sump levels = and flow rates at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , i- and monitoring the primary containment atmospheric particulate and' gaseous i radioactivity at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This .8-hour surveillance t

frequency is also justified by the February 16, 1990 NRC SER.

HL-1446 001312 El-1

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ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

GENERIC LETTER 88-01 BASIS FOR CHANGE REQUEST Existing Unit 2 TS 3.4.3.2.b and 3.4.3.2.d specify a limit of 5 gpm unidentified RCS leakage and a 2 gpm increase in unidentified leakage,_

respectively. The February 16, 1990 NRC SER stated the 2 gpm increase in unidentified leakage should not be averaged over- a 24-hour period.

Therefore, conformance to the 2 gpm increase in RCSL unidentified leakage will be achieved by comparing the latest reading _'of unidentified leakage to '

the three previous readings and assuring the increase has been less than 2 gpm. The proposed TS -(3.4.3.2.d) will be -modified.to state "within a ,

24-hour period or less."

PROPOSED CHANGE TWO:

Unit 1 TS 3.6.G.1 (Reactor Coolant Leakage) and 3.6.G.2L(Leaep 'v - ection -

Systems) will be modified to reflect the NRC's recommendations stated in the February 16, 1990 SER. Note that Amendment 93 changed the Unit 1 TS'to incorporate NRC requirements relative to RCS- leakage limits and-detection systems; therefore, Unit I has no outstanding Confirmatory Order.

Basis for Proposed Chanoe Twg:

Unit 1-IS 3.6.G,1, which specifies permissible leakage'llimits. has-been .

-l changed to reflect the NRC's position-in the February 16, 1990 SER and wil_1 be consistent with the corresponding' Unit 2 TS-discussed under Proposed' Change One. Specifically, Unit 1- TS 3.6.G.I.a-(the S gpm_ unidentified RCS leakage limit) no longer specifies averaging over Ja;24-hour period.: This TS will now- be consistent with existing Unit 2 TS - 3.4.3.2.b. : Proposed Unit-1 TS 3.6.G.l.b-(the 2 gpm increase' limit) specifies: the limit will not be exceeded "within a 24-hour period or less." As discussedLabove, this requires . comparing -the latest leakage reading _with the three previous readings to assure any_ increase in unidentified leakage is less:than 2-gpm.

A minor wording change to existing Unit 1 TS 3.6.G.I.c was made, specifying_

total _ RCS leakage (identified and unidentified) shall not exceedl25 gpm 3 raged over "any 24-hour period" instead= of "a 24-hour period,"-

.rge achieves consistency with existing Unitc2 TS 3.4.3.2.c.

Mr coolant -leakage requirements' (SR 4.6.G)_-and the surveillance ncy associated with the primary containment atmosphere: particulate

.u , activity monitoring system, the_ primary ~ containment radiciodino:

monitoring system, and - the primary' containment gaseous- radioactivity monitoring system will be changed to "at least once: .per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ,"; as opposed to "at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ,""as specified currently. The basis for this change is the NRC SER discussed in-Prop'osed' Change One.

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HL-1446 001312 El-2 1

4 ENCLOSURE 1 (Continued)

REQUEST TO REVISE-TECHNICAL SPECIFICATIONS:

GENERIC LETTER 88-01 BASIS FOR CHANGE REQUEST PROPOSED CHANGE THREE:

This proposed change revises Unit 1 SR 4.6;K and Unit 2 SR 4.0,5 to include a paragraph stating the ISI Program for piping, covered by the scope of GL 88-01, is in conformance with NRC Staff positions on schedule,-methods and personnel, and sample expansion, except where specific written relief has been granted by the NRC. Also, material in Unit 2 SR 4.0.5 referencing'Section XI requirements prior to the start-of commercial operation has been-removed, Basis for'Pronosed Chance Three:-

In~ the February 16, 1990 SER, which addresses. GPC's response to GL 88-01, the - NRC requested GPC revise the existing TS by including the requirement to perform ISI in accordance with GL 88-01 and the BWR Technical Specifications Improvement Program. Specifically,-the SER revises- the Plant Hatch ISI -Program to be.in conformance with NRC Staff positions (GL 88-01) on schedule, methods and personnel, and sampleLexpansion, except:

where specific written relief has -been granted'by the Commission.- Also, in GL 88-01, the-NRC recognizes that in th9 future, the. inservice inspection and testing sections of the= TS may be deleted as part of the-BWR Technical Specifications Improvement Program, if this occurs, the requirement.will remain to-reference GL 88-01 in an alternativo requirements document.

, A section of existing Unit 2 SR 4.0.5 references the 2974/SummerL : 1975 .

Addenda of the ASME Code, 'Section XI, which is :no longer applicable and benee has been deleted. The remainitig text, which covers The operational phase, is still applicable, since it references ~ 10 CFR 50i._55<(9),

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

GENERIC LETTER 88-01 10 CFR 50.92 EVALVATION PROPOSED CHANGED ONE:

This proposed change revise the Unit 2 reactor coolant system (RCS) leakage monitoring Technical Specifications -(TS) requirements to reflect the latest NRC Staff positions. Unit 2 TS 3/4.4.2 has been modified to incorporate the requirements of an NRC Confirmatory Order dated July 8, 1983 and an NRC Safety Evaluation Report (SER) dated February 16, 1990.

Specifically, limiting conditions for operation (LCOs) and surveillance requirements (SRs) associated with Unit 2 TS 3.4 3.1 (Leakage Detection Systems) and 3.4 3.2 (Operational Leakage) have been modified to reflect the Confirmatory Order, except where superseded by the February 16, 1990 SER.

Basis for Prooosed 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. The proposed change does not significantly increase the probability or consequences of an accident prsviously evaluated. This change, which was made at the NRC's reque.t, does not involve any physical modifications to the plant and does not- affect the operation, maintenance, or testing of -the plant. Revising the RCS leakage monitoring interval or reducing the averaging period for checking-conformance to limits will not fundamentally change the method, or the fact that RCS leakage is checked on a frequent basis. For these reasons, this change does not significantly increase the probability or consequences of an accident previously evaluated.

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

Plant Hatch is analyzed for large, unisolatable leaks in the RCS; leakage is carefully monitored to reduce the probability of this occurring. Since no change is being made to the design, operation, maintenance, or testing of the plant, a new mode of failure is not created. Therefore, a new or different kind of accident will not occur as the result of this change.

3. The proposed change does not significantly reduce a margin of safety.

Safety analysis assumptions and equipment performance are not changed, as reflected in the NRC SER dated February 16, 1990. RCS leakage will continue to be carefully monitored.

HL-1446 001312 E2-1

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ENCLOSURE 2 (C 7tinued)

REQUEST TO REVISE TECHNICAL SPECif! CATIONS:

GENERIC L(JJER 88-01 10 CFR 50.92 EVALUATION l

! PROPOSED CHANGE TWO: I Unit 1 TS 3.6.G.1 (Reactor Coolant Leakage) and 3.6.G.2 (Leakage Detection Systems) will be modified to reflect the NRC's recommendations stated in the FeSruary 16, 1990 SER. Note that Amendment 93 changed the Unit 1 TS to incorporate NRC requirements relative to leakage limits and detection systems, <

jlasis.I,gt Proposed Chance Two:

! GPC has reviewed the proposed change (which is similar to Proposed Change One) and determined it does not involve a significant hazards consideration

based on the following:

1. The proposed change does not significantly increcse the probability of consequences of an accident previously evaluated. This change, which was made at the NRC's request, does not involve any physical

modifications to the plant and does not affect the operation, maintenance, or testing of the pl ant . Revising the RCS. leakage monitoring interval or reducing the- averaging period for checking conformance to limits will not fundamentally change the method, or the fact the RCS leakage is checked on a frequent basis. For these reasons, this change does not significantly increase the probability or consequences of an accident prevluusly evaluated. ,

2. The proposed change ooes not create the possibility of- a new or

different type of accident from any accident previously evaluated.

Plant Hatch is analyzed for large, unisolatable -lenk; in the RCS; leakage is carefully _ monitored to reduce the probability of this occurring. Since no change is being made to-the design, nperation, maintenance, or testing of- the plant, a new mode of- failure is not created. Therefore, a new or different kind of accident will not occu as the result of this change, I

3. The proposed change does not significantly reduce a margin of safety. .

2 Safety analysis assumptions and equi) ment performance are not changed, as reflected in the NRC SER-dated Fe)ruary 16,--1990 - RCS leakage =will continue to be carefully monitored.

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i ENCLOSURE 2 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

GENERIC LETTER Bj.:,Q1 I

10 CFR 50.92 EVALUAi!0N PROPOSED CHANGE THREE:

This proposed change revises Unit 1 TS 4.6 K and Unit 2 TS 4.0.5 to include a paragraph stating the ISI Program for piping, covered by the-scope of GL 88-01, is in conformance with the NRC Staff positions related to schedule, methods and personnel, and sample expansica, except where specific written relief has been granted by the NRC. Also, obsolete material in Unit 2 TS 4.0.5 referencing Section XI requirements prior to the start of commercial operation has been removed, fysis for Pr_gposed Chance Thtn:

GPC has reviewed the proposed change and determined it does not-involve-a significant hazards consideration based on the fc11owing:

1. The proposedofchange consequences an accidentwillprev not sig"iously evaluated.ificantly This change, which increase the probability was made at the NRC's request, simply restates the wording of GL 88-01 '

relative to 151. No changes to Plant Hatch 151 practices or methods are being made. This change does not involve any physical modifications to the plant and does not affect the operation, maintenance, and testing of the plant. Deleting the portion of existing Unit 2 TS 4.0.5, which reflected inservice inspection and testing requirements prior -to commercial operation, will have no impact, since both units have been operating for several years and follow the applicable 10 CFR 50.55a(g) requirements. 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 type of accident from any accident previously evaluated, 3 Since no change is being made to the design, operation, maintenance, or.

testing of the plant, a new mo.' of failure is not created. Therefore, a new or different kind' of ac,.ident will not occur as the result of this change.

3. The proposed change does not significantly reduce a margin of safety.

Safety analysis assumptions and equipment performance are not changed,

.s reflected in the NRC SER dated February 16. 1990. >

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ENCLOSURE 3 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES OPR-57, NPF-5 REQUEST TO REVISE TECHNICAL SPECIflCATIONS:

GENERIC LETTER 80_91 PAGE CHANGE INSTRUCTIONS The proposed changes to the Plant Hatch Units 1 and 2 Technical Specifications (Appendix A to Operating Licenses OPR-57 and NPF-5) will be incorporated as follows.

htgg Instruction UNIT 1: 3.6-7 Replace 3.6-8 Replace 3.6-10 Replace UNIT 2: 3/4 0-2 Replace 3/4 0-3 Replace 3/4 4-5 Replace 3/4 4-6 Replace

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HL-1446, Application for Amends to Licenses DPR-57 & NPF-5 Revising Tech Specs Re Generic Ltr 88-01, NRC Position on IGSCC Austenitic Stainless Steel Piping

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Enclosures:

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