ML19338D094

Application for Amend to Licenses DPR-57 & NPF-5 Consisting of Changes to Tech Specs

ML19338D094
Person / Time
Site:	Hatch
Issue date:	09/15/1980
From:	Widner W GEORGIA POWER CO.
To:
Shared Package
ML19338D095	List: ML19338D094 ML19338D099 ML19338D103
References
NUDOCS 8009190423
Download: ML19338D094 (4)

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a September 15, 1980 g 1 4. m o.,, Georgia Power v mr- m :r< c,s:m Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 6

NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, KPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2 NUREG-0578 RELATED TECHNICAL SPECIFICATION CHANGES Centlemer.:

Putetant to the request contained in your July 2, 1980, letter, Georgia Power Company has examined the need for Technical Specifications related to NUREG-0578 tategory A action items. The NRC proposed model specifications were evaluated for their effectivenss and pertinence to Plant Hatch's custom specifications as a part of this exaratacion. Enclosed are requested revi-sions to the Unit 1 and Unit 2 Technical Specifications (TSs) which were formulated as a result of our study. Each of the four proposed specifications are discussed below:

Water Level Instrumentation Water level instrumentation provides essential information to the plant operator both during operation and the Post-accident period. The supply of power to these instruments is discussed in enclosure 1 of our January 25, 1980, letter. Present Technical Specifications (Table 3.2-11 and 4.2-11 for Unit 1 and Table 3.3.6.4-1 and 4.3.6.4-1 for Unit 2) meet or exceed the requirements s stgcated by tb model Technical Specifications and are, therefore, not revised.

Valve Position Indication Safety / relief valve position indication is provided by two independent, diverse instruments on each of the Plant Hatch units. The primary in-dication is a pressure activated switch on the tailpipe of each of the SRVs.

The secondary indication is provided by a downstream temperature detector.

These instruments are discussed in greater detail by enclosure 3a of our January 25, 1980, letter. Either of these instruments provides the operator with the information necessary to determine if a SRV is open.

Together they can te considered to form two independent, diverse channels of a system for the mot.itoring of SRV position. While this system should be operabic and therefore should receive periodic surveillance, the proposed model Technical Specifications are overly restrictive with regard to the Limiting Condition for Operation. (LCO) . Plant Hatch has eleven SRVs with twenty-two valve position channels per unit. As the LCO is proposed in the

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A Georgia Power m.a Director of Nuclear Reactor Regulation i

U. S. Nuclear Regulatory Commission

September 15, 1980 i j Page Two i 4

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j model TSs, should any one of the eleven primary channels become inope-rable, a shutdown within seven days would be required. This requirement is inconsistent with the importance to safety of a stuck open relief valve and the philosophy previously employed in Technical Specifications l which permitted credit for backup instrumentation. It is our position l i that operability of the SRV position instrumentation is not . critical to  !

l' the safe shutdown capabilities of the plant. We have, therefore, proposed alternative actions for the condition of an inoperable SRV position indication. Specifically, if either the primary or secondary instrument ,

is inoperable, the torus temperature will be monitored periodically to l observe any unexplained temperature increases which occur which might i indicate an open SRV.. Should both channels be inoperable in two or more 1

SRVs, such that the open SRV could not be determined by deduction using 4

available indication, sufficient inoperable channels would be restored to I an operable status so that no more than one SRV has both primary and i secondary channels inoperable. If this could not be accomplished within seven days, the plant would be placed in hot shutdown within the next twelve hours. This LOC in conjunction with the surveillance proposed by

the model TSs will meet the intent of a reliable diagnostic aid to the l j operator.

i j Containment Isolation i

j- Present Technical Specifications for both Units 1 and 2 address the concern i

for a Table of Containment Isolation Valves and their respective isolation signals and associated surveillance. Unit 2 was licensed with Technical Specifications which were based upon BWR standard Technical Specifications which closely resemble the model TSs with the insignificant omission from

, tables of manual initiation of containment isolation. Unit 1 TSs having been licensed and issued prior to the BWR. Standard Technical Specifications contain the principle features of the model TSs, but in a different format.

4 Tables 3.2-1, 3.2-8, 3.7-1, 4.2-1, and 4.2-8 of Unit 1 TSs and Tables 3.3.2-1, 3.3.2-2, 3.3.2-3, 4.3.2-1, and 3.6.3-1 of Unit 2 TSs provide similar information and surveillance requirements to the model TSs tables,

and thus meet thier intent. Therefore, the present Technical Specifications do not require revision.

Shift Technical Advisor The specification related to minimum shif t manning was revised to reflect I. the position of Shif t Technical Advisor as recommended by the model TSs.

However, this specification should not become effective until January 1, 1981. . Prior agreement with the Commission staff provides for non-degreed 7

STAS through 1980.

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Georgia Power d U. S. Nuclear Regulatory Commission Director of Nuclear Reactor Regulation September 15, 1980 Page Three The Plant Review Board and the Safety Review Board have reviewed this proposed change to the Unit 1 and Unit 2 Technical Specifications, and have determined that an unreviewed safety question is not involved. The possibility of a new accident or malfunction not previously considered has not been created; nor have the consequences of previously analyzed accidents or mal-functions been changed. Margins of safety have not been reduced nor operating limits changed in a non-conservative direction.

1 Very truly yours, hY lh$ &

W. A. Widner .

I WEB /mb Sworn and subscribed before me this 15th day of September, 1980.

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Notary Public Notary Pubitc Georgia, State at Large xc: M. Manry My Comnission Enres Sept 20,1983 l R. F. Rogers, III l

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ATTACllMENT 1 NRC DOCKETS 50-321, 50-366 OPEKATING LICENSES DPR-57, NPF-5 EDWIN I. IIATCil NUCLEAR PLANT UNITS 1, 2 PROPOSED DETERMINATION OF AMENDMENT CLASS Pursuant to 10 CFR 170.12 (c), Georgia Power Company has evaluated the attached proposed amendments to Operating Licenses DPR-57 and NPF-5 and has determined that:

a) The proposed amendment does not require the evaluation of a new Safety Analysis Report or rewrite of the facility license; b) The proposed amendment does not contain several complex issues, does not favolve ACRS review,and does not require an environmental impact statement; c) The proposed amendment does not involve a complex issue, an environmental issue, and is not deemed to involve a significant hazards considera tion; d) The proposed amendment is therefore a Class III amendment for Unit 1 and a Class I amendment for Unit 2.