ML20034A301
| ML20034A301 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 04/11/1990 |
| From: | Hairston W GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20034A302 | List: |
| References | |
| HL-949, NUDOCS 9004230014 | |
| Download: ML20034A301 (6) | |
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ta. wr o;c m HL-949 000172 April 11, 1990 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 PLANT HATCH - UNIT 2 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:
i REMOVAL OF 3.25 LIMIT ON EXTENDING SURVEILLANCE INTERVALS Gentlemen:
i In accordance with the provisions of 10 CFR 50.90, as-required by 10 CFR 50.$9 (c)(1), Georgia Power Company (GPC) hereby proposes changes to the Plant Hatch Unit 2 Technical Specifications, Appendix A to Operating License NPF-5.
Specification 4.0.2 of the Plant Hatch Unit 2 Tec'hnical Specifications allows surveillance intervals to be extended up to 25 percent of the specified time interval.
Specification 4.0.2 currently limits the combined time interval for any three consecutive surveillance intervals to less than 3.25 times the specified surveillance interval. On August 21, 1989, the i
NRC issued Generic letter 89-14 which encouraged licensees to propose changes to plant Technical Specifications consistent with the guidance provided in the letter.
The NRC concluded removing the 3.25 limit from S)ecification 4.0.2 results in a greater benefit to safety than limiting tie use of the 25-percent allowance to extend surveillance intervals.
Consistent with the guidelines provided in Generic Letter 89-14, GPC proposes a revision to Unit 2 Technical Specification 4.0.2 to remove the 3.25 limit on extending surveillance intervals.
This change will remove an unnecessary restriction on extending surveillance requirements, thereby resulting in a benefit to safety when plant conditions are not conducive to the safe conduct of surveillance requirements. The removal of the 3.25 limit will provide greater flexibility in the use of the provision for extending surveillance intervals, reduce the administrative burden associated with its use, and have a positive effect on safety, f
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Georgia Ponvr d i
U.S. Nuclear Regulatory Commission April 11, 1990 Page Two
! provides a detailed description of the proposeo change'and the circumstances necessitating the change request.
' details the bases for GPC's determination that the proposed i
change does not involve significant hazards considerations.
l provides page change instructions for incorporating the proposed change into the Technical Specifications.
The. proposed changed l
pages for Unit 2 follow Enclosure 3.
l To allow time for procedural revisions and orderly incorporation into I
copics of the Technical Specifications, 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.
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. L. Ledbetter of l
the Environmental Protection Division of the Georgia Department of Natural Resources.
Mr.
W. G. Hairston, III states he is Senior Vice President of Georgia Power Company and is authorized to execute this oath on behalf of Georgia i
Power Com)any, and to the best of his knowledge and belief, the facts set forth in t1is letter are true.
GEORGIA POWER COMPANY BY:
ki d. $ d n i
- h. G. Hairston, III Sworn to and subscribed before me this fL, day of doi /
1990.
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Enclosures:
1.
Basis for Change Request W %.t;wp"%M'O 2.
10 CFR 50.92 Evaluation 3.
Page Change Instructions c: (See next page.)
000172 k
- Geory,ia Power A U.S. Nuclear Regulatory Comission
)
April 11, 1990 Page Three 1
c: Georaia Power Comoany Mr. H. C. Nix, General Manager - Nuclear Plant Mr. J. D. Heidt, Manager Engineering and Licensing - Hatch GO-NORMS U.S. Nuclear Reaulatory Comission. Washinoton. D.C.
Mr. L. P. Crocker, Licensing Project Manager Hatch U.S. Nuclear Reaulatory Comission. Reaion II Mr. S. D. Ebneter, Regional Administrator Mr. J. E. Menning, Senior Resident Inspector - Hatch State of Georaia Mr. J. L. Ledbetter, Comissioner - Department of Natural Resources i
s
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l 000172
-v-w-u-
T ENCLOSURE 1 PLANT HATCH - UNIT 2 NRC DOCKET 50-366 OPERATING LICENliE NPF-5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:
REMOVAL OF THE 3.25 LIMIT ON EXTENDING SURVEILLANCE INTERVALS BASIS FOR CHANGE RE0 VEST PROPOSED CHANGE:
i Plant Hatch Unit 2 Specification 4.0.2 currently limits the combined time interval for any three consecutive surveillance intervals to less than 3.25 times the surveillance interval.
The proposed change removes the 3.25 1
limit on extending surveillance intervals.
BASIS FOR PROPOSED CHANGE:
This request complies with the NRC's recommendation transmitted in Generic Letter "Line Item Improvements in Technical Specifications, Removal (GL) 84-14 of the 3.25 Limit on Extending Surveillance Intervals dated.
August 21, 1989."
In the letter, the NRC states that limiting the combined time interval for any three consecutive tests to 3,25 percent of the test interval is an unnecessary restriction and, therefore, recommends removing the 3.25 limit from Specification 4.0.2.
Georgia Power Company's concurrence with the NRC's recommendation is based on the following points:
1.
For tests performed during a refueling outage, the risk associated with removing the 3.25 limit is small compared to the negative impact of a forced shutdown.
In GL 89-14, the NRC concluded the 3.25 limit is impractical.
That is, the NRC has routinely granted one-time l
exceptions to the 3,25 on extending refueling surveillances, because, with each exception, the risk of continued operation was small compared to the risk of a forced shutdown to perform the surveillance.
2.
For tests performed during power operation, a safety benefit can be gained by removing the 3.25 limit. The basis for allowing a 25-percent extension for a single test is improved safety.
For example, plant safety is improved when a survelliance test can be delayed when plant conditions are not suitable for performing the test (i.e.,
transient plant operating conditions or conditions in which safety systems are out of service due to ongoing surveillance or maintenance activities.
Because the 25-percent extension is justified on the basis of improved plant safety, limiting its use to the 3.25 limit has no basis.
1
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000172 HL-949 El-1
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l ENCLOSURE 1 (Continued)
REQUEST TO REVISE TECHNICAL SPECIFICATIONS:
REMOVAL OF THE 3.25 LIMIT ON EXTENDING SURVEILLANCE INTERVALS BASIS FOR CHANGE REQUEST The intent of the 3.25 limit on extending surveillance intervals is to preclude routine use of the provisions for extending a surveillance interval by 25 percent.
GPC does not intend that this Amendment be used as a convenitnce to allow surveillance intervals to be repeatedly - ' ended beyond their specified interval for surveillances intended to be pe' *rmed on a routine basis during plant operation.
L 000172 HL-949 El-2
I ENCLOSURE 2 j
PLANT HATCH - UNIT 2 f
NRC DOCKET 50-366 OPERATING LICENSE NPF-5 i
I REQUEST TO REVISE TECHNICAL SPECIFICATIONS-REMOVAL OF THE 3.25 LIMIT ON EXTENDING SURVEILLANCE INTERVALS
~
i 10 CFR 50.92 EVALUATI.QN PROPOSED CHANGE:
i Unit 2 Technical Specification 4.0.2 currently limits the combined time l
interval for any three consecutive surveillance intervals to less than 3.25 times the surveillance interval.
The proposed change removes the 3.25 limit on extending surveillance intervals.
BASIS FOR PROPOSED CHANGE:
Georgia Power Company has evaluated the proposed amendment and determined it does not involve a significant hazards consideration, because:
1.
The proposed change does not involve a significant increase in the proba)ility or consequences of an accident previously evaluated.
Removing the 3.25-percent limit on extensions to surveillance intervals does not change the frequency of accident initiators or1 _the consequences of any accidents previously evaluated.
This amendment only affects the reliability of systems used to respond to accidents.
2.
The possibility of a different kind-of accident from any analyzed i
previously is not created by this change.
No change in the design or function of any plant system or component will result from this revision.
l 3.
The margin of safety is not significantly reduced by this change.
The basis for this conclusion is as follows:
a.
For surveillance testing performed each refueling outage, the NRC recognizes this requirement (3.25 limit) is unneccessarily i
restrictive.
In GL 84-14, the NRC concludes.the risks involved in l
delaying a test up to 25 percent of the allowed 18 months are insignificant when compared to the negative impacts of a forced shutdown in order to perform testing.
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b.
For surveillance testing performed during power operation, the l
margin of safety is improved by deleting the 3.25 requirement.
The allowed 25-percent extension is already justified in the Technical l
Specifications on the basis of improved plant safety.
Because each extension is justified on the basis of improved plant safety, denying the extension a second time merely because the conditions occur twice during three consecutive tests has no basis.
000172 i
HL-949 E2-1 1
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