ML20036A222

Safety Evaluation Supporting Amends 185 & 125 to Licenses DPR-57 & NPF-5,respectively

ML20036A222
Person / Time
Site:	Hatch
Issue date:	04/30/1993
From:	Office of Nuclear Reactor Regulation
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ML20036A223	List: ML20036A222
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NUDOCS 9305100243
Download: ML20036A222 (14)

Text

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UNITED STATES a " )M /%

NUCLEAR REGULATORY COMMISSION

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.j WASHINGTON, D. C. 20555 w,

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.185 TO FACILITY OPERATING LICENSE DPR-57 AND AMENDMENT NO.125TO FACILITY OPERATING LICENSE NPF-5 GEORGIA POWER COMPANY. ET AL.

EDWIN I. HATCH NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-321 AND 50-366

1.0 INTRODUCTION

By letter dated February 26, 1991, as supplemented February 4 and December 21, 1992, and February 17, 1993, Georgia Power Company, et al. (GPC or the licensee), proposed license amendments to change the Technical Specifications (TS) for the Edwin I. Hatch Nuclear Plant, Units I and 2.

The proposed changes incorporate allowable out-of-service times (A0T) for surveillance and repair with extended functional test intervals for Emergency Core Cooling (ECCS), Isolation Actuation Instrumentation, Reactor Protection System (RPS),

control rod blocks, Reactor Core Isolation Cooling (RCIC), and selected instrumentation as outlined in General Electric Topical Reports NEDC-30936P-A, Part 2, NEDC-31677P-A, NEDC-30851P-A, NEDC-30851P-A (Supplements 1 and 2),

GENE-770-06-1, and GENE-770-06-2. These reports utilize a probabilistic approach to establish a technical basis for extending surveillance test intervals and allowable out-of-service times. The'results of the analysis show the effect on the probability of failure to actuate is negligible for the extended surveillance intervals and A0Ts proposed for ECCS, Isolation Actuation Instrumentation, RPS, control rod blocks, RCIC, and selected instrumentation.

The referenced licensing topical reports were previously reviewed by the staff and found to be acceptable. The staff issued Generic Safety Evaluation Reports approving the results of the analysis and specifying the requirements for plant-specific application.

The December 21, 1992, and February 17, 1993, letters provided additional information in support of the above changes.

The letters did not change the NRC staff's proposed no significant hazards consideration determination as published in the Federal Reaister on April 15, 1992 (57 FR 13131).

The Hatch Unit 1 TS do not provide complete A0T for testing or repair. The TS requires this instrumentation to be operable or tripped. The licensee currently controls the A0T administratively based on a TS notation for RPS allowing an instrument to be out of service for a brief period of time.

In the absence of a repair / test A0T, it would normally be expected that the action statement /LCO would be entered when a system is inoperable during required surveillance testing. The Hatch Unit 1 TS provide, limited allowances and time limits for ECCS.or isolation actuation instrumentation 9305100243 930430 DR ADOCK 0500 1

'l surveillance testing.

The Unit 2 TS provide test a'nd repair A0Ts consistent with the Standard Technical Specifications (STS) for isolation actuation instrumentation and limited allowances and time limits for ECCS instrumentation. The STS allow a channel (instrument) to be inoperable for a 1

specified~ period of time in order to perform surveillance testing.

To provide for required instrument surveillance-testing the licensee proposed A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for the surveillance of referenced topical report i

instrumentation.

The licensee also proposed 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> surveillance test A0Ts for instrumentation not specifically addressed by the referenced topical reports or the STS.

A repair A0T for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is also proposed.for ECCS, Isolation Actuation and additional topical report related instrumentation.

The surveillance functional test intervals for ECCS, Isolation Actuation, and additional instrumentation have been revised from once per month to quarterly based on reliability analysis results presented in the referenced GE topical reports.

The licensee proposed to revise the isolation actuation and selected instrumentation tables in the Unit 1 TS to more closely resemble the Unit 2 TS.

Changes to the RPS, bases, and various editorial changes were also

.i proposed for both units.

l The licensee performed an evaluation of GE topical reports NEDC-30936-A Part 2, NEDC-31677P-A, NEDC-30851P-A, NEDC-30851P-A (Supplements I and 2), GENE-l 770-06-1, and GENE-770-06-2 and concluded that the' topical report generic analysis is applicable to Hatch Units I and 2.

~

't By letter dated April 27, 1988, from C. Rossi-(NRC) to the'BWR 0wners Group, i

the NRC requested licensees to examine plant setpoint drift data over a sufficient period'to demonstrate that the drift expected with extended a

t surveillance intervals is within the existing calculated setpoint allowance or l

that the allowance and/or setpoint have been adjusted to account for the expected increase in drift. No additional information was requested for staff review by the above referenced letter. However, records showing the actual setpoint calculation and supporting data should be retained onsite for l

possible future staff audit.

The licensee reviewed the plant setpoint calculations (drift) associated with the affected instrumentation and determined that the existing setpoint drift calculations bound the proposed quarterly functional test surveillance i

interval.

No revision to instrument setpoint values or allowances were i

required.

I 2.0 EVALUATION t

The proposed changes include revising the Emergency Core Cooling System (ECCS) i 5

and Isolation Actuation Instrumentation channel functional test interval from monthly to quarterly.

For instrumentation where the existing calibration j

interval is-quarterly, the channel calibration now incorporates the channel functional test. The proposed quarterly test interval is in agreement with i

the approved GE topical reports and is acceptable to the staff.

l 4

t t

A 6-hour surveillance test A0T for ECCS and isolation actuation instrumentation is also provided.

For Hatch Units 1 and 2, the 6-hour test A0T has been included in the action statement. The proposed A0T is in agreement with the referenced topical reports. These changes are acceptable to the staff.

The licensee revised the action statement /LC0 to incorporate a 12-hour A0T for ECCS and Isolation Actuation Instrument repair. The 12-hour A0T proposed by the licensee is in agreement with the GE topical reports. The staff finds the proposed 12-hour A0T for repair and the associated action statements to be acceptable.

The licensee also included a 2-hour A0T for Unit 1 Table 3.2-1 (Isolation Actuation Instrumentation) action statement /LC0 for restoring of an inoperable channel (single channel per trip system) when tripping that channel would cause the trip function to occur. This is in agreement with the Hatch Unit 2 TS and STS.

The proposed action statement is acceptable to staff.

The licensee revised Unit 1 TS Table 3.2-1 to include additional HPCI, RCIC, and LPCI isolation instrumentation that was previously listed on Unit 1 TS Tables 3.2-2, 3.2-3, and 3.2-5 (and corresponding surveillance Tables 4.2-2, 4.2-3, and 4.2-5).

This change provides one uniform table for isolation actuation instrumentation and results in a more consistent application of the action statements /LCO. The proposed licensee revision to TS Table 3.2-1 is consistent with the STS and applicable GE topical reports. This change is acceptable to the staff.

The licensee also proposed test A0Ts for instrument surveillance A0Ts not specifically referenced in a topical report or the STS. The selected A0T is 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and is consistent with the test A0Ts specified for RPS, ECCS, and Isolation Actuation Instrumentation. The licensee did not propose any extension of the functional test surveillance interval or repair A0T for this instrumentation.

The licensee indicated that having to enter the actions statement for testing can restrict the time available to perform the surveillance and may result in implementation of the action statement. The addition of a test A0T for instrumentation not referenced in the STS and GE topical reports will allow consistency with the A0Ts for both RPS, ECCS, Isolation Actuation, and related instrumentation.

In some cases, the addition of a test A0T will limit the out-of-service time allowed for surveillance testing when compared to the current action statement /LCO. Additionally, the proposed instrumentation may be related to instrumentation covered in the topical report, may perform only monitoring functions, or is unique to the custom TS format.

Based on the above, the staff finds the proposed changes acceptable as referenced in the licensee submittal.

The licensee proposed changes to the Reactor Protection System surveillance test A0T to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (Unit 1 Table 3.1-1).

This change completes the RPS A0Ts previously submitted by the licensee, is in agreement with the referenced topical reports, and is, therefore, acceptable to the staff.

Additional editorial changes were also proposed for both units.

J

.! 1 Technical Soecification Amendments As a result of the TS changes associated with the referenced GE topical d

. reports and related instrumentation, the licensee proposed various amendment's j

to the Hatch Units l'and 2 TS. The staff finds the following~ changes-acceptable.

l Unit 1 Technical Soecification Chanaes Chance 1:. Table of Contents, Page 1, Section 3.2, Protective M

Instrumentation, Item A.

The description for Item 3.2-A is revised to l

" Isolation Actuation Instrumentation" to be more consistent with the Unit 2, 1

TS.. The description' for Surveillance Section 4.2 is also revised accordingly..

3 Chance 2: List of Tables, Pages vii, viii, Table 3.2-1. The title is revised -

l, to " Isolation Actuation Instrumentation" to be more consistent with the Unit 2 TS. Table 4.2-1 is revised to " Isolation Actuation Instrumentation

' Surveillance Requirements" to agree with Table 3.2-1.

Chanae 3: Table 3.1-1, Note (b), Page 3.1-6.

" Reactor Protection System" is j

modified to include a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> as Note / ACTION (b.2).

t Chanae 4:

Bases Section 4.1, Item A, Page 3.1-15. " Reactor Protection System" l

1s revised to reflect the incorporation of the referenced GE topical ^ reports and.to be more consistent.with the STS.

b Chanae 5

Bases Sections, 4.1.A.2.and 4.1.A, Pages 3.1-16 and 3.1-17 is'no-longer applicable and is deleted.

5 Chanae 6: Bases Section 4.1.C, References, Page 3.1-18, is revised to' include.

1 the referenced GE topical report. The graphical aid (Figure 4.1.1) for-i selection of an adequate interval between tests is no longer applicable and is deleted.

Chance 7:. Section.3.2, Page 3.2-1, Item A is revised to read " Initiates Isolation Actuation."

l

.(

Chanae 8: Table 3.2-1, Page 3.2-2.

The title is revised to match the Unit.2 1

-TS and'the STS, " Isolation Actuation' Instrumentation."

A.

Revise action statement and remarks for Functional Unit 2, " Reactor a

Vessel Steam Dome Pressure (Shut-down cooling mode)."

a B.

Revise required operable channels lper trip system: from one to two for y

functional Unit 16, "HPCI Turbine Exhaust Diaphra'gm Pressure" and-Functional Unit 22,~"RCIC Turbine Exhaust' Diaphragm Pressure" (Pages 3.2-3a-and 3b)..

l

t C.

Revise Note (c), Page 3.2--4.to be consistent with the ACTION in the Unit 2

+

TS/STS and to include a maintenance A0T of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Note-(c) is relabelled as (c.1).and a new note (c.2) is added to include a

-m

'b m

,2

=

surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Note (b) is relabelled as (b.1) and a new note (b.2) is added to include a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Chanae 9: Table 3.2-2, Pages 3.2-5, 3.2-6, and 3.2-7, " Instrumentation Which Initiates-or Controls HPCI."

A.

Delete Functional Units 8 through 13.

These Functional. Units are transferred to Table 3.2-1 to provide consistent actions for Isolation Actuation Instrumentation.

B.

Revise note _ (b) to include a maintenance A0T of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and. include a new note to provide a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The notes are labelled (b.1) and (b.2), respectively.

Chance 10: Table 3.2-3, Pages 3.2-8, 3.2-9, and 3.2-9a, " Instrumentation Which Initiates or Controls RCIC."

A.

Delete Functional Units 7 through 12. These Functional Units are transferred to Isolation Actuation Table 3.2-1 to provide consistent ACTIONS for isolation actuation instrumentation.

B.

Revise note (b) to include a maintenance A0T of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and include a new note to. provide a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The: notes are labelled -

(b.1) and (b.2) respectively.

Chance 11: Table 3.2-4, Page 3.2-10, " Instrumentation Which Initiates or

-Controls-ADS." Revise note (b) to include a maintenance A0T time of 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />s-and include a new note providing a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The. notes are~-

labelled (b.1) and (b.2), respectively.

Chanae 12:. Table 3.2-5, Pages 3.2-11 and 3.2-13 " Instrumentation Which Initiates or Controls the LPCI Mode of RHR." Revise Functional Unit 3

" Reactor Vessel Steam Dome Pressure" to differentiate the functions for each instrument.

Revise note (b) to include a maintenance A0T of_12 hours and include a new note _ providing a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. These notes are labelled (b.1) and (b.2), respectively.

Chanae 13: Table 3.2-6,' Page 3.2-14, " Instrumentation Which Initiates or Controls Core Spray." Revise note-(b) to include' a maintenance A0T. of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and include a new ' note providing a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The notes:are labelled (b.1) and (b.2), respectively.

'Chanae 14: Table 3.2-7, Pages 3.2-16a and 3.2-17, " Neutron Monitoring Instrumentation' Which Initiates Control Rod Blocks."' Revise note (b) to-include a surveillance A0T of'6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.- The notes are labelled (b.1) and (b.2),:respectively. Note (h) is added to specify' that control rods are not permitted to be withdrawn during surveillance testing'(scram discharge volume).

Chance 15: Table 3.2-8, Page 3.2-19, " Radiation Monitoring Instrumentation Which Initiates Control Rod Blocks." Revise note (b) to include a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The notes are labelled (b.1) and (b.2),

respectively.

Chance 16:

Table 3.2-9, Page 3.2-20, " Instrumentation which Initiates Recirculation Pump Trip." Revise note (b) to include a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The notes are labelled (b.1) and (b.2), respectively.

Revise note (f) to include a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The notes are labelled (f.1) and (f.2), respectively.

Chance 17: Table 3.2-10, Page 3.2-21, " Instrumentation Which Monitors Leakage into the Drywell." Revise note (b) to include a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

The notes are labelled (b.1) and (b.2), respectively.

Chance 18: Table 3.2-11, Pages 3.2-23 and 3.2-23a, " Instrumentation Which Provides Surveillance Information." Add note (c.2), (e.2), and (f.2) to include a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Label notes (c), (e), and (f) as (c.1), (e.1), and (f.1), respectively. Add note (g.2) to include a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Revise note (g) to (g.1) and relabel items (1) and (2) as (a) and (b).

Chance 19:

Table 3.2-12, Page 3.2-23b, " Instrumentation Which Initiates the Disconnection of Offsite Power Sources." Add note (c.2) to include a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Relabel note (c) as (c.1).

Chance 20: Table 3.2-14, Page 3.2-23d, " Instrumentation Which ARMS Low Set S/RV System." Add note (b.2) to include a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Relabel note (b) as (b.1).

Chance 21: Table 4.2-1, Pages 3.2-24, 3.2-25, 3.2-25a, and 3.2-26; Rename title as " Isolation Actuation Instrumentation Surveillance Requirements" to be consistent with the Unit 2 TS and the STS.

A.

Revise from monthly to quarterly the channel functional test frequency for Functional Units referenced in the licensee submittal (Table 4.2-1,

" Isolation Actuation Instrumentation Surveillance Requirements").

B.

Note (d) is no longer appropriate and is deleted.

C.

Revise the instrument channel check frequency for Functional Unit 12, "Drywell Radiation" from once per day to once per shift.

D.

Add Functional Units 13 through 24 as referenced in the licensee submittal.

This change provides consistent actions for isolation actuation instrumentation.

Chance 22: Table 4.2-2, Pages 3.2-27, 3.2-28, and 3.2-29, " Check, Functional Test, and Calibration Minimum Frequency for Instrumentation Which Initiates or Controls HPCI."

A.

Revise from monthly to' quarterly the channel functional test frequency for the Functional Units referenced in the licensee submittal.

y

<a s

l l

l o

l i B.

' Delete Functional Units 8 through 13.

This change provides consistent ACTIONS for Isolation Actuation Instrumentation.

C.

Note (d) is no longer appropriate and is deleted.

t Chanae 23: Table 4.2-3, Pages 3.2-30 and 3.2-31, " Check, Functional Test, and Calibration Minimum Frequency for Instrumentation Which Initiates or Control RCIC."

A.

Revise from monthly to quarterly the channel functional test frequency.

}

I for the Functional Units as referenced in the licensee submittal.

B.

Delete Functional Units 7 through 12. This change provides consistent application.of the ACTIONS for-Isolation Actuation Instrumentation.

-r Chance 24: Table 4.2-4, Page 3.2-33, " Check, functional Test, and Calibration Minimum Frequency for Instrumentation Which Initiates or Controls ADS."

Revise from monthly to quarterly the channel functional test frequency for the functional units referenced in the licensee submittal.

7 Chance 25: Table 4.2-5,~ Page 3.2-35, " Check, Functional Test, and Calibration Minimum Frequency for Instrumentation Which Initiates or Controls'the LPCI Mode of RHR." Revise the channel functional test frequency from monthly to quarterly for the functional units referenced it in the licensee submittal.

Revise Functional Unit 3, " Reactor Vessel Steam Dome Pressure" to= reflect the i

function of each instrument.

Chanae 26: Table 4.2-6, Page 3.2-38, " Check, Functional. Test and Calibration Minimum Frequency for Instrumentation Which Initiates or Controls Core Spray."

Revise the channel functional test frequency from monthly to quarterly-for the Functional Units' referenced in the licensee submittal.

1 Chanae 27: Table'4.2-7, Page 3.2-40, " Check, Functional' Test,.and Calibration l

Minimum Frequency for Neutron Monitoring' Instrumentation Which Initiates Control Rod Blocks." Revise the channel functional test frequency from

-monthly to quarterly for Functional Unit (3.c), "APRM Downscale" as-refer enced

~

in the licensee submittal.

Chance 28: Table 4.2-8, Pages 3.2-42 and 3.2-43, " Check, Functional' Test and I

Calibration Minimum Frequency for Radiation Monitoring Systems Which Limit Radioactivity Release." Revise' the channel functional. test frequency from'-

monthly to quarterly for the Functional Units referenced in the licensee submittal... Also,. note (e) is no longer appropriate and is deleted.

Chance 29: Table.4.2-9, Page 3.2-45, " Check, and Calibration Minimum-Frequency for Instrumentation Which Initiates Recirculation Pump Trip."

Revise the channel functional test frequency from monthly'to quarterly for the Functional Units referenced -in the licensee' submittal..

Chance 30: Table'4.2-10,'Pages 3.2-46 and 3.2-47, " Check, Functional Test, and Calibration Minimum frequency for Instrumentation Which Monitors Leakage l

into the Drywell " _ Revise the channel functional test-frequency.to monthly-I

1 1 for the Functional Units referenced in the licensee' submittal. Note (e} is no longer appropriate and is_ deleted.

Chance 31: Table 4.2-14, Page 3.2-49c, " Check, Functional Test, and Calibration Minimum Frequency for Instrumentation _Which Arms the Low Low Set S/RV System." Revise the channel functional test frequency from monthly to quarterly for the functional Units referenced in the licensee submittal.

Chanat_32: Pages 3.2-69, 3.2-70, and 3.2-71, " Bases for Limiting Conditions for Operation", Section 4.2, " Protective Instrumentation" is revised to reference the methodologies and related topical reports that form the bases for the surveillance and repair A0Ts proposed by the licensee.

Figure 4.2-1,

" System Unavailability," is no longer required and is deleted.

Chanae 33:

Page 3.2-50, " Bases for Limiting Conditions of Operation," Section 3.2, " Protection Instrumentation" is revised to reflect the incorporation of the GE topical report channel functional test frequencies and A0Ts.

Additional changes are included to reflect revisions to Tables 3.2-1, 3.2-2, 3.2-3, and 3.2-5. (Pages 3.2-52, -52a, -52b, -53, -54, -55, -56, -57, and -60)

Chance 34: Section 4.5H, Page 3.5-11, " Maintenance of Filled Discharge r

Pipes," Item (4).

The channel functional test requirements for' the discharge piping level switches are revised from monthly to quarterly.

Chance 35:

Section 4.6.H.1, Pages 3.6-9 and 3.6-9a, " Operability of Tailpipe Pressure Switches" Item (e). Revise item (e) to include a 6-hour surveillance A0T and increase the channel functional test interval from 31 days to every 92 days.

Chance 36:

Section 4.6.H.2, Page 3.6-9a, " Relief Valves low Set Function,"

Item (a).

Revise the functional test interval from monthly to quarterly and incluce a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Chance 37: Section 4.9.A.7, Page 3.9-4a, " Logic Systems," Item 3.

Item 3 is covered elsewhere in the TS and is, therefore, deleted, Chance 38: Section 3.14.1, Page 3.14-1, ACTION (b), " Radioactive Liquid Effluent Instrumentation." Revise ACTION (b) to provide for a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> as referenced in the licensee submittal.

Chance 39: Table 3.14.2-1, Pages 3.14-9 and 3.14-10, ACTIONS 104, 105, 106, 107, and 108, " Radioactive Gaseous Effluent Monitoring Instrumentation."

Revise the above ACTION statements to include a surveillance interval of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> as referenced in the licensee submittal.

Unit 2 Technical Specification Chanae Chance 1: Section 3.1.3.5, Page 3/41-8, " Control Rod Scram Accumulators."

The ACTION statement is revised to include a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> as ACTION (c).

_9_

Chance 2: Section 3.1.4.3, Page 3/41-17, " Rod Blotk Monitor." The applicable ACTIONS are revised to include a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> as ACTION (c).

Chance 3: Section 3.3.1, Pages 3/4 3-1, 3/4 3-5, and 3/4 3-5a, " Reactor Protection Instrumentation." ACTION (c) is replaced with an ACTION that includes a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The present ACTION (c) is relabelled as ACTION (d).

Editorial changes are also proposed for RPS surveillance requirements. Table 3.3.3-1 Note (a) is deleted as the surveillance A0T is now located within the ACTION statement.

Chance 4:

Section 3.3.2, Pages 3/4 3-9 and 3/4 3-9a, " Isolation' Actuation Instrumentation." ACTION (b) is replaced with an ACTION statement that includes a maintenance A0T of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. ACTION (d) is revised to include a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The present ACTION (d) is relabelled as ACTION (e).

Chance 5: Table 3.3.2-1, Pages 3/4 3-15, 3/4 3-21, 3/4 3-22, and 3/4 3-23

" Isolation Actuation Instrumentation." Note (b) is deleted and relocated to the applicable actions. Table 4.3.2-1 channel functional test requirements are revised from monthly to quarterly as referenced in the licensee submittal.

The channel check requirements for Functional Unit 1, Item (c) " Main Steam Line Radiation High," Item (g) "Drywell Radiation High," Functional Unit 2, Item (a) " Reactor Building Exhaust Radiation," and Item (d) " Refueling Floor Exhaast Radiation - High" and Functional Unit 3, Item (a) " Delta Flow High" are revised from once per day to once per shift.

Chance 6: Section 3.3.3, Pages 3/4 3-24, 3/4 3-31, and 3/4 3-32, " Emergency Core Cooling System Actuation Instrumentation." Revise ACTION (b) to include a maintenance A0T of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Replace ACTION (d) with an ACTION statement that includes a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The existing ACTION (d) is relabelled as ACTION-(e). Table 4.3.3-1 channel functional test requirements are revised from monthly to quarterly as referenced in the licensee submittal.

Chance 7:

Section 3.3.4, Pages 3/4 3-33, 3/4 3-34, and 3/4 3-36, " Reactor Core Isolation Cooling System Actuation Instrumentation." Revise ACTION (b) to include a maintenance A0T of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. A surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is also provided as a new ACTION (d). Table 4.3.4-1, " Reactor Core Isolation Cooling System Actuation Instrumentation Surveillance Requirements," channel functional test requirements are revised from monthly to quarterly as referenced in the licensee submittal. An editorial change to note-(a) is also included (Table 3.3.4-1).

Chance 8: Section 3.3.5, Pages 3/4 3-37, 3/4 3-38, 3/4 3-39, and 3/4 3-41,

" Control Rod Withdrawal block Instrumentation." ACTION (c) is replaced with a new ACTION (c) that provides a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The present ACTION (c) is relabelled as-(d). Table 3.3.5-1, Pages 3/4 3-38 and 3/4 3-39,

" Control Rod Withdrawal Block Instrumentation" is revised to include note (g) which prohibits rod withdrawal during channel functional testing / channel calibration (scram discharge volume). Table 4.3.5-1 functional test requirement for APRM downscale is revised from monthly to quarterly as referenced in the licensee submittal.

Chance 9: Section 3.3.6.1, Page 3/4 3-43, " Radiation Monitoring Instrumentation." ACTION (c) is revised to include a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The existing ACTION (c) is relabelled as (d).

i Chance 10:

3.3.6.2, Page 3/4 3-47, " Seismic Monitoring Instrumentation."

ACTION (b) is revised to include a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The existing ACTION (b) is relabelled as (c).

Chance 11:

Section 3.3.6.3, Pay 3/4 3-50, " Remote Shutdown Monitoring Instrumentation." ACTION (t) is re'ised to include a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The existing ACTION (bi is elabelled as (c).

Chance 12: Section 3.3.6.4, Pages 3/4 3-53 and 3/4 3-54, " Post-Accident Monitoring Instrumentation." ACTION (b) is revised to include a surveillance i

A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The existing ACTION (b) is relabelled as (c). An editorial change to Table 3.3.6.4-1 is also included.

Chance 13: Section 3.3.6.5, Pages 3/4 3-56 and 3/4 3-56a, " Source Range Mcnitors." Add ACTION (c) to provide for a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Chance 14: Section 3.3.6.7, Pages 3/4 5-58, 3/4 5-58b and 3/4 5-5Sd, " Main Control Room Environmental Control System (MCRECS) Actuation Instrumentation."

Add ACTION (b) to provide a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. With the surveillance A0Ts moved to the action statement note (a) to Table 3.3.6.7-1 is no longer required and is deleted.

Revise note (b) to Table 3.3.6.7-1 to provide a maintenance A0T of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Table 4.3.6.7-1 channel functional test requirements are revised from monthly to quarterly as referenced in the licensee submittal.

Chance 15: Section 3.3.6.9, Page 3/4 3-60a, " Radioactive Liquid Effluent Instrumentation." ACTION (c) is revised to include a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The existing ACTION {c) is relabelled as (d).

Chance 16: Section 3.3.6.10, Page 3/4 3-60f, " Radioactive Gaseous Effluent Instrumentation." ACTION (c) is revised to include a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The existing ACTION (c) is relabelled (d).

Chance 17: Section 3.3.8, Page 3/4 3-63, Degraded Station Voltage Protection Instrumentation." Add an' ACTION (b) to provide a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

s Chance 18: Section 3.3.9.1, Pages 3/4 3-66, 3/4 3-66a, ar.d 3/4 3-69,

" Recirculation Pump Trip Actuation Instrumentation, ATWS Recirculation Pump Trip System Instrumentation." Revise ACTIONS (b) and (c.1) to provide a maintenance A0T of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Add a new ACTION (f) that provides a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Table 4.3.9.1-1 channel functional test requirements are revised from monthly to quarterly as referenced by the licensee submittal.

Chance 19: Section 3.3.9.2, Pages 3/4 3-70, 3/4 3-72, and 3/4 3-75, "End-0f-Cycle Recirculation Pump Trip System Instrumentation." Revise ACTIONS (b) and (c.1) to provide a maintenance A0T of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Add a new ACTION (f) that provides a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Table 3.3.9.2-1 note (a) which

! provides for a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> surveillance A0T is deleted. ' Table 4.3.9.2.1-1 functional test requirements are revised from monthly to quarterly as referenced in the licensee submittal.

Chance 20: Section 3.4.2.1, Page 3/4 4-4, " Safety / Relief Valves." Add a new ACTION (g) that provides a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Revise Section 4.4.2.1, (tail pipe pressure switches) channel functional test requirements from monthly to quarterly for functional unit (a) Items 1 and 2.

Chance 21: Section 3.4.2.2, Page 3/4 4-4a, " Safety / Relief Valves low-Low Set Function." Add a new ACTION (c) that provides a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Revise Section 4.4.2.2 (low-low set relief valve) channel functional test requirements from monthly to quarterly as referenced in the licensee submittal.

Chance 22: Section 3.4.3.1, Page 3/4 4-5, " Reactor Coolant System Leakage."

Add a new ACTION (d) that provides a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Chanae 23:

Section 3.5.3.1, Page 3/4 5-4, " Low Pressure Core Cooling Systems." Add a new ACTION (3) that provides a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Chanae 24:

Section 3.5.4, Page 3/4 5-10, " Suppression Chamber." Add a new ACTION (e) that provides a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Chance 25: Section 3.6.2.1, Page 3/4 6-12, "Depressurization Systems Suppression Chamber." Add a new ACTION (h) that provides a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Chanae 26: Section 3.9.2, Page 3/4 9-3, " Refueling Operations Instrumentation." Add a new ACTION (b) that provides a surveillance A0T of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Chance 27: Section 3/4.3.1, Page B 3/4 3-1, " Bases, Reactor Protection System Instrumentation." Editorial changes are proposed for the Bases section allowing for the maintenance and surveillance A0Ts as referenced in the licensee submittal.

In general, the Standard Technical Specifications (STS) allow a channel / instrument to bc inoperable for a short period of time in order to perform surveillance testing. This may be accomplished by a test A0T or an appropriate action statement /LCO. The existing Hatch Units 1 and 2 TS do not provide complete allowable out-of-service times for the testing of ECCS or Isolation Actuation Instrumentation. To improve the A0T consistency between both units, the licensee proposed the addition of surveillance A0Ts for the affected instrumentation in each unit. Additionally, the licensee elected to incorporate TS A0T revisions as approved by the referenced General Electric (GE) Topical reports. These topical reports include extended A0Ts for both repair and testing and the adoption of quarterly surveillance intervals for RPS, ECCS, Isolation Actuation Instrumentation, and additional related instrumentation. The TS revisions proposed by the licensee are consistent with the GE topical reports and are acceptable to the staff.

' The licensee also proposed test A0Ts for instrumentation not specifically referenced in the GE topical reports or the STS. The staff reviewed the action statements associated with these changes and determined that the incorporation of a test A0T provides an adequate amount of time to perform the surveillance. The addition of A0Ts for this instrumentation also provides consistency with associated ECCS, RPS, and Isolation Actuation Instrumentation and generally limits the out-of-service time for surveillance testing.

The staff also expressed concern that the model TS ACTION could be interpreted to permit a loss of functional capability for the extended A0T repair interval specified in the GE topical reports (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />). The owners group and GE agreed with the staff that the assumptions of the topical report ' analysis (NEDC-30851P-A) did not support the model TS Action.

However, the licensee, by letter dated February 17, 1993, committed to implement formal administrative controls to ensure that operation with a loss of trip, isolation, or actuation instrumentation functional capability is not permitted during a 12-hour allowed out-of-service time (A0T for repair). The proposed administrative controls also commit to take corrective actions within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> should such a condition be discovered. Additionally, Hatch Unit 2 is the lead plant for conversion to the Improved Standard Technical Specifications. Once implemented at Hatch, the ISTS will resolve the TS loss of function issue for extended A0Ts for both units.

Based on the above, the staff finds the implementation of administrative controls to control the i

extended repair A0Ts included with the referenced GE topical reports to be acceptable.

Based on our review, the staff finds the proposed amendments to incorporate revised A0Ts, based on the referenced GE topical reports, STS referenced A0Ts, and additional surveillance test A0Ts to be acceptable.

3.0 STATE CONSULTATION

i In accordance with the Commission's regulations, the Georgia State official was notified of the proposed issuance of the amendments. The State official had no comments.

4.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the installation or use_ of facility components located within the restricted area as defined in 10 CFR l

Part 20 and change surveillance requirements.

The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (57 FR 13131 dated April 15,1992). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

y.

E :

5.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: C. Doutt Date: April 30, 1993 I

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References 1.

NEDC-31677P-A, " Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation" dated July 1990.

2.

NEDC-30936P-A, "BWR Owners' Group Technical Specification Improvement Methodology (With Demonstration for BWR ECCS Actuation Instrumentation)

Part 1," dated December 1988.

3.

NEDC-30936P-A, "BWR Owners' Group Technical Specification Improvement Methodology (With Demonstration for BWR ECCS Actuation Instrumentation),"

Part 2, dated December 1988.

4.

NEDC-30851P-A, " Technical Specification Improvement Analyses for BWR Reactor Protection System," dated March 1988.

5.

NEDC-30851P-A, Supplement 1, " Technical Specification Improvement Analyses for BhR Control Rod Block Instrumentation," dated October 1988.

6.

NEDC-30851P-A, Supplement 2, " Technical Specification Improvement Analyses for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation," dated March 1989.

7.

GENE-770-06-1, " Bases for Changes to Surveillance Test Intervals and Allowed Out-Of-Service Times for Selected Instrumentation Technical Specifications," dated February 1991.

8.

GENE-770-06-2, " Addendum to Bases for Changes to Surveillance Test Intervals and Allowed Out-0f-Service Times for Selected Instrumentation Technical Specifications." (BWR RCIC Instrumentation), dated February 1991.

9.

Letter, dated July 26, 1991, from C. E. Rossi (NRC) to G. J. Beck (BWROG), "BWR owners group (BWROG) topical reports on Technical Specification improvement analysis for BWR reactor protection systems -

use for relay and solid state plants (NEDC-30884 and NEDC-30852P)."

10.

Letter, dated November 4, 1992, from C. L. Tully (BWR0G) to Brian K.

Grimes (NRC), "BWR owners group (BWROG) topical reports on Technical.

Specification improvement analysis for BWR reactor protection systems -

use for relay and solid state plants (NEDC-30884 and NEDC-30852P)."

-.