ML20064C718

Application for Amends to Licenses NPF-68 & NPF-81, Reinstating Exception 3.0.4 for TS 3.2.4, Quadrant Power Tilt Ratio,

ML20064C718
Person / Time
Site:	Vogtle
Issue date:	03/01/1994
From:	Mccoy C GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20064C722	List: ML20064C718 ML20064C724
References
LCV-0282, LCV-282, NUDOCS 9403100182
Download: ML20064C718 (7)

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Georga Power Company 40 invemess CenWr Parkway

, Post oSce Bon 1295 Birrrangham Abbama 35201 Tetephone 205 877 7122 liarch 1,1994 .

m C. K. McCoy Georgia Power vce Pm9 dent Nudcar .

Vogde Progt . ge MWrn ehtoc system LCV4282 Docket Nos. 50-424 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen:

VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNICAL SPECIFICATIONS REINSTATEMENT OF EXCEPTION TO 3.0.4 FOR SPECIFICATION 3.2.4 In accordance with the provisions of 10 CFR 50.90 and 10 CFR 50.59, Georgia Power Company (GPC) hereby proposes to amend the Vogtle Electric Generating Plant (VEGP)

Unit 1 and Unit 2 Technical Specifications, Appendix A to Operating Licenses NPF-68 and NPF-81.

The proposed revision will add an exception to the requirements of specification 3.0.4 for specification 3.2.4, quadrant power tilt ratio. This exception was part of the original Technical Specifications. Georgia Power Company requested that it be removed in conjunction with the revised wording of specification 3.0.4 based on NRC Generic Letter 87-09, which allows entry into an operational mode,or other specified condition, in compliance with the action requirements when conformance permits continued operation for an unlimited period of time. The action requirements for specification 3.2.4 allow continued operation at a power level above 50 percent power for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, aller which power is to be reduced to less than 50 percent if the quadrant power tilt ratio (QPTR) is not restored to within its limit. Specification 3.2.4 does not apply below 50 percent power.

In the case of specification 3.2.4, the revised wording of specification 3.0.4 prohibits raising power above 50 percent and entering the action statement if the QPTR has been determined to be out oflimit prior to exceeding 50 percent power. This has resulted in delays in returning to full power operation following a reactor shutdown.

Georgia Power Company requests that this change be approved by May 1,1994.

The proposed change and the basis for the change is described in enclosure I to this letter.

Enclosure 2 provides an evaluation pursuant to 10 CFR 50.92 showing that the proposed change does not involve significant hazards considerations. Instructions for incorporation n rs n 4 co n 9403100182 940301 4 DR ADOCK 0500 i

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Georgia Powe'r1 U. S. Nuclear Regulatory Commission Page 2 of the proposed change into the Technical Specifications and a copy of the change are provided in enclosure 3.

In accordance with 10 CFR 50.91, the designated state official will be sent 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.

l GEORGIA POWER COMPANY By: k C. K. Mc oy Sworn to and subscribed before me this[$_ ay of vbik ,1994.

IlSh 7), b d blv, Notarypublic g l #'E W 4; g

Enclosures:

1. Basis for Proposed Change

2. 10 CFR 50.92 Evaluation

3. Instructions for Incorporation and Revised Pages c(w): Georgi.g Power Company Mr. J. B. Beasley, Jr.

Mr. M. Sheibani NORMS U. S. Nuclear Regulatory Commission Mr. S. D. Ebneter, Regional Administrator Mr. D. S. Hood, Licensing Project Manager, NRR Mr. B. R. Bonser, Senior Resident Inspector, Vogtle State of Georgia l Mr. J. D. Tanner, Commissioner, Dept. of Natural Resources kv-0282 7[0775

ENCLOSURE 1

. VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNICAL SPECIFICATIONS REINSTATEMENT OF EXCEPTION TO 3.0.4 FOR SPECIFICATION 3.2.4 BASIS FOR PROPOSED CHANGE 1

Proposed Change Add action statement "d" to specification 3.2.4 along with the following statement, " The provisions of specification 3.0.4 are not applicable."

A Ilasis The original issue of the Vogtle Electric Generating Plant Technical Specifications contained an exception to the provisions of specification 3.0.4 in the action requirements for specification 3.2.4. At that time, specification 3.0.4 simply prohibited entry into an operational mode when the limiting condition for operation (LCO) could not be met without reliance on the action requirements. Generic letter 87-09 proposed a change to specification 3.0.4 to allow entry into an operational mode, or other specified condition, when compliance with the LCO relies on an action statement if the action statement permits continued operation for an unlimited period of time. In 1992, GPC proposed to amend the VEGP Technical Specifications to incorporate the revised wording of 3

specification 3.0.4 as proposed by the Generic Letter. The new wording of specification 3.0.4 appeared to allow power to be raised above 50 percent when the quadrant power tilt ratio (QPTR) was greater than 1.02 because the action statement allowed continued operation for an unlimited period of time at reduced power. Therefore, the exception to specification 3.0.4 was removed with the implementation of the revised wording of the specification. The LCO for specification 3.2.4 is only applicable in mode 1 above 50 percent power. The action statement only allows operation above 50 percent power for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, after which time, it must be reduced to below 50 percent if the QPTR is not restored to within its limit. Since the action statement ultimately requires a change in plant i operating conditions that puts it outside the applicability requirements of the specification, the revised wording of specification 3.0.4 prohibits raising power above 50 percent and entering the action statement if the QPTR has been determined to be out oflimit prior to exceeding 50 percent power.

During startup, it is common for the QPTR to exceed 1.02 at low power levels. As power increases, the QPTR gradually lowers. This situation has resulted in a number

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ENCLOSURE 1 (CONTINUED)

VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNICAL SPECIFICATIONS j REINSTATEMENT OF EXCEPTION TO 3.0.4 FOR SPECIFICATION 3.2.4 BASIS FOR PROPOSED CHANGE of delays in power ascension as a result ofhaving to wait, at a power leveljust under 50 percent, for QPTR to lower below 1.02 before entering the operational conditions where the action requirements of specification 3.2.4 are applicable. By reinstating the exception to specification 3.0.4, power ascension can continue while the LCO is being met in '

accordance with the action statements. The higher power level and time limits allowed by the action statement are sufficient to assure that the QPTR will stabilize without resulting in a requirement to reduce power to a value outside the applicability of the specification.

The margin of safety inherently provided by the technical specification will not be affected since the limitations of the action statement will continue to be met.

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4 ENCLOSURE 2 J

VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNICAL SPECIFICATIONS REINSTATEMENT OF EXCEPTION TO 3.0.4 FOR SPECIFICATION 3.2.4 10 CFR 50.92 EVALUATION Pursuant to 10 CFR 50.92, Georgia Power Company (GPC) has evaluated the proposed revision to the Technical Specifications and has determined that operation of the facility in j accordance with the proposed amendment would not involve any significant hazards considerations. I

Background

Limiting condition for operation (LCO) 3.2.4 requires that power operation be reduced 3 percent for each I percent of quadrant power tilt ratio (QPTR) in excess of 1.00 when the QPTR is greater than 1.02. If the QPTR has not been returned to within its limit i within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the action statement allows continued operation only at power levels below 50 percent power. The 24-hour period allows time for correcting the QPTR by operator action or by stabilization as a result of additional burnup. Specification 3.0.4 l does not allow operation above 50 percent power when the plant is being started up unless i the QPTR is already within its limit. By including an exception to specification 3.0.4 in the Vogtle Electric Generating Plant (VEGP) Technical Specifications similar to the one j contained in the original specifications and those of plants of the same design, unnecessary delays in plant startup can be eliminated.

Analysis 4

The QPTR limit assures that the gross radial power distribution remains consistent with

. the design values used in the safety analyses. When the QPTR is greater than 1.02, the 4

power reduction of 3% for each percent of QPTR in excess of 1.00 is a conservative tradeoffof total core power with peak linear power, thus, assuring continued operation in l accordance with the safety analyses. The reinstatement of the exception to specification l 3.0.4 will not result in operation in conditions that are different than those already allowed by the specifications; therefore, the margin of safety provided by the technical specification will not be affected by this change.

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l . ENCLOSURE 2 (CONTINUED) j- VOGTLE ELECTRIC GENERATING PLANT '

l i REQUEST TO REVISE TECHNICAL SPECIFICATIONS

. REINSTATEMENT OF EXCEPTION TO 3.0.4 FOR SPECIFICATION 3.2.4 l 10 CFR 50.92 EVALUATION l l

l l Conclusion j Based on the above considerations, GPC has concluded the following concerning 10 CFR 50.92. >

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1. The proposed change to the Technical Specifications does not involve a significant increase in the probability or consequences of an accident previously evaluated

! because it does not allow operation in a condition that is not already allowed by the

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) 2. The proposed change to the Technical Specifications does not create the possibility of j a new or different kind of accident from any accident previously evaluated because it will not allow operation under conditions different from those already allowed by the l technical specifications.

j 3. The proposed addition to the Technical Specifications does not involve a significant reduction in the margin of safety because the action requirements will continue to be met in the same manner as currently required by the Technical Specifications.

Based upon the preceding information, it has been determined that the proposed Technical j Specifications addition does not involve a significant hazards consideration as defined by j 10 CFR 50.92.

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ENCLOSURE 3

. VOGTLE ELECTRIC GENERATING PLANT l REQUEST TO REVISE TECHNICAL SPECIFICATIONS

• REINSTATEMENT OF EXCEPTION TO 3.0.4 FOR SPECIFICATION 3.2.4

INSTRUCTIONS FOR INCORPORATION I

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The proposed change to the Vogtle Electric Generating Plant Technical Specifications i i would be incorporated as follows.

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• Overleafpage contains no changes.

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