ML20076E967

Application for Amend to License NPF-5,proposing Addl Tech Spec Surveillance Requirements for High Reactor Water Level Trip Function & Main Turbine Bypass Valves

ML20076E967
Person / Time
Site:	Hatch
Issue date:	05/26/1983
From:	Beckham J GEORGIA POWER CO.
To:	Stolz J Office of Nuclear Reactor Regulation
Shared Package
ML20076E970	List: ML20076E967 ML20076E981
References
NED-83-303, TAC-49989, TAC-51054, TAC-52103, NUDOCS 8306010367
Download: ML20076E967 (3)

Text

. Georgia Power Company _

333 Piedenont Averue Atlanta. Gecrg c 30305 Telephone 404 526 7020 Maihng Address-Post Omce Bcs 4545 Atianta, Georg.a 30302 Georgia Power J. T. Beckham, Jr. IT Wit'em etcnc system Vce Presdent and General Varager Nuclear Generaton NED-83-303 May 26, 1983 Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555 NRC DOCKET 50-366 OPERATIm LICENSE PPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 RESPONSE TO REQUEST FOR TECHNICAL SPECIFICATIONS Gentlemen:

Georgia Power Company (GPC) has received your letter of May 12, 1983, which requests that Georgia Power Company submit additional Technical Specifications prior to restart of Plant Hatch Unit 2 from the current refueling outage. Consequently, GPC amends its submittal of March 30, 1983, to include the attached Technical Specifications which propose additional t surveillance requirements on the high reactor water level trip function (i.e., for main turbine and feedwater turbines) and which specify surveillance testing of the main turbine bypass valves.

GPC does not agree with the conclusion presented in your letter of May 12, 1983, regarding the need for additional Technical Specifications. More importantly, we are concerned over the issuance of this letter by the NRC staff for two reasons: 1) the sense of urgency implied by attaching this requirement to our cycle 4 reload and formally informing GPC of the request only 17 days before the originally scheduled startup date is not supported by an appropriate technical basis; 2) the NRC staff is apparently avoiding the established generic issues review process by withholding reload licenses on a plant-by-plant basis until additional Technical Specifications are backfitted when the stated issue is an obvious generic concern.

First, we want to point out that the issues involved have been the subject of several conversations between GPC licensing personnel, the NRC Hatch Licensing Project Manager, and other NRC staff personnel. These conversations have occurred over a period of several months, and actually began during the latter part of the previous operating cycle. At that time we stated our position that the NRC proposed requirements were more appropriately discussed in a generic review since their implementation was being imposed generically and since the proposal was in variance with I

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1 Georgia Power d Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 May 26, 1983 Page Two accepted licensing bases. At that time we also requested that the NRC transmit the request to GPC in writing, so that a forum for discussion of the technical merit of the request could be established. A letter was not issued by the NRC, and Unit 2 continued to the end of cycle 3 operation and into the current refueling / maintenance outage.

Second, only 17 days prior to the originally scheduled startup date for cycle 4 operation, the NRC finally chose to issue the request with the additional arbitrary requirement that it be resolved prior to unit startup.

GPC objects to being informed at such a late date that the reload license will be withheld until the requested Technical Specifications are accepted by GPC. Furthermore, the technical questions involved relate to pressurization transients which historically are not limiting at beginning of cycle operation. Clearly, in light of GPC's objections to its substance, the requirement to resolve this request prior to restart and without adequate time for GPC and NRC to mutually and fully discuss the issues is inappropriate.

Third, the procedure being followed by the NRC avoids the established generic issues review process. It is inappropriate to impose backfits lacking a finding of need for substantial additional public protection. The NRC staff conclusion expressed in the May 12, 1983, letter clearly rejects i the assumptions previously accepted by NRC as stated in General Electric's Generic Reload Fuel Application licensing report (EDE-240ll-P). As such, this is an issue that should be addressed by the Committee to Review Generic Requirements (CRGR) so that the nuclear industry can comment on the staff conclusions. However, we understand that these requirements have previously been imposed on at least one other operating nuclear unit during a refueling outage and on two near term operating license (NTOL) units as they approached receipt of an operating license. The staff is apparently masking generic requirements as plant-specific modifications and issuing them without the formal analysis required by the Commission. By applying this requirement on a plant-by-plant basis as a particular nuclear plant is placed in a vulnerable position, a commitment can be easily extracted due to the threat of non-approval of a reload licensing package or an operating license. GPC objects to this procedure.

GPC is ready to discuss with the staff the reasons why additional Technical Specifications are not required. However, that issue should be properly dealt with by referring the subject to the CRGR. We propose a meeting in the near future (possibly June 1983) of representatives from the NRC, GE licensing, and GPC licensing staffs to discuss the issues expressed in this letter as well as the technical merits of the proposed specifications.

700775

Georgia Power d Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 May 26, 1983 Page Three In the meantime, GPC proposes additional Technical Specifications in compliance with your request. The Plant Review Board and Safety Review Board have reviewed these changes and have determined that the implementation of these changes does not constitute an unreviewed safety question because these changes merely establish LCOs and codify surveillances on equipment and/or systems that were previously being serviced by plant maintenance and surveillance procedures. Since there is no change to the plant and only a codifying of surveillances, the probability of occurrence and the consequences of an accident or malfunction of equipment important to safety are not icreased above those analyzed in the FSAR. The possibility of an accident or malfunction of a different type than analyzed in the FSAR does not result, nor is the margin of safety as defined in Technical Specifications reduced due to implementation of these changes. Because we desire to resolve the technical issues regarding this submittal, we request that these Technical Specifications be made applicable to cycle 4 operation only, pending resolution of this subject.

The proposed Technical Specifications have been determined to be an amendment, as requested, to a previous submittal. As such, no fee is required.

J. T. Beckham, Jr. states that he is Vice President of Georgia Fower 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 are true.

GEORGIA POWER COWANY By: /._

J. T. Beckham, Jr.

Swor to and subscri befor me this 26th day of May, 1983.

d/ Notary Pubhc, Georgia, State at Large gL , M _ ; My Commission Expires Sept. 20.1983 Notary Public T/mb Enclosure xc: J. T. Beckham, Jr.

H. C. Nix, Jr.

J. P. O'Reilly (NRC- Region II)

Senior Resident Inspector V. Stello J. R. Tourtellotte 700775

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