ML20082E594

Revised Application to Amend License NPF-5,replacing RCPB Piping.Submittal Clarifies 831121 Amend Proposal & Amplifies Basis for Determination of No Involvement of Significant Hazard

ML20082E594
Person / Time
Site:	Hatch
Issue date:	11/23/1983
From:	Head G GEORGIA POWER CO.
To:	Stolz J Office of Nuclear Reactor Regulation
References
NED-83-588, TAC-52483, NUDOCS 8311280249
Download: ML20082E594 (7)

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NED-83-588 November 23, 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 OPERATING LICENSE NPF-5 EDWIN I. IIATCH NUCLEAR PLANT UNIT 2 RFVISION TO '3fE PROPOSED LICENSE AMENDMENT FOR RFAC'IDR COOLANT PRFSSURE BOUNDARY PIPING REPIACBiBT Gentlemen:

Georgia Power Company (GPC) submitted to the NRC by letter dated November 21, 1983, a proposed license amendment for supplemental license conditions to be in effect during the replacement of Plant Hatch Unit 2 recirculation system and certain attached piping. GPC hereby withdraws that submittal and proffers the attached proposed license amendment. This letter with its enclosures supersedes in toto our November 21 , 1983 letter NED-83-553. This action is taken to clarify our proposal and amplify upon our basis for our determination of "no involvement of a significant hazard" performed in accordance with 10 CFR 50.92.

GPC notified the NRC by letter dated October 5,1983, that due to the presence of flaws, we plan to replace the Plant Hatch Unit 2 recirculation system piping and certain attached piping. The replacement is to be perfonned in an outage commencing in early January 1984.

GPC is in the process of reviewing the various aspects of the piping replacement project for possible unreviewed safety questions as defined in 10 CFR 50.59. At this time, no unreviewed safety questions have been identified.

Discussions with NRC staff have led GPC to conclude that an amendment to the Hatch Unit 2 operating license may be required regardless of the results of our safety evaluations. We further understand that the NRC staff is developing guidelines for application by boiling water reactor owners who are contemplating the replacement of piping in determining whether or not a license amendment is required.

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Georgia Powerkn Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, 011ef Operating Reactors Branch No. 4 November 23, 1983 Page Two GPC has entered into certain commitments regarding this project to replace piping, such that our resources are targeted toward reactor shutdown occurring on January 6, 1984. Various contracts and the mobilization and training of many workers are involved. Further, long-term plans for the operation of our statewide electrical system are based on work commencing at that time.

We realize that the licensing process can significantly impact our plans and, due to this uncertainty in the licensing process, GPC has decided to request the enclosed proposed license amendment. Should our final 10 CFR 50.59 evaluation and the NRC staff's guidelines conclude that a license amendment is not needed, we would, of course, withdraw this request for amendment.

In order to ensure our ability to proceed with our planned shutdown on January 6,1984, we feel this action is necessary. Vario"s conversations with Mr. Ilarold Denton, including our meeting with him and tne NRC staff on October 11, 1983, give assurance that the NRC staff will grant high priority toward implementing these actions. We again would like to request your support. An interdisciplinary project organization has been established within GPC to enable us to manage and apply our best resources in this effort. If you require further information, please contact this office.

Accordingly, included herein as Enclosure 1 is a proposed license amendment. Pursuant to the requirements of 10 CFR 50.92, J. L. Irdbetter of the Georgia Department of liiman Resources will be sent a copy of this letter and all applicable attachments.

The proposed amendment to the Operating License has been reviewed and approved by the Plant Review Board and the Safety Review Board. The proposed amendment has received preliminary evaluation and has been determined not to involve significant hazards considerations. This l evaluation is documented in Enclosure 2.

Georgia Power d Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Gief Operating Reactors Branch No. 4 November 23, 1983 Page 'Ihree As discussed in Enclosure 3, the proposed amendment to the Hatch Unit 2 Operating License has been evaluated to be a single Class III amendment.

Our check no 966488 dated November 4,1983, for $4,000.00 was enclosed in our November 21, 1983 letter (NED-83-553). Please apply that payment to the review of this proposal.

G. F. Head states that he is Senior 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 are true.

GEORGIA POWER COMPANY By: $ }. /

' G. F. Head Sworn to and subscribed before me this 23rd day of November, 1983.

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Notary Rblic, Cecrga, State at LarNotary Public JAE/mb My Commission Expires Aug.25,1986 Enclosures xc: J. T. Beckham, Jr.

H. C. Nix, Jr.

L. T. Gucwa Senior Resident Inspector

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

J. L. Ledbetter

Georgia Power d ENCLOSURE 1 NFC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATOi NUCLFAR PLANT UNIT 2 PROPOSED LICENSE AMENINENT FOR REAC'IDR COOLANT PRESSURE BOUNDARY PIPING REPLACIMENT ne proposed amendment to the Operating License would add a new section 2.C(3)(g) as follows:

(g) Recirculation System Piping Replacement:

During the replacement of the recirculation piping, Georgia Power Company shall be subject to the following conditions:

(i) He licensee shall complete the recirculation piping stress analysis prior to restart of Fdwin I. Hatch Nuclear Plant -

Unit 2. The results of this analysis shall be submitted to the NRC prior to restart of the facility.

(ii) All fuel shall be removed from the reactor pressure vessel and stored in the spent fuel pool during the period that work on the recirculation system replacement project is in progress.

(iii) ne licensee shall provide an estimate of the anticipated man-rem exposure by major task prior to initiation of the recirculatior, system piping replacement project.

(iv) Progress reports shall be provided at 90-day intervals from January 1, 1984 (or the actual date of shutdown for the replacement work) and due 30 days after the close of the interval, with a final report within 60 days after completion

! of repair. %ese reports shall include:

1. A summary of the occupational dose received to date by major task, and

2. A comparison of the actual doses to the dose estimates.

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Georgia Power d ENCLOSURE 2 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 PROPOSED LICENSE AhENEMENT FOR REACTOR COOLANT PRESSURE BOUNDARY PIPING REPLACISENT Pursuant to 10 CFR 50.92, Georgia Power Company (GPC) has evaluated the attached proposed amendment to the Operating License for Hatch Unit 2 and has detennined that its adoption would not involve a significant hazard.

W e basis for this determination is as follows:

PROPOSED CHANGE Add a new section 2.C (3)(g) to the Hatch Unit 2 Operating License such that GPC is subject to certain conditions while replacing the recirculation system piping. The conditions include completion of piping stress analysis and submittal thereof to NRC prior to unit restart, removal of all fuel from the reactor pressure vessel during piping replacement, providing an estimate of the anticipated man-rem exposure by major task prior to initiation of replacement, and submittal of progress reports at certain intervals during the course of the replacement work.

BASIS

%e proposed change has been reviewed pursuant to the criteria of 10 CFR 50.92, paragraph (c). The following is a summary analysis of the review:

(1) The proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated because the work to be performed will be accomplished with the reactor totally defueled. Those systems required for the safe cooling of the spent fuel in the spent fuel pool and those systems and components required to maintain separation from the operating unit (HNP Unit-1) will be maintained fully OPERABLE as defined in the Plant Hatch Technical Specifications.

(2) He proposed amendment will not create the possibility of a new or different kind of accident from any accident previously evaluated because the work will be accomplished with the fuel removed frce the reactor. W e comments on item (1) above also apply.

(3) The proposed amendment will not involve a significant reduction in a margin of safety. He safety margins in the analyses of the mitigation of nuclear accidents will be unaffec ted by the replacement work as the accident mitigation systems associated with accidents in the spent fuel pool will remain OPERABLE.

Georgia Power d ENCLOSURE 2 (continued)

Page 2 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 PROPOSED LICENSE AMENDMENT FOR REACTOR COOLANT PRE 55URE BOUNDARY PIPING REFLACDENT The institution of a special ALARA program for the replacement work will serve to ensure that radiation exposures remain ALARA during the piping replacement. Thus, the radiation exposures will be adequately controlled and will not constitute a reduction in a margin of safety.

The proposed change will add new restrictions to the licensee for the duration of the piping replacement work. These added restrictions will assure that the NRC is fully informed concerning piping stresses and radiation exposures on the replacement job. The proposed change does not affect the probability or consequences of an accident or malfunction analyzed in the FSAR. The proposed change does not create the possiblility of an accident or malfunction of a different type than analyzed in the FSAR. The margin of safety as defined in the basis for any Technical Specification is not affected. Inasmuch as the amendment constitutes an additional limitation and reporting requirement not presently in the Operating License or Technical Specifications, the aroposed change is within the acceptance criteria and consistent with Item Kii) of the " Examples of Amendments That Are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14870 of the April 6, 1983 issue of the Federal Register.

ENCLOSURE 3 Georgia Power4n NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 PROPOSED LICENSE AMENDhENT FOR REAC10P, COOLANT PRESSURE BOUNDARY PIPING REPIACIMENT Ptrsuant to 10 CFR 170.22 (c), Georgia Power Company has evaluated the attached proposed amendment to Operating License n'.'F-5 and has detemined that:

a. The proposed amendment does not require evaluation of a new Safety Analysis Report and rewrite of the facility license;

b. The proposed amendment does not require evaluation of several complex issues, involve ACRS review, or require an environmental impact statement;

c. The proposed amendment involves one safety issue, namely, adding new restrictions to the licensee for the duration of the recirculation system piping replacement work to assure that the NRC is fully informed concerning pipe stresses and radiation exposures on the replacement job;

d. The proposed change to Operating License NPF-5 is therefore a Class III amendment.

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