ML20082F367

Application for Amend to License NPF-5 to Allow RCPB Piping Replacement During Outage Commencing in Jan 1984.NSHC Determination & Safety Evaluation Encl

ML20082F367
Person / Time
Site:	Hatch
Issue date:	11/21/1983
From:	Head G GEORGIA POWER CO.
To:	Stolz J Office of Nuclear Reactor Regulation
References
NED-83-553, TAC-52483, NUDOCS 8311280530
Download: ML20082F367 (6)

Text

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• 2. Georgia Power Corrpany 333 Pedmcnt Avemue AraWa Georg a 30306 4 TWThone 404 526J8'13:

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Post Ofttee Boa 4545 A:fanta Georg a 30302 G. F. Head Smet V!ce P<cson:

Power GeneraMn NED-83-553 November 21, 1983 Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Orief 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 EIMIN I. HATCH NUCLEAR PLANT UNIT 2 PROPOSED LICENSE AMENBfENT FOR REAC1DR COOLANT PRESSURE BCUNDARY PIPING REPLACBfENT 3

Gentlemen:

, Georgia Power Company (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 performed 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.

Georgia Power Company has entered into certain commitments regarding this project to replace piping, such that our resources are targeted toward l 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.

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Georgia Power A Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, 011ef Operating Reactors Branch No. 4 November 21, 1983

! Page 1 W 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. Various conversations with Mr. Harold Denton, including our meeting with him and the 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 Georgia Power Company 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. Ledbetter of the Georgia Department of Human Resources will be sent a copy of this letter and all applicable attachments.

1he 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 evaluation is documented in Enclosure 2.

Georgia Power 1 Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, 011ef Operating Reactors Branch No. 4 November 21, 1983 Page 'Ihree As discussed in Enclosure 3, the proposed amendment to the Hatch Un.it 2 Operating License .has been evaluated to be a single Class III amendment.

Enclosed as the amendment fee is our check no. 966488 dated November 4, 1983, for $4,000.00.

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 CGfPANY By: $ , f.)

G. F. Head S scribed before me,t 's 21st da f November, 1983.

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Notary Pu U Enclosures-xc:

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J. T. Beckham, Jr.

H. C. Nix, Jr.

i r. L. T. Gucwa Senior Resident Inspector J. P. O'Reilly, (NRC-Region II)

J. L. Ledbetter Notary Pubte, Cecec's,5 tat ts@

My Commiulon upkes A.ly 26 MS

, . . s GeorgiaPowerk ENCLOSURE 1' NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 PROPOSED LICENSE #fEhTMENT FOR RFAC'IOR COO

%e proposed amendment to the Operating License would add a new section 2.C(3)(g) as follows:

(g) Recirculation System Piping Replacement:

Georgia Power Company is authorized to remove the existing recirculation. system piping and replace it with new material subject to the following conditions:

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

Unit 2. He 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) %e - licensee - shall provide an estimate of the anticipated man-rem exposure by. major task prior to initiation of the recirculation 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. Rese 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'Powel I ENCLOSURE 2

' NRC DOCKET 50-366

' OPERATING LICENSE NPF-5 EININ I. HATCH NUCLEAR PLANT UNIT 2 PROPOSED LICENSE: AMENINENT FOR REACTOR COOLANT PRESSURE BOUNDARY PIPING REPLACEMENT 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 determined that ' its adoption would not .' involve a significant hazard.

%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 authorized to remove the existing recirculation system; and replace it with new material subject to certain: conditions. 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 will add new restrictions to the licensee for the duration of- the ' piping replacement work. Lese added restrictions will assure that - the - NRC . is fully informed concerning piping stresses and radiation exposures on the replacement job. %e proposed change does not affect the probability or consequences of an accident or malfunction analyzed'in the FSAR. %e proposed- change does not create the possiblility of an accident or malfunction of a different type than analyzed in the FSAR. We 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 proposed change is within

' the acceptance criteria: and consistent with Item (ii) of the " Examples of Amendments %at Are Considered Not Likely to Involve Significant Hazards Considerations" listed -on page 14870 of the April 6, 1983 issue of the Federal Register.

-4 ENCLOSURE 3 Georgia PowerAn NRC DOCKET 50-366 0 PIRATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 PROPOSED LICENSE AMENINENT FOR REACIDR COOLANT PRESSURE BOUNDARY PIPING REPLACINENT Pursuant to 10 CFR 170.22 (c), Georgia Power Company has evaluated the attached proposed amendment to Operating License NPF-5 and has detemined that:

a. The proposed amendment does not require evaluation of a new Safety An. lysis 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. 'Ihe proposed change to Operating License NPF-5 is therefore a Class III amendment.