ML20083M595

Safety Evaluation Supporting Amends 85 & 63 to Licenses NPF-68 & NPF-81,respectively

ML20083M595
Person / Time
Site:	Vogtle
Issue date:	05/15/1995
From:	Office of Nuclear Reactor Regulation
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ML20083M594	List: ML20083M595
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NUDOCS 9505190339
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$ Clay p

UNITED STATES j

j NUCLEAR REGULATORY COMMISSION t

WASHINGTON, D.C. 20S664001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 85 TO FACILITY OPERATING LICENSE NPF-68 AND AMENDMENT NO. 63 TO FACILITY OPERATING LICENSE NPF-81 GEORGIA "0WER COMPANY. ET AL.

V0GTLE ELECTRIC GENERATING PLANT. UNITS 1 AND'2 DQG ET NOS. 50-424 AND 50-425

1.0 INTRODUCTION

By letter dated March 18, 1994, as supplemented by letters dated February 28 i

and March 17, 1995, Georgia Power Company, et al. (the licensee) proposed license amendments to change the Technical Specifications (TS) for Vogtle i

Electric Generating Plant (Vogtle), Units 1 and 2.

The proposed changes would incorporate Limiting Condition for Operation (LCO) 3.3.3 from NUREG-1431,

" Standard Technical Specifications Westinghouse Plants," dated September 1992, into TS 3/4.3.3.6, Accident Monitoring Instrumentation. The February 28 and March 17, 1995, letters provided clarifying information that did not change the scope of the March 18, 1994, application and initial proposed no significant hazards consideration determination.

Incorporation of the Standard Technical Specifications (STS) LC0 3.3.3 would:

a.

Replace the columns titled " Total No. of Channels" and " Minimum Channels Operable" with a column titled " Required Channels" in TS Table 3.3-8.

b.

Revise the action statements in TS Table 3.3-8 associated with inoperability of instrumentation for the post accident monitoring (PAM) parameters.

The proposed amendment would also delete TS 3/4.6.4.1, revise BASES B 3/4.6.4, and consolidate the operability and surveillance requirements for hydrogen monitors into TS 3/4.3.3.6.

2.0 EVALUATION The purpose of the PAM instrumentation is to display variables that provide information required by the control room operators during accident situations.

This information provides the necessary support for the operator to take the manual actions required for safety systems to accomplish their safety functions for design basis accidents (DBAs). The operability of the PAM instrumentation ensures that sufficient information is available on selected parameters for the operator to monitor and to assess unit status and behavior following an accident. The following evaluation addresses the operability requirements and the associated required actions. The evaluation focuses on the deviations of the proposed changes from the STS.

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.M 2.1. Reauired Channels The licensee proposed a revision to TS Table 3.3-8 using the format presented in STS Table 3.3.3-1 by replacing columns titled " Total No. of Channels" and

" Minimum Channels Operable" with a column titled " Required Channels." LC0 3.3.3 of the STS requires two operable channels for most PAM functions. Two operable channels ensure that no single failure prevents the operator from getting information necessary for determining the safety status of the unit, and bringing the unit to a safe condition following an accident.

Consistent with STS Table 3.3.3-1, the licensee has proposed that two channels for each parameter be provided operable as specified in TS Table 3.3-8, with the exception of reactor coolant system (RCS) temperature T wide d (wide range), steam generator (SG) water level (win r(ange)

RCS T by provi' n,g a direct indication of reactor core temperature, and steamline radiation.

For each of these parameters, the licensee has proposed one channel of instrumentation for operability along with indication of a diverse variable. The core exit thermocouples would serve as a diverse variable for RCS T,,ture, steamline pressure would serve as a diverse variable for RCS T (wide range) by providing a direct indication of reactor core 3

tempera (wide range) by providing indirect indication of thermodynamic conditions,

,,t, auxiliary feedwater flow would serve as a diverse variable for SG water level (wide range) by providing indication of water supply to the SG, and SG level (narrow range) would serve as a diverse variable for steamline radiation by providing indication of possible SG level increase due to a SG tube break.

The staff finds the diverse means for monitoring RCS T,line radiationW e range), E no T,,ge (wide range), SG water level (wide range), and steam acceptable as they provide an appropriate alternative indication of the i

associated safety parameter.

f 2.2 Action Statements The licensee has also proposed changes to the action statements associated with each PAM variable. The staff reviewed the proposed action statements against those of the STS, and found the following deviations.

2.2.1 Orderly Transition The proposed Action Statement 31b states that with two required channels inoperable, restore at least one channel to operable status within 7 days, or be in at least hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The STS recommends that when the required action and associated completion time are not met, be in Mode 3 [ hot standby) within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and be in Mode 4 [ hot shutdown] within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The action statement in the existing TS Table 3.3-8, which the proposed Action Statement 31b replaces, does not have the intermediate transition step of reaching Mode 3 [ hot standby] within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The proposed action statement, without the explicitly stated intermediate transition, is consistent with the current TS action statement and provides for appropriate plant shutdown when equipment is inoperable. The proposed change is therefore, acceptable.

2.2.2 Diverse Indications The action statements proposed for the four PAM variables [RCS T wide radiation) win,on(wide range), SG water level (wide range), and range), RCS T e required channel and a designated diverse channel deviate from the STS. The action statements for these variables in the new proposed TS state that with the required channel inoperable and at least one diverse channel operable for the affected loop, restore the required channel to operable status wjthin 30 days.

If the required channel is not restored to operable status within 30 days, prepare and submit a Special Report to the Commission, pursuant to Specification 6.8.2, within 14 days outlining the actions taken (including the preplanned alternate method of monitoring), the cause of the inoperability, and the plans and schedule for restoring the inoperable channel to operable status.

The above action statements are similar to the action statements in the STS for PAM variables with two required channels where in the event that one channel is inoperable, the STS require the inoperable channel be restored to operable status within 30 days or a special report be submitted to the NRC within the next 14 days which must provide the plan for restoring the inoperable channel to operable status. The licensee takes credit in the new,

TS for the diverse channel in place of the second required channel and follows the action statement for one inoperable required channel. Although the operable diverse channel is not an exact measurement of the primary variable, the operator is still able to derive the necessary information about the primary variable.

Therefore, the action statements for these four PAM variables with the appropriate diverse channel as the second required channel is consistent with the STS and is, acceptable.

In the event that both, the required channel and the diverse channel for the affected loop,are inoperable, the TS would require the diverse indication be restored within 7 days or the unit be shut down, which is commensurate with the required action in the STS for a total loss of indication and is, therefore, acceptable.

2.2.3 Containment Isolation Valve Position Indications The STS requires one position indication per containment isolation valve which is considered one channel and the indication for the other valve on the same containment penetration is considered the second channel.

In the March 18, 1994, submittal, the licensee addresses the action statement for inoperability of individual valve position indication as recommended in the STS. The licensee's action statement did not address the condition when the indication of both containment isolation valves for the same penetration become inoperable. This condition was addressed in item 9 of Table 3.3.3-1 of the STS. When two required channels for the same containment penetration are inoperable, the STS requires the plant to enter into hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when one of the two required channels cannot be restored within 7 days.

_4_

In the February 28, 1995, response to the staff's February 9, 1995, request for additional information, the licensee addressed the action statement required for the condition when the indication of both containment isolation valves for the same penetration becomes inoperable.

TS Table 3.3-8 invokes Action Statement 31b, when two required channels for the same containment penetration are inoperable.

It requires the plant to be in hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when one of two channels cannot be restored within 7 days.

This action statement is consistent with the statement of Table 3.3.3-1 of the STS and is, therefore, acceptable.

In Appendix M of NUREG-1137 Supplement No. 2, " Safety Evaluation Report Related to the Operation of Vogtle Electric Generating Plant, Units 1 an 2,"

dated May 1986, the staff determined that redundant containment isolation valves with single position indication per valve met the Regulatory Guide 1.97, Category 1 criteria. However, the licensee's March 18, 1994, submittal, refers to the containment isolation valve position indication as Category 2 instrumentation.

In the February 28, 1995, response to the staff's February 9,1995, request for additional information, the licensee confirmed that the containment isolation valve position indication meets the Category 1 criteria with the exception of single position indication per valve. The licensee will incorporate a change to the Final Safety Analysis Report update to reflect this as-built condition with respect to containment isolation valve position indication. The staff finds that the licensee's position on containment isolation valve position indication meets the criteria of Regulatory Guide 1.97 and is, therefore, acceptable.

2.3 Hydrocen Monitors In the March 18, 1994, submittal, the licensee proposed deletion of TS 3/4.6.4.1 for hydrogen monitors and consolidation of its operability and surveillance requirements into TS 3/4.3.3.6, Accident Monitoring Instrumentation.

The licensee has also proposed a modification of the operability requirements of the hydrogen monitors to conform to those for the PAM instrumentation.

In addition to the surveillance requirements for the PAM instrumentation, the licensee would retain the requirements of using sample gases for sensor verification. The calibration interval of using sample gases would be extended from 92 days to 6 months on a staggered test basis. The hydrogen monitors are redundant and passive instruments with no automatic function. The operator could also obtain hydrogen concentration from the post accident sampling system. The above modified operability and surveillance requirements conform to the STS and their basis and, therefore, are acceptable.

The licensee has also proposed deletion of the detection requirement from BASES B 3/4.6.4, Combustible Gas Control.

Since hydrogen detection would be included in the PAM instrumentation section of the TS, it is acceptable to delete the detection requirement in the combustible gas control section of 4

the TS.

2.4 Steam Generator Level (Narrow Ranae)

In the licensee's March 17, 1995, supplemental submittal, the number of SG water level (narrow range) channels per SG in TS Table 3.3-8 was reduced from four to three. The required number of channels per SG in TS Table 3.3-8 is two, therefore, three channels is also acceptable. The licensee has stated that the changes in the number of SG water level (narrow range) channels will be included in the next periodic update of the Final Safety Analysis Report and other documents as appropriate. The staff finds the change in the number of SG water level.(narrow range) channels acceptable.

Based on our review of the proposed amendment, the staff concludes that the proposed changes to the PAM instrumentation operability requirements for the Vogtle TS conform to the STS and their bases with the noted deviations. The i

noted deviations were reviewed, and the staff determined that the proposed TS changes provide appropriate limiting conditions for operation and action statements for the PAM instrumentation, and are, therefore, acceptable.

3.0 STATE CONSULTATION

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 requirements with respect to install'ation or use of a facility component located within the restricted area as defined in 10 CFR 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 (59 FR 22008 dated April 28, 1994). 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.

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:

Barry Marcus Date:

May 15, 1995

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