ML20092H571

Responds to Generic Ltr 84-09, Hydrogen Recombiner Requirements of 10CFR50.44. Inerted BWR Mark I Containments Requested to Be Exempt from Equipment Qualification Requirements (Ref 10CFR50.44(c)(3)(ii))

ML20092H571
Person / Time
Site:	Hatch
Issue date:	06/21/1984
From:	Gucwa L GEORGIA POWER CO.
To:	Stolz J Office of Nuclear Reactor Regulation
References
GL-84-09, GL-84-9, NED-84-318, TAC-56045, TAC-56046, NUDOCS 8406260200
Download: ML20092H571 (3)

Text

Georg;a Power Corroany

• *6 333 Piedmont Avenue Ananta Georga 30308 Telephore 404 526 6%6 Maang Mdress Post Office Box 4545 At:arita. Georgia 30302 Georgia Power L T. Gucwa u sou...,o,.r.c z w .m Manag- Nuc! ear Ervne-9 June 21, 1984 NED-84-318 and Cruef Naclear Eng neer Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 Division of Licensing U. S. Nuclear Regulatory Cannission Washington, D. C. 20555 NRC DOCKE'IS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EIMIN I. HA'IGI NUCEEAR PIRTP UNITS 1, 2 RESPONSE 'IO GENERIC IEITER 84-09 HYDROGEN REOCNBINER REQUIRB'ENIS OF 10 CFR 50.44 Gentlemen In Generic Intter 84-09, the NRC concurred with the position that, if certain criteria are met, an inerted BWR Mark I contalment does not rejuire a hydrogen recebiner to meet the requirenents of 10 CFR 50.44(c)(3)(ii).

Per the instructions of that letter, we hereby provide the requested information regarding Plant Hatch conformance to the criteria and request that Plant Hatch Units 1 and 2 be considered exmpt frm the hydrogen recebiner rejuirment of 10 CFR 50.44(c) (3) (ii).

Georgia Power Ca pany (GPC) has reviewed the stated criteria and has concluded that Plant Hatch Units 1 and 2 meet the necessary conditions.

Unit 2 was originally licensed with a non-inerted contalment and, therefore, had a recebiner installed during construction. However, Unit 2 containment was subsequently inerted and has a safety grade purge /repressurization systen. GPC is preparing a sutmittal to request that the Unit 2 hydrogen recebiners be redefined in the licensing basis to be consistent with the licensing basis of Unit 1, and, therefore, exenpt frm equipnent qualification retuirenents.

GFC was a participant in the DhR Owners Group (BWROG) flydrogen Control Cannittee. De BWROG position is applicable to Plant Hatch. n e following is a restatenent of the criteria frm your letter, followed by a discussion of Plant Hatch conformance to the criteria:

criterion 1:_ "%e plant has technical specifications (limiting conditions for operation) requirirej that, when the contairinent is required to be inerted, the containment abnosphere be less than four percent oxygen."

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GeorgiaIbwer1 Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 June 21, 1984 Page 2 Plant Hatch Conformance: Technical Specifications require that, when the contalment is reluired to be inerted, the contairunent atmosphere be less than four percent oxygen. Both units have a Technical Specification limiting condition for operation (ICO) specified if the requiranent cannot be met.

Criterion 2: "he plant has only nitrogen or recycled containment atmosphere for use in all pnematic control systes within containnent."

Plant Hatch Conforiaance: Plant Hatch uses recycled contalment atmosphere as the primary source, and nitrogen as a back-up source for all pneunatic systes inside containnent. A cross tie fra the drywell pneunatic systen to the non-interruptable instrunent air systen is available if needed in an energency. Use of air fra the instrunent air systen is controlled by a renovable spool piece, and would be used only in the unlikely event that the two normal pneunatic supply systens were lost.

Criterion 3: "%ere are no potential sources of oxygen in contalment other than that resulting from radiolysis of the reactor coolant.

Consideration of potential sources of inleakage of air and oxygen into containment should include consideration of not only normal plant operating conditions but also postulated loss-of-coolant-accident conditions. %ese potentiti sources of inleakage should include instrument air systens, service air systens, MSIV leakage control systens, purge lines, penetrations pressurized with air and inflatable door seals."

Plant Hatch Conformance: We have identified three potential sources of oxygen addition into the primary containnent:

1) Use of the cross tie to the non-interruptable instrument air systan- as stated in the discussion of criterion 1, the tie to the instrunent air systen is controlled by a renovable spool piece and would be used only in the unlikely event that the two normal pneunatic supply systens are lost. Technical Specification reluirenents would result in operator action to maintain contairunent oxygen concentration below 44.

2) H2-02 analyzers use oxygen as a reagent to measure hydrogen concentration- the snount of oxygen reagent available to the H0 2 analyzer would, if added to the containment atmosphere, 2 change oxygen concentration less than 14. %e worst credible failure in the H022 analyzer would result in a very slow leak into containnent. Several weeks would be room

Georgia Power b Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 June 21, 1984 Page 3 required before contaiment oxygen concentration changed a significant mount. 'Ite Technical Specification surveillance requirments, and the ICO on oxygen concentration assure that concentration would not be allowed to increase above 4%.

3) The leakage of secondary contaiment air into primary contalment- Technical Specification requirments for allowable contalment leak rates assure that inleakage is mall under any circmstances. Further reducing the possibility of inleakage is the fact that primary contaiment is normally maintained at a positive pressure relative to secondary contaiment.

We conclude that there are no potential sources of oxygen which would increase oxygen concentration above the flmability limit. We further conclude that, based on the BWROG hydrogen control study and subsequent NRC investigations, Plant Hatch Units 1 and 2 should be considered exmpt frm the 10 CFR 50.44(c)(3) (ii) ra;uirment for hydrogen recmbiner capability.

Please contact this office if you have any questions or coments.

Very truly yours,

()h)pl'1 A 1sL. T. Gucwa PIS/

xc: H. C. Nix, Jr.

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

Senior Resident Inspector FC07 ?S