ML20134Q059

Application for Amend to License NPF-5,correcting Erroneous Footnote in Tech Spec Table 3.3.4-2 Re RCIC Sys Actuation Instrumentation

ML20134Q059
Person / Time
Site:	Hatch
Issue date:	08/30/1985
From:	Pinson R GEORGIA POWER CO.
To:	Stolz J Office of Nuclear Reactor Regulation
Shared Package
ML20134Q063	List: ML20134Q059 ML20134Q075
References
2103N, NED-85-655, TAC-59576, NUDOCS 8509090148
Download: ML20134Q059 (6)

Text

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• O Georgta Power Company 333 Pwx1mor't Avenue At!anta. Georg a 30308 Telephone 404 526 7853 Malog A11ress:

Pot.! Off.ce Box 4545 A:ianta, Georg;a 30302 h Georgia Power nmm ex,osen P

@jp, NED-85-655 eng. nee,og a.,o construa on serwes 2103N August 30, 1985 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. HATCH NUCLEAR PLANT UNIT 2 EMERGENCY TECHNICAL SPECIFICATION CHANGE RCIC INSTRUMENTATION Gentlemen:

In accordance with the provisions of 10 CFR 50.90 as required by 10 CFR 50.59(c)(1), Georgia Power Company hereby proposes a change to the Technical Specifications, Appendix A to Operating License NPF-5. This change is requested on an emergency basis.

It has been discovered that a literal interpretation of an erroneous footnote in Table 3.3.4-2 results in a declaration of inoperability for the Reactor Core Isolation Cooling (RCIC) system and entry into a 14 day Limiting Condition for Operation in accordance with Technical Specification 3.7.3.a. The requested change will change a footnote for the subject table to correct the present error.

Attachment 1 provides a detailed description of the proposed change and circumstances necessitatir.g the change request.

Attachment 2 details the basis for our determination that the proposed change does not constitute an unreviewed safety question.

Attachment 3 details the basis for our determination that the proposed change does not involve -significant hazards considerations. Pursuant to 10 CFR 50.91 (a)(5), we request that this amendment, which involves no significant hazards consideration, be issued without prior notice or a public comment period. Failure to provide the requested change will result in a unit shutdown. This application is being made in a timely fashion, on the day of discovery of the erroneous footnote.

Attachment 4 provides page change instructions for incorporating the proposed change.

8509090148 850830 PDR P ADOCM 05000366 pop (A 1 i

I Georgia Powerkh Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 August 30, 1985 Page Two The proposed changed Technical Specification page follows Attachment 4.

Payment of filing fee will follow.

Pursuant to the requirements of 10 CFR 50.91, Mr. J. L. Ledbetter of the Environmental Protection Division of the Georgia Department of Natural Resources will be sent a copy of this letter and all applicable attachments.

R. H. Pinson states that he is 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: ~77 , ,

L/srarn

'R. H. Pinson ' ~~ '

Sworn to and subscribed before me this 30th day of August,1985.

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JJ 6b Notary PubHe, Georda, State at Large Notary Public " = " '

REB / _

Enclosures xc: Mr. H. C. Nix, Jr.

Dr. J. N. Grace (NRC-Region II)

Senior Resident Inspector, Plant Hatch Mr. J. L. Ledbetter F00?TS

V Georgia Power d ATTACHMENT 1 TO GPC LETTER NED 85-655 BASIS FOR PROPOSED CHANGE The proposed change revises the footnote on page 3/4 3-35 which explains the Condensate Storage Tank (CST) level of which the RCIC suction automatically transfers from the CST to the suppression pool. The safety design basis for the transfer logic recuires that the transfer take place at a level corresponding to 10,000 gallons of water remaining in the CST, to ensure an uninterrupted supply of water to the RCIC pump. The CST level at which there are 10,000 gallons of water remaining is 130'-10 1/2" above mean sea level. The level switch which provides the signal to the transfer logic is installed correctly and provides the recuired signal at the 10,000 gallon level. When Technical Specifications were revised to reflect the addition of the suction transfer logic, the level at which suction transfer takes place was erroneously specified as 131'-0" above mean sea level. Since the level switch can not be calibrated to actuate at the 131'-0" level, the Technical Specification recuirement is not met in the strictest sense, even though the system is capable of properly performing its safety function. Non-compliance with this Technical Specification places the unit in a 14 day limiting condition for operation. The proposed change is an administrative change which merely corrects the footnote to specify the actual basis for the setpoint, which is a level corresponding to 10,000 gallons of water in the CST.

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GeorgiaPowerd ,

ATTACHMENT 2 TO GPC LETTER NED 85-655 10 CFR 50.59 EVALUATION Pursuant to 10 CFR 50.59, the Plant Review Board and the Safety Review Board have reviewed the proposed change and determined that it does not involve an unreviewed safety question.

Incorporation of the proposed change will not increase the probability or the ~ consequences of accidents analyzed in the FSAR. The proposed change is '

administrative in nature. Footnote "**" to Table 3.3.4-2 erroneously refers to CST instrument zero as being at a level ~ of 131 feet, 0 inches above mean sea level (MSL). In actuality,' CST instrument level zero is equivalent. to 130 feet, 10.5 inches above MSL, which differs from the Technical Specification footnote by 1.5 inches. However, the CST inventory - corresponding to the actual switchover has been analyzed and provides appropriate margins (i.e.,

greater than 10,000 gallons in CST). Therefore, the proposed change to the Technical Specifications, to reflect the CST inventory rather than level, is essentially administrative. Plant operation is not affected. No new types of accidents are created since no changes to plant operation are involved. The margin of safety as defined in the basis for the Technical Specification is not reduced. This margin reflects actual design values which are correct and not affected. The proposed change merely corrects an erroneous Technical Specification reference to correctly reflect the actual safety design basis for the system.

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. Georgia Power A ATTACHMENT 3 TO GPC LETTER NED 85-655 10 CFR 50.92 EVALUATION Proposed Change Change footnote "**" for Table 3.3.4-2 to read " Equivalent to 10,000 gallons of water in the condensate storage tank."

Basis The Reactor-Core Isolation Cooling (RCIC) system pump takes suction from either the Condensate Storage Tank (CST) or the Torus. When the water level in the CST drops to a preset point, switchover to the torus occurs. The switchover level is based on providing an uninterrupted supply of water to the The switchover level (>0 inches CST RCIC pumplevel instrument during)the corresponds switchover process.

to an inventory of 10,000 gallons in the CST.

The proposed administrative change would change the footnote, which presently references an elevation above mean sea level (MSL), to instead reference the remaining inventory in gallons. It has been determined that the level above MSL provided in the footnote is in error by a very small margin. Changing the l note to reflect the inventory will more accurately reflect the safety basis.

The proposed change does not result in a significant increase in the probability or consequences of analyzed accidents. The proposed change ,

essentially corrects an error in the Technical Specifications. No changes to plant operation will result. The proposed change does not create any new types of accidents since plant operation is unaffected. The proposed change does not significantly reduce a margin of safety. The change corrects an error and provides the appropriate cross reference for the subject setpoint.

Margins of safety are not affected. This change is consistent- with example (1) of " Amendments that are considered not likely to involve significarc hazards considerations" as described in the Federal Register, Vol. 48, No. 67, Page 14870.

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Georgia Powerkh l

ATTACHMENT 4 TO GPC LETTER NED-85-655 INCORPORATION INSTRUCTIONS The proposed change to Technical Specifications (Appendix A to Operating License NPF-5) would be incorporated as follows:

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