ML20137F639

Application for Amend to License NPF-5,revising Tech Specs to Delete Requirements for Primary Containment Hydrogen Recombiners as Primary Means of post-LOCA Combustible Gas Control.Fee Paid

ML20137F639
Person / Time
Site:	Hatch
Issue date:	01/06/1986
From:	Beckham J, Beckmam J, Beckman J GEORGIA POWER CO.
To:	Miller D, Muller D Office of Nuclear Reactor Regulation
Shared Package
ML20137F647	List: ML20137F639 ML20137F693
References
0105C, 105C, SL-80, TAC-56541, NUDOCS 8601170562
Download: ML20137F639 (6)

Text

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z Georgia Power Company g 333 Piedmont Avenue Atlanta. Georgia 30308 Telephone 404 526-7020 Maihng Address:

Post office Box 4545 Atfanta. Georgia 30302 h

Georgia Power J. T. Beckham, Jr. the southern elecinc system Vice President and Ge'teral Manager Nuclear operations SL-80 0105C Jan2ary 6, 1986 Director of M1 clear Reactor Regulation Attention: Mr. D. Miller, Project Director

.BWR Project Directorate No. 2 Division of Boiling Water Reactor Licensing U. S. M1 clear Reg.11atory Comnission Washington, D. C. 20555 NRC DOCKET 50-366 OPERATING LICENSE N W-5 EDWIN I. HA'1UI NUCLEAR PLANT UNIT 2 REGJEST 'IO REVISE 'IEGINICAL SPECIFICATIONS:

REMOVAL OF PRIMARY CDNTAIlWENT HYDROGEN RECDMBINERS Gentlemen:

In accordance with the prcvisions of 10 CFR 50.90 as realired by 10 CFR 50.59(c) (1), Georgia Power Qxnpany hereby proposes changes to the Technical Specifications, Appendix A to Operating License NPF-5.

We proposed change would delete from Plant Hatch Unit 2 Technical Specifications Section 3/4.6.6.2, realirements for primary containment hydrogen recombiners as the primary means of post LOCA comb.Istible gas control.

Attachment 1 provides a detailed description of the proposed change and the basis for the change req 2est.

Attachment 2 details the basis for o.tr determination that the proposed change does not constitute an unreviewed safety cuestion.

Attachment 3 details the basis for oar determination that the proposed change does not involve significant hazards considerations.

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

We proposed changed Technical Specification pages follow Attachment 4.

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Payment of filing fee is enclosed.

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8601170562 860106 PDR ADOCK 05000366 P PDR Re&&**f*c0

E GeorgiaPower d Director of N2 clear Reactor Regalation Attention: Mr. D. Miller, Project Director .

BfR Project Directorate Ib. 2 Jamary 6,1985

Page '1ko In order to allow time for procecilre revision and orderly incorporation into copies of the 'Dechnical Specifications, we recuest that the proposed amendment once approved by the NRC, be isaled with an effective date to be no later than 30 days from the date of issaance of the aa=nahnt. -

R1ralant to the requirements of 10 CER 50.91, Mr. J. L. Iedbetter of the

. Environmental Protection Division of the Georgia Department of Natural Resources will be sent a copy of this letter and all applicable attachments.

J. T. Beckham, Jr. states that he is Vice President of Georgia Ibwer Conpany and is althorized to execute this oath on behalf of Georgia Ibwer Conpany, and that to the best of his knowledge and belief the facts set forth

.in this letter and attachments are trae.

GBORGIA 10WER (DMPANY d

By: - -

g J. T. Beckham, Jr. '

Sworn to and albscribed before me this 6th day of Jamary,1986.

Nctary Pubr4 Geotpa. State at t.ega Notary Riblic

&(y Commission Expres Aug26,1986 EEE/1tEB/lc -

Encloalres c: Mr. H. C. Nix, Jr.

Senior Resident Inspector Dr. J. N. Grace, (NRC-Region II)

Mr. J. L. Iedbetter 4

i 4-700775

a Georgia Pbwer A

- ATTAGMENT 1 NRC DOGET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HAIG NUCLEAR PLANT UNIT 2 BASIS EUR GANGE REGJEST Plant Hatch Unit 2 was originally licensed with a non-inerted containment which used primary containment hydrogen recombiners as the primary means of post IDCA comtustible gas control. A safety-related containment Eurge system was also provided as a primary backup for the hydrogen recombiners. In 1982,

.the Unit 2 containment was inerted as recuired by 10 CFR 50.44 (c) (3) (i). The proposed change would delete the Technical Specifications for the hydrogen recombiners, section 3/4.6.6.2.

The primary basis for deleting the recuirement for safety-related hydrogen recombiners is an anaysis performed by GE for the Boiling Water Reactor Owners Group (BWROG) ~ (NEDO-22155, aine 1982) . This study showed that the existing inerted BWR Mark I Containment design is adecuate for control of contustible gases withcut the need for hydrogen reconibiners or containment venting. In a follow-tip letter from T. J. Dente (BWROG) to D. G. Eisentut (NRC) , 11ay 2, 1983, . the NEDO analysis was extended to additional Mark I plants including Hatch Unit 2. _ The NRC concurred with the results of the NEDO provided that the plant meet the three criteria listed in NRC Generic Ietter 84-09:

Criterion 1:' "The plant has Technical Specifications (limiting conditions for operation) recniring that, when the containment is recpired to be inerted, the containment atmosphere be less than four percent oxygen."

Criterion 2: "The plant has only nitrogen or recycled containment atnosphere for use in all pnalmatic control systems within containment."

Criterion 3: "There are no potential sources of oxygen in containment other than that rea11 ting from radiolysis of the reactor coolant. Onsideration of potential sources of inleakage of air and oxygen into containment should include consideration of not only normal plant operating conditions tut also postulated loss-of-coolant-accident conditions. These potential sources of inleakage should include instrument air systems, service air systems, MSIV leakage control systems, Eurge lines, penetrations presaarized with air and inflatable door seals."

In Georgia Power Conpany's response to Generic Ietter 84-09 (letter NED-84-318, aine 21, 1984), it was demonstrated that both Hatch units adecuately meet the above criteria.

In addition to the GS analysis, Northmst Utilities Service Conpany (NUSCD) perfornned an analysis on Millstone which addressed the NRC concern over the adverse affect of iciine inpirity on radiolysis (Docket 50-245, uns

Georgia Power d ATI'AONENT 1 (contimed) j Alcyst 1982) . We reallts showed that the predicted post design basis accident (DBA) primary coolant iodine concentrations, using conservative Appendix K models, were still well below the iodine concentration level which would ca2se radiolysis to be a concern for comhistible gas generation. A albsecuent calculation by GE confirmed that for Hatch Unit 2, recombiners are not needed I for flamable gas control when the effect of impirities is considered, and the conchisions of the NUSOD analysis are applicable.

Herefore, since Hatch Unit 2 has an inerted containment ar.d it has been demonstrated that BWRs with inerted containments do not need hydrogen

' recombiners or containment pirge systems for post-DBA comhlstible gas control, it is proposed that the hydrogen recombiner Technical Specification be deleted. %e existing hydrogen recombiners will be kept, hit will be downgraded to a nonsafety-related system, and the containment p2rge system will become the primary backup to inerting. 'Itus, hydrogen recombiners will no longer be recuired to meet ecpipment cualification recuirements (10 G R 50.49), nor would an LCD be entered in the event of a recombiner failure.

. 700775

l I

Georgia Power A ATTAONENT 2 NRC DOGET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HA'IUI NUCLEAR PLANT UNIT 2 10 CFR 50.59 EVAWATION R1ratant to 10 CPR 50.59, the Plant Review Board and Safety Review Board have reviewed the attached proposed amendment to the Plant Hatch Unit 2 Technical Specifications and have determined that implementation of the proposed change does not constitute an unreviewed safety glestion.

'Ite probability of occarrence or the conseglences of an accident or malfunction of the eglipnent inportant to safety are not increased above those analyzed in the FSAR die to this change beca1se the peak containment oxygen concentrations' are maintained below the comtustible gas limits at all times without regliring containment venting or hydrogen recombinerc.

'Ihe possibility of an accident or malfunction of a different type than analyzed in the FSAR does not reallt from this change becalse no new modes of operation have been introd1ced.

'1*e margin of safety as defined in Technical Specifications is not rediced die to this change beca1se, as demonstrated in NRC approved GE 'Ibpical Report NECO-22155 and related documents, hydrogen recombiners are not realired for comtustible gas control in plants with inerted Mark I containments (see

- Attachment 1) .

700779 -

C. -- 1

+ i LGeorgiaPowerA ATI'ACHMENT 3 NRC DONET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HA'IGI NUCLEAR PLANT UNIT 2 10 CFR 50.92 EVAWATION

- R1ratant to 10 CFR 50.92, Georgia Power Company has evaluated the attached proposed amendment for Plant Hatch Unit 2 and has determined that its adoption would .not involve a significant hazard. %e basis for this determination is -

as follows:

%e proposed change does not involve a_ significant increase in the probability or conseglences of an accident previously evaluated beca1se the peak containment oxygen concentrations are maintained below the combustible gas limits at all times without regliring hydrogen recombiners.

We proposed change does not create the possibility of a new or different kind of. accident from any accident previously evaluated beca1se no new nodes of operation have been introd1ced.

We proposed change does not involve a significant .rediction in a margin of safety becalse NEDO-22155 and albseglent applicability extensions have demonstrated that hydrogen recombiners are not required for combustible gas control in plants with inerted Mark I containments (see Attachment 1) .

%e proposed change is consistent with Item (iv) of the " Examples of Amendments %at Are (bnsidered Not Likely To Involve Significant Hazards -

Oonsiderations" listed on page 14,870 of the Federal Register, April 6,1983.

Item - (iv) is defined as "A relief granted upon demonstration of acceptable .

operation from an operating restriction....". We change is consistent with Item (iv) becalse it would delete req 11rements for primary containment

-hydrogen recombiners from the Technical Specifications becalse new analyses have demonstrated that hydrogen recombiners are not regiired for contustible gas control in plants with inerted Mark I containments (see Attachment 1) .

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