ML20138A089

Application for Amend to License DPR-57,deleting Tech Spec Table 3.7-1, Primary Containment Isolation Valves, Clarifying Definition & Text & Revising Shutdown Requirement 3.7.D.3.Basis for Request Encl.Fee Paid

ML20138A089
Person / Time
Site:	Hatch
Issue date:	03/03/1986
From:	Beckham J GEORGIA POWER CO.
To:	Muller D Office of Nuclear Reactor Regulation
Shared Package
ML20138A093	List: ML20138A089 ML20138A097
References
0261C, 261C, SL-226, TAC-61054, TAC-61280, NUDOCS 8603140030
Download: ML20138A089 (11)

Text

T 1 Georgia Power Company 8- 4 333 Piedmont Avenue Atlanta, Georgia 30308 Telephone 404 526 7020 Mailing Address:

Post Othce Box 4545 Atlanta. Georgia 30302 Georgia Power J. T. Beckham, Jr. tre snuttern etttnc system Vice President and General Manager

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SL-226 0261C March 3, 1986 Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 Division of Boiling Water Reactor Licensing U. S. Nuclecr Regulatory Commission Washington, D. C. 20555 NRC DOCKET 50-321 OPERATING LICENSE DPR-57 EDWIN I. HATCH NUCLEAR PLANT UNIT 1 REQUEST TO REVISE PRIMARY CONTAINMENT SYSTEM TECHNICAL SPECIFICATIONS Gentlemen:

In accordance with the provisions of 10 CFR 50.90 as required by 10 CFR 50.59(c)(l'), Georgia Power Company hereby proposes changes to the Technical Specifications, Appendix A to Operating License DPR-57 The proposed changes would: (1) delete Plant Hatch Unit 1 Technical Specifications Table 3.7-1, " Primary Containment Isolation Valves", and replace the table with references to valve listings contained in applicable giant procedures; (2) clarify the Definition and text in regard to the deactivation in the isolated position" of Containment Isolation Valves in each line having an inoperable valve; and (3) revise shutdown requirement 3.7.D.3 for an inoperable Containment Isolation Valve, to be consistent with shutdown requirement 3.7.A.8 for loss of Primary Containment integrity.

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8603140030 860303

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' Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 Director of Nuclear Reactor Regulation March 3,.1986 Page Two These changes are requested in addition to those identified in our letter to NRC dated March 5,1979 which proposed deletion of Technical Specifications Tables 3.7-2, 3.7-3, and 3.7-4 Deletion of component listings, as requested in proposed change (1) above, has been identified as a potential generic improvement to Technical Specifications by ongoing industry and NRC programs to improve Technical Specifications. The NRC Technical Specification Coordination Branch (TSCB) will be provided with a copy of this submittal.

The Plant Review Board and Safety Review Board Subcommittee have reviewed the proposed changes.

Attachment 1 provides a detailed description of the proposed changes and bases for the changes.

Attachment 2 details the basis for our determination that the proposed changes do not involve a significant hazards consideration.

Attachment 3 proposed changes. provides page change instructions for incorporating the The proposed changed Technical Specifications pages follow Attachment 3 i i

Payment of filing fee is enclosed. '

1 In order to allow time for procedure revision and orderly incorporation I

. into copies of the Technical Specifications, we request that the proposed {

amendment, once approved by the NRC, be issued with an effective date to be 4

no later than 60 days from the issuance of the amendment.

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.  !

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Georgia Powerk h-Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 Director of Nuclear Reactor Regulation March 3,1986 Page Three J. T. Beckham, Jr. 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 the letter and attachment are true.

GEORGIA POWER COWANY By:

J. T. Beckham, Jr. /

Sworn to and subscribed before me this 3rd day of March,1986 Uw $ $x>tC pt i., Public reb. m PubHc.ctayton county.Geor g ary py c mmissi n Expires Dec. 12,1989 Attachments c: Mr. H. C. Nix, Jr.

Mr. E. J. Butcher - NRC TSCB Senior Resident Inspector, Plant Hatch Dr. J. N. Grace Mr. J. L. Ledbetter GO-NORMS l

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i GeorgiaPower1 ATTACHENT 1 NRC DOCKET 50-321' OPERATING LICENSE DPR-57 EDWIN I. HATCH NUCLEAR PLANT UNIT 1 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

BASIS FOR CHANGE REQUEST Proposed Change 1:

Delete Table 3.7-1, " Primary Containment Isolation Valves," from the Technical Specifications.

Basis i

Plant Hatch Unit 1 Technical Specification Section 3/4.7 addresses Containment Systems. Table 3.7-1 provides a partial listing of " Primary 1

Containment Isolation - Valves". This listing includes the Main Steam Isolation Valves and excess flow check ~ valves. Surveillance Specification 4.7.D.1 requires that "the operable isolation valves that are power operated

, and automati "'ly initiated shall be tested for simulated automatic initiation ana , _ closure times specified in Table 3.7.1." Georgia Power Company (GPC) performed a review of the Primary Containment Isolation System (PCIS) Technical Specifications at NRC request (letter of August 22, 1984, transmitting Amendment 40 to the Hatch Unit 2 Technical Specifications).

This review, which is now complete for Hatch Unit 1, has indicated that certain changes to Table 3.7-1 are necessary to accurately reflect the as-built PCIS. However, rather than propose changes to the Table, GPC believes it is appropriate to request deletion of Table 3.7-1 from the l Technical Specifications, and replacement with a reference to valve listings '

contained in plant procedures. Our reasons for this detemination are as l follows:

1. Removal of the listings from the Technical Specifications is i appropriate in the context of Technical Specification refom. Current Industry /NRC efforts to improve Technical Specifications have identified I component listings as an item for removal because they do not contribute ,

to plant safety and their level of detail results in frequent requests  ;

for License Amendments. This, in turn, results in inherent inaccuracies

, .in the Technical Specifications due to the delays in receiving license ,

amendments brought about by the current regulatory environment. NRC has already recommended and approved removal of analogous snubber listings from the Plant Hatch Technical -Specifications. In addition, tables related to - fire protection devices and containment penetration protection circuit breakers have been removed from Technical 6

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Georgia Powerkh ATTACHMENT 1 (Continued)

. Specifications for other dockets. Use of component listings through reference to plant procedures ensures that timely information is maintained which reflects recent plant modifications. Changes to these 3 plant ~ procedures are strictly controlled under 10 CFR 50.59 In addition; the Technical Specifications requirement to maintain primary containment integrity, as well as ASME code testing requirements and 10 CFR 50 Appendix J requirements. .are maintained. Only the list of valves

would be subject to licensee control under 10 CFR 50.59 4

2. Appropriate mechanisms and controls exist to ensure correct testing for the valves through plant procedures. As discussed above, these

. procedures.will incorporate valve list information developed to meet the requirements of Technical Specification 4.7.D, as well as Appendix J (Section II.H.2 requires leak rate testing of all automatic closing containment isolation valves, and thus maintenance of a list of such valves), and Section XI of the ASME code, which requires once per cycle testing of valve closure and timing for certain of the Table 3.7-1 valves. In addition, Technical Specifications for Protective Instrumentation (notes to Table 4.2-1) require once per cycle performance of a Logic System Functional Test for most of the valves listed in Table 3.7-1. This test, per definition, includes actuation of the valve. A complete listing of containment isolation valves and required closure times is also provided as Table 7.3-1 to the Hatch Unit 1 updated Final Safety Analysis Report. All the above requirements are appropriately integrated into plant procedure (s) subject to change only under - 10 CFR 50.59 The procedures cover testing (to or beyond the present Technical Specifications -requirements) for all valves currently l

! included in Table 3.7-1. References to plant procedures will replace l l references to Table 3.7-1 in the text of the Technical Specifications.  !

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Pl ant procedures are auditable and subject to inspection by NRC. l Specific closure time testing requirements will be maintained in the I Technical Specifications for the MSIVs under Section 4.7.D.1.c.(2) l l

3 Additionally, there are no specific criteria for which valves should

,l be included in the Technical Specifications table of PCIS valves. The  :

scope of this list. Varies with individual plant's Technical l Specifications. Five operating plants have Technical Specifications '

which do not even contain such a list. The wording of . Specification .

4.7.D.1 implies that all automatic containment isolation valves should  ;

be tested whether or not they appear in the Table. Additionally, there j is - no requirement for a similar table to list non-automatic isolation valves, which also make up the containment boundary. The Table lists '

excess flow check valves which do not receive a containment isolation signal.

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- GeorgiaPower A ATTACHENT 1 (Continued)

Proposed Change 2:

Clarify Technical Specifications regarding deactivation of containment isolation valves in the isolated position .for lines with inoperable valves.

Basis

This chan would revise the definition of "

Primary Containment Integrity"gefor clarity by replacing text in' Technical Specification Section 1.0.T.3. Currently, this section states "All automatic containment isolation valves are operable or deactivated in the  :

isolated position." Because Technical Specifications Section 3.7.D.2 allows for an alternate valve to be isolated if an automatic containment isolation valve is found inoperable, Section 1.0.T.3 has '

been clarified to read "All automatic containment isolation valves are either operable, or at least one automatic containment isolation valve 1 in each line having an inoperable valve is deactivated in the isolated l posi tion. " Also, to correspond with the proposed revised text in l Section 1.0.T.3, the phrase in Section 3;7.D.2 which states "in the mode' corres)onding to the isolated condition" has been clarified to read "deacti vated in its isolated position." Section 4.7.D.2 has also been reworded to correspond to the changes in Section 3.7.D.2 Proposed Change 3:

Provide equivalent LCO times for inoperability of a primary I

containment isolation valve and loss of primary containment integrity.

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Basis l

This change proposes to revise Technical Specifications section l

1 3.7.D.3 (action statement for inoperable containment isolation valves)  !

in the following manner:

Current Specification:

"If Specification 3.7.D.1 and 3.7.D.2 cannot be met, an orderly I shutdown shall be initiated and the reactor shall be placed in the ,

cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />". 1 Proposed Spectfication:

"If Specifications 3.7.D.1 and 3.7.D.2 cannot ~be met, an orderly shutdown shall be initiated and the reactor shall be brought to Page 3 4

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t GeorgiaPower d ATTACHMENT 1 (Continued) hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and shall be in the cold shutdown condition within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

This proposed change provides an equivalent LCO for inoperability of a PCIS valve as that specified in 3.7.A.8, for loss of primary containment integrity. This change is appropriate because primary containment integrity is the function preserved by the primary containment isolation valves. Therefore, inoperability of a single isolation valve should not require entry into a more severe LCO than that for loss of primary containment integrity. Additionally, this change is consistent with the Plant Hatch Unit 2 Technical Specifications and with Specification 3.6.3 of the General Electric Standard Technical Specifications for BWR/4s. The proposed LC0 provides for more time to take corrective action to repair an inoperable containment isolation valve, before having to take action to bring the plant to a cold shutdown condition.

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GeorgiaPbwerd ATTACMENT 2 NRC DOCKET 50-321 OPERATING LICENSE DPR-57 EDWIN I. HATCH NUCLEAR PLANT UNIT 1 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

10 CFR 50.92 EVALUATION Pursuant to 10 CFR 50.92, Georgia Power Company has evaluated the i attached proposed amendment for Plant Hatch Unit 1 and has determined that its adoption would not involve a significant hazard. The basis i

for this determination is as follows.

Proposed Change 1:

Table 3.7-1 would be deleted.

Basis:

This change is consistent with Item (i) of the " Examples of Amendments That are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the Federal Register, April

6, 1983 This change is considered purely administrative as the

testing requirements are unchanged.

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The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated because no accident analysis is affected by this change.

4 The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated because no accident analysis is affected by this change.

The. proposed change does not involve .a significant reduction in the '

margin of safety because it is befr.g made for clarification purposes and to remove potentially confusing equipment listings.

Proposed Change 2:'

This proposed change would replace text in Technical Specification

. Section 1.0.T.3 for clarity. Currently, this section states "All automatic containment isolation valves are operable or deactivated in the isolated position." Because Technical Specifications Section 1

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GeorgiaPower d ATTACHMENT 2 (Continued) 3.7.D.2 allows for an alternate valve to be. isolated if an automatic containment isolation valve is found inoperable, Section 1.0.T.3 has been ,

clarified to read "All automatic containment isolation valves are either '

operable, or at least one automatic containment isolation valve in each line having an inoperable valve is deactivated in the isolated position."

Also, to correspond with the new text in Section 1.0.T.3, the phrase in Section 3.7.D.2 which states "in the mode corresponding to the isolated condition" has .been clarified to read " deactivated in its isolated position." Section 4.7.D.2 has also been reworded to correspond to the changes in Section 3.7.D.2 Basis:

These changes are consistent with item . (i) of the " Examples of Amendments That are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the Federal Register, April 6, ,

1983 The proposed changes provide for administrative clarification to the Technical Specifications, and thus clearly fall under Item (1).

The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated because no accident analysis is affected by these changes.

The proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated because no accident analysis is affected by these changes.

The proposed changes do not involve a significant reduction in the margin of safety because they are editorial and do not cha.nge the intent of the Plant

Hatch Unit 1 Technical Specifications.

Proposed Change 3 i .

i This change proposes that an additional twelve hours be added to the LCO time to Technical Specification 3.7.D.3 to be- consistent with Plant Hatch '

Unit 1 Technical Specification 3.7. A.8, the Plant Hatch Unit 2 Technical Specifications, and Standard Technical Specifications. This specification deals with actions to be taken with the inoperable containment isolation >

valves.

l Basis:

l The proposed change does not involve a significant increase in the  :

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Georgia Powerkh ATTACHMENT 2 (Continued) probability or consequences of an accident previously evaluated because no accident analysis is affected by this change. The primary containment isolation system will still function as described in the FSAR. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated because no accident analysis is affected by this change and no new plant configurations for operation are proposed by this change.

The proposed change does not involve a significant reduction in the margin of safety because this proposed change is within the acceptable limits set forth by the NRC as demonstrated in Specification 3.6.3 of the General Electric Standard Technical Specifications for BWR/4 Reactors.

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GeorgiaPbwerA ATTACHMENT 3 f 1

i NRC DOCKET 50-321 1 OPERATING LICENSE DPR-57 EDWIN I. HATCH NUCLEAR PLANT UNIT 1 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

INSTRUCTIONS FOR INCORPORATION The proposed changes to Technical Specifications (Appendix A to Operating License DPR-57) would be incorporated as follows:

Remove Page Insert Page ix ix  !

1.0-4 1.0-4 l 3.2-2 3.2-2 i 3.2-3 3.2-3 l 3.2-4 3.2-4 l 3.7-13 3.7-13  !

3.7-14 3.7-14  !

3.7-16 3.7-16  ;

3.7-17 3.7-17 3.7-18 3.7-18 3.7-19 3.7-19 3.7-20 3.7-20 3.7-35 3.7-35 i

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