ML20151C316

Application for Amend to License DPR-57,revising Tech Specs Re Secondary Containment Boundary Under Specific Plant Conditions as Described in Tech Spec 3.7.C.2.Fee Paid

ML20151C316
Person / Time
Site:	Hatch
Issue date:	07/11/1988
From:	Hairston W GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20151C320	List: ML20151C316 ML20151C328
References
SL-4769, TAC-68893, NUDOCS 8807210314
Download: ML20151C316 (11)

Text

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.J

, . . . be . *Georg a Power Company 333 PMmont Avenue Atlanta. Georg a 30308 Te!ephone 404 526 6526 I t Off x 4545 Atlanta, Georgia 30302 GeorgiaPower Nuclear Operations Department N ' * *" + M l' C W""

SL-4769 2074C X7GJ17-H600 July 11, 1988 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C. 20555 PLANT HATCH - UNIT 1 i NRC DOCKET 50-321 OPERATING LICENSE DPR-57 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

SECONDARY CONTAINMENT B0UNDARY RE0VIREMENTS Gentlemen:

In accordance with the provisions of 10 CFR 50.90, as required by 10 CFR 50.59(c)(1), Georgia Power Company (GPC) hereby proposes changes to the Plant Hatch Unit 1 Technical Specifications, Appendix A to Operating License DPR-57.

Planning and scheduling maintenance work during Unit I refueling outages is a difficult task due to the inability to perform simultaneous work on the Unit 1 main steam isolation valves (MSIVs) and the Unit 1 turbine stop valves without breaching secondary containment integrity.

The normal Unit 1 secondary contaiament boundary includes the Unit I reactor building area below the refueling floor and the common Units 1 and 2 area above the refueling floor. Therefore, simultaneous work on both groups of valves could introduce a leakage path through the reactor building, and consequently, secondary containment.

Since the problem is recurrent, GPC proposes permanent changes to the Unit 1 Technical Specifications to conditionally modify the secondary containment boundary under specific plant conditions as described in Technical Specification 5.7.C.2. Under the configuration contemplated, the proposed "modified" Unit I secondary containment would include only the common area above the Unit 1 and Unit 2 refueling floor, allowing continuation of refueling activities and Unit 2 reactor operation during a Unit 1 outage. Similar temporary changes were approved by the Nuclear Regulatory Commission (NRC) with the issuance of Amendment 91 to the Unit 1 Technical Specifications. That amendment provided a temporary revision to the secondary containment related Technical Specifications during the 1982 refueling outage to permit major modi fication work associated with the Mark I Containment Long-Term Program. The intent of the change described herein is to permanently implement the temporary changes contained in Amendment 91.

lN 's_

8807210314 880711 POR 0 0l ADOCK 05000321 p P PDC @ g (plgg

Georgia Power b U.S. Nuclear Regulatory Commission July 11, 1988 Page Two The changes described in Enclosure 1 will facilitate work planned for the next Plant Hatch Unit I refueling outage which is currently scheduled to begin October 1,1988. Therefore, approval of these changes is requested prior to that date.

Some editorial changes are also proposed to delete redundant material, correct section numbering, and clarify wording.

Enclosure 1 provides a detailed description of the proposed changes and the circumstances necessitating the change request.

Enclosure 2 details the bases for our determination that the proposed changes do not involve significant hazards considerations.

Enclosure 3 provides page change instructions for incorporating the proposed changes. The proposed revised . Technical Specifications pages follow Enclosure 3.

Payment of the filing fee in the amount of one hundred and fifty dollars is enclosed.

To allow time for procedure revisions and orderly incorporation into copies of the Technical Specifications, Georgia Power Company requests the proposed amendments, once approved by the NRC, be issued with an effective date to be no later than 60 days from the date of issuance of the amendment.

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

Mr. H. G. Hairston, III states he is Senior Vice President of Georgia Power Company, and to the best of his knowledge and belief, the facts set forth in this letter are true.

GEORGIA POWER COMPANY By: -

c I W. G. Hairston, III Sworn to and subscribea before me this lith day of July 1988.

RAf d ff

~MNot6ry Public " y Pubhc. Cobb County Go,

(/ W Commission Expires May 5.199o KHH/cd

Enclosures:

(See next page.)

2074C

\

GeorgiaPoiver b U.S. Nuclear Regulatory Commission -l July 11, 1988 Page Three

Enclosures:

1. Basis for Change Request.

2. 10 CFR 50.92 Evaluation.

3. Page Change Instructions.

4. Filing Fee - $150.00.

c: Georaia Power Comoany Mr. J. T. Beckham, Jr., Vice President - Plant Hatch Mr. L. T. Gucwa, Manager Nuclear Safety and Licensing GO-NORMS U.S. Nuclear Reaulatory Commission. Washington. D.C.

Mr. L. P. Crocker, Licensing Project Manager - Hatch U.S. Nuclear Reaulatory Commission. Region II Dr. J. N. Grace, Regional Administrator Mr. J. E. Menning, Senior Resident Inspector - Hatch State of Georaia Mr. J. L. Ledbetter, Commissioner - Department of Natural Resources l

2074C 700775

. , . , .- . , . - . ~ , -

Georgia Powerkh ENCLOSURE 1  !

PLANT HATCH - UNIT 1 l NRC DOCKET 50-321 l OPERATING LICENSE DPR-57 1 REQUEST TO REVISE TECHNICAL SPECIFICATIONS: l SECONDARY CONTAINMENT B0UNDARY REQUIREMENTS l BASIS FOR CHANGE REOUEST PROPOSED CHANGE 1:

This change will revise the Plant Hatch Unit 1 Technical Specifications pertaining to secondary containment boundary requirements. The change will establish two modes of secondary containment to facilitate activities l during outage situations. Accordingly, a "normal" . secondary containment mode will be maintained during most plant conditions, and a "modified" secondary containment configuration may be established if certain l conditions are met while the unit is shutdown. Specifically, this proposed change will modify Limiting Conditions for Operation Specifications 3.7.C.1 and 3.7.C.2, the associated surveillance requirements (Specifications l 4.7.C.) and 4.7.C.2), the Design Features Section 5.0.D.2 and the applicable bases. This change will permit modification of the normal Unit I secondary containment boundary (Figure 1, page El-4) when the conditions of 3.7.C.2 are met. Figure 2 (pages El-5 and El-6) shows the modified configuration.

P Basis for Procosed Change 1:

Following a design basis postulated loss-of-coolant accident or fuel handling accident, the ability to maintain secondary containment integrity is essential in order to limit the release of radioactivity to the environment. The standby gas treatment system (SGTS) is an important element of the secondary containment system and is designed to filter and exhaust the secondary containment atmosphere to the main stack during secondary containment isolation conditions. A 1/4 inch water gauge negative pressure is maintained in the secondary containment during SGTS operation.

Figure 1 illustrates how the Unit 1 and Unit 2 SGTS's normally operate with the Unit 1 secondary containment defined to include the Unit I reactor building area below the refueling floor and the common Unit I and Unit 2 area above the refueling floor. The logic which actuates the Unit 1 SGTS is designed to operate in conjunction with the Unit 2 SGTS. The following scenarios summarize how the logic operates:

1. An accident on Unit 1 which causes high drywell pressure, low reactor water level, or high radiation in the Unit 1 reactor building exhaust will cause the Unit i reactor building isolation valves to close and the Unit 1 reactor building HVAC to trip.

2074C El-1 7/11/88 SL-4769 rwm

^

Georgia Power A ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

SECONDARY CONTAINMENT B0UNDARY REQUIREMENTS BASIS FOR CHANGE RE00EST Basis for Proposed Change 1: (Continued)

Also, the refueling floor isolation valves will close and the refueling floor HVAC will trip. Subsequently, the Unit 1 reactor building SGTS isolation valves will open and the Unit I and Unit 2 refueling floor SGTS isolation valves will open. Both Unit 1 and Unit 2 SGTS fans will then start.

2. High radiation in the refueling floor ventilation exhaust will initiate the same sequence for activating SGTS as outlined in (1),

3. An accident on Unit 2 which causes high drywell pressure, low reactor water level, or high radiation in the Unit 2 reactor building exhaust will cause the Unit 2 reactor building isolation valves to close and the Unit 2 reactor building HVAC to trip.

Subsequently, the Unit 2 reactor building SGTS isolation valves will open. The Unit 2 SGTS fans will then start.

In order to conduct plant operations with the proposed modified Unit i secondary containment, SGTS operation must be modified as well. Figure 2, Sheet 1 of 2 illustrates how the Unit I and Unit 2 SGTS's will operate in .

the proposed modified configuration. The SGTS suction lines located in the I Unit 1 reactor building below the refueling floor, including the drywell l and torus, will not be permitted to be open. This condition is permissible, while the conditions specified by 3.7.C.2 are met, since Unit 1 activities which might lead to a postulated release of radioactivity .

during a Unit I refueling outage will be confined to the common Unit I and  !

Unit 2 refueling floor area. For this reason, SGTS service is not required in the Unit I reactor building area below the refueling floor under the conditions specified. In the modi fied configuration, the performance '

capability of the SGTS will not be reduced since the Unit I secondary containment is defined to include a smaller volume. Since the operability of the Unit 1 and Unit 2 SGTS fans and filters would not be affected, the system design basis to maintain a 1/4 inch water gauge negative pressure under accident conditions is preserved and the radiological consequences to the environment are not increased.

To maintain Unit I secondary containment integrity in the common Unit 1 and l

Unit 2 refueling floor area only, automatic or inadvertent opening of l

certain valves (see Figure 2, sheet 2 of 2) in the 3GTS suction lines located in the Unit 1 reactor building area below the refueling floor must be precluded. These valves, if opened would permit suction fra the Unit I reactor building, Unit I drywell, and Unit 1 torus and, therefore, must be secured closed to prevent their operation. They will, therefore, U? closed and administratively controlled in the closed condition.

2074C El-2 7/11/88 SL-4769 l

700775

Georgia Power b ENCLOSURE I (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

SECONDARY CONTAINMENT BOUNDARY REQUIREMENTS BASIS FOR CHANGE RE00EST Basis for Prooosed Chanae 1: (Continued)

Also, to insure proper secondary . containment integrity is maintained, the Unit 1 main equipment hatch located on the refueling floor will be closed and sealed. A personnel airlock, with interlocked doors, will be constructed to permit access to the refueling floor. Other accesses to the refueling floor will .be locked closed and made airtight. Floor and wall penetrations and drain lines will be sealed where appropriate.

PROPOSED CHANGE 2:

This change will correct the following three editorial errors.

1. Hording in Specifications 4.7.C.I.a and 4.7.C.2.a will be revised for clarification purposes.

2. Specification 4.7.C.1.b appears twice and will be deleted in one instance.

3. Existing specifications 3.7.C.2 and 4.7.C.2 will be renumbered 3.7.C.3 and 4.7.C.3, respectively, on page 3.7-13 to correct a numbering error.

Basis for Procosed Change _2: 1 1

Existing Technical Specifications 4.7.C.l.a and 4.7.C.2.a require a preoperational secondary containment capability test be conducted. The word "preoperational" conveys a preoperating license condition carry-over which is not intended. By deleting the word "preoperational" from both specifications, confusion will be eliminated. 1 Specification 4.7.C.I.b, page 3.7-13, should be deleted since the identical material is stated on page 3.7-12.

Specifications 3.7.C.2 and 4.7.C.2, page 3.7-13, are numbered . incorrectly.

They should be numbered 3.7.C.3 and 4.7.C.3, respectively, since Specifications 3.7.C.2 and 4.7.C.2 are properly located on page 3.7-12a.

These numbering errors were inadvertently introduced when the Plant Hatch Unit 1 Technical Specifications Amendment No. 100 was issued.

2074C El-3 7/11/88 SL-4769

Georgia Powerkh F

5 l<h 2

FILTERS FANS

~~ g

+ -

-l l CP+ 'Ix ,

+:: : ca+

4 d l "J _

i

"" j I I 1 2 RCFUELING FLOOR i_ , I i r l r r _ _ _ _ _ _4 ,_7 m _____a -

r l

! (i

1. ~~

T l

l (mT li

-r

- = ,

i i i o

' I l 1 i l I

' l l l I

/ , t j ) s i rgrae

_r l.' \ l l 1 ,

^s /^4 l b v/ i) t_________1__________

UNIT I RX BLDG UNIT 2 RX BLDG FIGURE 1 l NORMAL CONFIGURATION 2074C El-4 7/11/88 SL-4769 rwm l

Georgia Power d i

F x l N

s FILTERS FANS 5

+ __

l l@ $ '

~~

+ -

l l CP+  :

n d b l i-l. INSTALL AIRLOCK - 2. CLOSE HATCHES p_ ___________ ._ _ _ _ _ _ _ _ _ ,

! ~

1

;= l M l

r REFUELING FLOOR f 4

,=

, 4 l r_[__ _ _s r_ 7 4 s_____a 7

.h

- 1 s I

_  ! r3 l r _s3 p, vd.

l l i j  ! i m i\ I, 7, I l l l l i= ! IcPl+-

N\ pp' / \ l / \r, ,j h'!"' I 5 w&,V^'6k._)O l dx_)6' S l

( SE DETAIL' A" ) L_________.L_________J UNIT I RX BLDG UNIT 2 RX BLDG FIG'JRE 2 (SHEET 10F 2)

PROPOSED HODIFIED CONFIGURATION Note: This configuration may be used only when the conditions contained in proposed Technical Specification section 3.7.C.2 are satisfied.

2074C El-5 7/11/88 SL-4769 F00??$

Georgia Power A 1

TO STAN0er GAS TMAT!KMT Sri l l

l

[

W  % F032A i

I i

'R' $ FROM U.l n

WF0328 lU 1

l 1

l

lAl lAl F33GA # F334A F335A F3368  % F3348 lAl lAl F3358 g C

0

% F313 M lMN F320 F319 4 1 w a w a l d b  % F340 F34l 1

lAl lAl u-t l

F337A  % F332A F333A DRYWELL l F3373 . % F3328 lAl lAl F3338 x

-)( F312 wN F326 P.18 w a .,

r , r , U"1

%F338 F339 i TORUS

% DEN 0TES VALVES TO BE CLOSED AND TAGGED QUT.\

DETAI L 'A' FIGURE 2 (SHEET 2 0F 2)

PROPOSED H00IFIED CONFIGURATION 2074C El-6 7/11/88 SL-4769 700775

... r-GeorgiaPower b ENCLOSURE 2 PLANT: HATCH - UNIT 1 NRC DOCKETS 50-321 0PERATING LICENSE'DPR-57 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

SECONDARY CONTAINMENT BOUNDARY-REQUIREMENTS.

10 CFR 50.92 EVALUATION PROPOSED CHANGE 1:

This change will revise the Plant Hatch Unit 1 Technical Specifications pertaining to secondary containment boundary requirements. The change will establish two modes of secondary containment to facilitate activities during outage situations. Under "modi fi ed" secondary ; containment conditions,  ;

Unit _1 secondary containment will be defined as the area above ,the refueling floor common to Units 1 and 2, allowing fuel-handling activities and Unit '2 reactor operation to continue during a Unit 1 outage. The modi fied' configuration is permissible only under the conditions specified by 3.7.C.2.

Basis for No Signifirant Hazards Consideration Determination:

Proposed Change 1 does not involve a significant hazards consideration for the following reasons:

1. It does not involve a significant increase in the- probability or consequences of an accident previously evaluated, because .the basic function of the Unit I secondary containment system,- which = is to maintain a 1/4-inch negative pressure on the commos Unit I and Unit 2 area above the refueling floor, remains unchanged in the modified configuration. Therefore, refueling activities and Unit 2 reactor operation are permitted to continue without- invoking a limiting condition for operation (LCO).

2. It does not create the possibility of a new 'or different' kind of accident from any previously evaluated, because the modified configuration will exclude the Unit 1 - reactor building area- below the refueling floor and SGTS suction to 'that area so that secondary containment . integrity in the common area above the refueling floor can be maintained. This condition is permissible only under conditions specified by 3.7.C.2, since Unit 1 activities that may lead to a postulated release of radioactivity during a Unit I refueling outage will be confined to -the common refueling floor area. Therefore, under certain conditions, SGTS service is not required in. the Unit I reactor building area below the refueling floor.

2074C E2-1 7/11/88

. SL-4769 700??$ '

. . - _ . ,m._.-.. ,,._ _ , . __ _ . . . _ _ . _ , . . . _ . . _ . _ , _ _ , - . . . _ _ . __ - . _

Georgia Power d ENCLOSURE 2- (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

SECONDARY CONTAINMENT BOUNDARY REQUIREMENTS 10 CFR 50.92 EVALUATION Basis for No Significant Hazards Consideration Determination: (Continued)

3. Tia proposed change does not involve a reduction in the margin of safety, because secondary containment integrity for the modified configuration will continue to maintain the capability to obtain a 1/4-inch water gauge negative pressure in secondary containment.

Therefore, the radiological- consequences to the environment following a postulated refueling accident are not increased.

PROPOSED CHANGE 2:

Proposed Change 2 will correct the following three editorial errors:

1. Hording in Specifications 4.7.C.1.a and 4.7.C.2.a will be revised for clarification purposes.

2. Specification 4.7.C.1.b appears twice and will be deleted in one instance.

3. Existing specifications 3.7.C.2 and 4.7.C.2 will be renumbered 3.7.C.3 and 4.7.C.3, respectively,on page 3.7-13 to correct a numbering error.

Basis for No Sianificant Hazards Consideration Determination:

Since these changes are editorial in nature, they do not involve a significant increase in the probability or consequences of an accident ,

previously evaluated, do not create the possibility of a new or different  !

kind of accident from any previously evaluated, nor involve a reduction in the margin of safety.

i 2074C E2-2 7/11/88 SL-4769 700775