ML20154D087

Application for Amend to License DPR-57,revising Tech Spec to Redefine Definitions of Hot & Cold Shutdown So Changing Operational Condition Modes When Test Being Performed Above 212 F Will Be Unnecessary.Fee Paid

ML20154D087
Person / Time
Site:	Hatch
Issue date:	09/06/1988
From:	Hairston W GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20154D092	List: ML20154D087 ML20154D094
References
HL-41, TAC-69408, NUDOCS 8809150141
Download: ML20154D087 (9)

Text

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Attanta, Georg a 30306

. Te'ept%e 404 52465 '6 Mad.ng Adiew Fbst Off:ce Box 4545 Atlanta, Georgia 30302 Nn?o??e'O?e%nt N.,Cle& ' Operations HL-41 2111C X7CJ17-H600 September 6, 1988 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C. 20555 PLANT HATCH - UNIT 1 NRC DOCKET 50-321 OPERATING LICENSE DPR-57 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

HYDROSTATIC AND LEAK TESTING MQYE 212*F USING NON-NUCLEAR HEAT Gentlemen:

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

The proposed changes are related to the required reactor vessel system hydrostatic / leakage pressure testing with a non-critical reactor core at reactor coolant temperatures above 212*F. The changes supplement GPC's original Unit I submittal for allowing non-nuclear heat hydrostatic testing, which was provided to the NRC on March 4, 1987, and implemented in the Unit 1 Technical Specifications as Amendment 137. The proposed changes redefine the definitions of Hot and Cold Shutdown, so changing Operational Condition modes when the test is being performed and the coolant temperature is above 212'F will be unnecessary. The changes, if approved, will be consistent with the Unit 2 Technical Specifications (Amendment 91).

Enclosure 1 provides the detailed description of the proposed changes and the bases for the change request.

Enclosure 2 details the bases vor our determination that the proposed changes do not involve significant hazards considerations, j kh ge

,. .et Georgia Power d U.S. Nuclear Regulatory Commission September 6, 1988 Page Two Enclosure 3 provides page change instructions for incorporating the proposed changes into the Plant hatch Unit 1 Technical Specifications. '-

The proposed changed Technical Specifications pages follov Enclosure 3. i Payment of a filing fee in the amount of one hundred and fifty dollars is enclosed.

To sllow time for procedure revisions and orderly incorporation into copies Of the Technical Specifications, GPC requests the proposed amendment, 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.

The changes described in Enclosure 1 are necessary to facilitate the startup of Plant Hatch Unit I from the upcoming refueling outage which is schedule'i to begin September 28, 1988. Without approval of these changes, the required hydrostatic / leakage tests, which are performed on critical path, will take longer and result in capacity factor losses.

Therefore, GPC requests priority approval of the proposed changes by November 11, 1988.

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 is authorizt to execute this oath on behalf of Georgia Power Company, and to the besc of his "nowledge and belief, the facts set forth in this letter are true.

GEORGIA POWER COMPANY By: d h

• t H. G. Hairston, III

! Sworn to and subscribed before me this 6th day of September 1988.  !

/ Sub Wd /

g / Notary Public

% % ce66 cower, a.,

GKH/ac Mr t-- . ' :ss u ,, p ean

Enclosures:

(See next page.) ,

c: (See next page.)

2111C l

c' .4 GeorgiaPower A U.S. Nuclear Regulatory Commission September 6, 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. H. C. Nix, Jr., General Manager - Plant Hatch Mr. L. T. Gucwa, Manager, Licensing and Engineering - Hatch GO-NORMS U.S. Nuclear Regulatory Commission. Washinaton. D.C.

Mr. L. P. Crocker, Licensing Project Manager - Hatch U.S. Nuclear Reaulatorv Commission. Reaion li Dr. J. N. Grace, Regional Administrator Mr. J. E. Henning, Senior Resident Inspector - Hatch State of Georgia Mr. J. L. Ledbetter, Commissioner - Department of Natural Resources l

c 2111C

j .' ,; i Georgia Power 1 ENCLOSURE 1 PLANT HATCH - UNIT 1 NRC DOCKET 50-321 OPERATING LICENSE DPR-57 REOUEST TO REVISE TECHUCAL SPECIFICATIONS:

HYDROSTATIC AND LEAK TESTING ABOVE 212*F USING NON-NUCLEAR HEAT BASIS FOR CHANGE REOUEST Prior to the last Unit 1 maintenance / refueling outage, Georgia Power Company (GPC) historically used nuclear heat for performance of inservice hydrostatic / leakage pressure tests for the Plant Hatch units. However, the Nuclear Regulatory Commission (NRC) now requires vessel inservice hydrostatic / leakage testing per ASME Code,Section XI be performed prior to the reactor going critical after a refueling outage. The Unit 1 Technical Specifications (TS) changes to support the non-nuclear test were approved by the NRC via Amendn,ent 137, and a leakage test using non-nuclear heat was performed during the last outage. Amendment 137 relaxed requirements on the operability of certain systems and the need to have primary containment integrity during the test when coolant temperature is above 212*F.

When the reactor coolant exceeded the 212*F, however, it was still nacessary to switch Operational Condition modes (i.e., Cold Shutdown to Hot Shutdown). Changing the mode to Hot Shutdown while heating up the vessel for the test involves performing surveillances on equipment which is not needed when the unit is not preparing to start up. Because of this inconsistency, the - L'ni t 2 submittal (approved as Amendment 91) modified the definitions of Cold and Hot Shutdown for hydrostatic / leakage testing and specified components and systems required to be operable.

This proposed changes, if approved, will resolve this inconsistency for Unit 1, in a manner similar to Unit 2 Amendment 91.

PROPOSED CHANGES:

The )roposed changes will modify the definitions of Cold and Hot Shutdown Conditions contained in Unit 1 Technical Specifications Section 1.0.

When determining the ap)licability of Limiting Conditions for Operation (LCO), the revised definitions will allow the average coolant temperature to be above 212*F when performing hydrostatic / leakage tests with all l control rods inserted. Also, LCOs, which specify "when the reactor coolant temperature is less than 212*F", will be interpreted as Cold Shutdown and allow coolant temperatures wove 212*F when performing the tests. For compliance with Technical Specifications Action statements (e.g., "achieve 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 />") on equipment and systems required to be operable for the tests, an Action requiring Cold Shutdown will require a reactor coolant temperature of 1212*F.

2111C El-1 9/06/88 HL-41 l

Georgi..

Power d ENCLOSURE 1 (Continued)

REOUEST TO REVISE TECHNICAL SPECIFICATIONS:

HYDR 0 STATIC AND LEAK TESTING ABOVE 212*F USING NON-NUCLEAR HEAT BASIS FOR CHANGE RE00EST For example, with the revised definitions, the reactor vessel steam dome high pressure scram instrumentation (Table 3.1-1) will not be required during the pressure test, and the Action statement in Table 3.2-1 requiring the Cold Shutdown Condition will not apply. However, if the intermediate range monitor (IRH) high flux scram became inoperable during a test, reducing the coolant temperature to 1212'F would still be required.

Clarifications have also been added to Specifications 3.5.A.2, 3.5.B.l.b.

3.5.B.2c , 3.5.C.2, 3.6.G. 3.7.C. I . a. (7), and to applicable notes in Table 3.2-1. These clarifications supplement the modified definition of Cold Shutdoan by specifing equipment which must be operable during the test and will assure the test will be performed in a safe manner. The changes, if approved, will make the Technical Specifications for Unit 1 more consistent with the Unit 2 Specifications approved in Amendment 91.

A minor editorial change has also been proposed for Unit 1 Specification 4.5.C.2. This change corrects a typographical error by changing "RHR" to "RHR service water" to more accurately represent the intent of the Specification.

BASIS FOR PROPOSED CHANGES:

The systems and components required durig the hydrostatic / leakage tests are similar to those specified in the Unit 2 Technical Specifications (Amendment 11). Having this equipment operable during the test will insure the hydrostatic / leakage pressure test can be performed in a safe manner, without requiring all the components and systems to be operable that are currently necessary prior to reactor startup (i.e., when the reactor is in hot shutdown). Specific comoonents and systems required (in addition to those required for cold shutdown) are discussed below.

The integrity of secondary containment will be required during the test, and, therefore, the operability of the standby gas treatment (SBGT) system and certain instrumentation which initiates SBGT must be maintained. Specifically, Specification 3.7.C.I .a.(7) has been added to require Secondary Containment Integrity, and a note has been added to Table 3.2-1 requiring that the vessel water level (Level 2) instrumentation be operable during the test. Since the SBGT system is operable, the refueling floor and reactor building exhaust vent radiation monitors (Table 3.2-8) will be required. The h',gh drywell pressure scram will not be required, since pr'aary containment integrity is not required. (See Amendment 137 for Unit I and Amendment 91 for Unit 2.)

2111C El-2 9/06/88 <

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Georgia Power A ENCLOSURE 1 (Continued)

RE00EST TO REVISE TECHNICAL SPECIFICATIONS:

HYDROSTATIC AND LEAK TESTING ABOVE 212'F USING NON-NUCLEAR HEAT BASIS FOR CHANGE REOUEST GPC's revised definition of the Cold Shutdown Condition will require operability of the reactor protection system (RPS) scram trip signals (Table 3.1-1) including the mode switch in shutdown, manual scraa, IRH high flux, and scram discharge volume high level. These t,lps are currently required for Cold Shutdown conditions and will also b) required during a leakage test when the reactor coolant temperature exce sds 212*F.

Operability requirements for the auxiliary electrical systet.s including emergency diesel generators, will be as specified in Section 3.9. No changes to the Technical Specifications are required. Specification 3.5.B.1.b has been modified to require one residual heat removal (RHR) loop with two pumpt or two loops with one pump per loop operable in the low pressure coolant injection (LPCI) mode, as well as in the shutdown cooling mode as is presently required. The current Technical Specifications require one RHR service water loop to be operable during the hydrostatic / leakage tests. These systems will be adequate to keep the core cool in the event of a piping system leak, since stored energy in the reactor core and containment will be low under pressure testing conditions.

Operability specifications for conductivity and chloride will be as stated in Specification 3.6.F.2.d. Reactor coolant leakage monitoring (Specification 3.6.G) will not be required, since the hydrostatic / leakage tests are a requirement of ASHE Code,Section XI, and are subject to the criteria specified in the Code for determination of an acceptable test.

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• 9/06/88 HL-41 pp

Georgia Power d ENCLOSURE 2 PLANT HATCH - UNIT 1 NRC DOCKET 50-321 OPERATING LICENSE DPR-57 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

HYDROSTATIC AND LEAK TESTING ABOVE 212'F USING NON-NUCLEAR HEAT 10 CFR 50.92 EVALUATION PROPOSED CHANGES:

The proposed changes add a footnote to Technical Specifications Section 1.0, modifying the Operational Condition definitions of Hot Shutdown and Cold Shutdown during non-nuclear hydrostatic / leak testing per ASME Code,Section XI requirements. The revised definitions will allow for the reactor to be considered in Cold Shutdown during the performance of a test, even when the reactor coolant temperature is above 212'F. The proposed changes also revise Technical Specifications to require secondary containment integrity and to require certain core and containment cooling systems be operable when performing the tests. Since hydrostatic / leak tests are performed water solid with all rods inserted l into the ren' r core at low decay heat values, and at or near Cold Shutdown Condition, the stored energy in the core and containment will be very small. The amount of reactivity contained in any postulater1 steam leak would also be small. Additionally there is a proposed charge that I

clarifies one Specification 4.5.C.2.

Basis for No Significant Hazards Ccnsideration Determing11on:

l The proposed changes do not involve a significant hazards consideration ,

l for the following reasons:

l 1. They do not involve a significant increase in the probability or l consequences of an accident previously evaluated, because the t hydrostatic / leak tests to which these changes apply occur when primary system energy is minimal; all control rods are inserted; and low temperature and low fuel decay heat values are established. Under these test conditions, the systems specified I to be operable will function to ensure a significant increase in the consequences or the probability of an accident will not occur.

2. The proposed changes do not create the possibility of a new or different kind of accident from any previously analyzed, because no change in plant design or operation will occur as a result of the change. The changes described herein apply only to the performance of ASME Code-required hydrostatic or leak testing (with all control rods inserted), and are in addition to those changes granted with Amendment 137.

2111C E2-1 9/06/88 HL-41

y 9

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Georgia Power d ENCLOSURE 2 (Continued)

RE00EST TO REVISE TECHNICAL SPECIFICATIONS:

HYDROSTx7IC AND LEAK TESTING ABOVE 212'F USING NON-NUCLEAR HEAT 10 CFR 50.92 EVALUATION

3. The proposed changes do not involve a.significant reduction in the margin of safety, because plant operation is not affected, and analyzed margins of safety are unchanged.

The proposed editorial change which changes "RHR" to "RHR service water" in Specification 4.5.C.2 corrects a typographical error, and is administrative in nature.

I 2111C E2-2 9/06/88 I HL-41 l l

.s Georgia Power d ENCLOSURE 3 PLANT HATCH - UNIT 1 NRC DOCKET 50-321 OPERATING LICENSE DPR-57 RE00EST TO REVISE TECHNICAL SPECIFICATIONS TO ALLOW PERFORMANCE OF HYDkOSTATIC AND LEAK TESTING ABOVE 212*F USING NON-NUCLEAR HEAT PAGE CHANGE INSTRUCTIONS The proposed change to the Unit 1 Technical Specifications (Appendix A to Operating License DPR-57) will be incorporated as follows:

Remove Page Insert Paae 1.0-1 1.0-1 1.0-2 1.0-2 3.2-4 3.2-4 3.5-2 3.5-2 3.5-3 3.5-3 3.5-4 3.5-4 3.5-5 3.5-5 3.6-7 3.6-7 3.7-12 3.7-12 i

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