ML20199B585

Forwards Detailed Info Re Tech Spec Improvement Program for Review Prior to Meeting,Per 860520 Request

ML20199B585
Person / Time
Site:	Hatch
Issue date:	06/10/1986
From:	Gucwa L GEORGIA POWER CO.
To:	Muller D Office of Nuclear Reactor Regulation
References
0567C, 567C, SL-830, NUDOCS 8606170176
Download: ML20199B585 (8)

Text

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Georgia Fbwer Company o 333 Piedmont Avenue Atlanta Georgia 30308 Telephone 404 526-6526 Mailing Address:

Post Office Box 4545 Atlanta, Georgia 30302 Georgia Power t!e soot!vm enctoc sr, tem L. T. Gucws Manager Nuclear Safety and Ucensing SL-830 0567C June 10,1986 Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 Division of Boiling Water Reactor Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN 1. HATCH NUCLEAR PLANT UNITS 1, 2 MEETING TO DISCUSS TECHNICAL SPECIFICATIONS IMPROVEMENT PROGRAM Gentlemen:

In a letter dated April 22, 1986, Georgia Power Company (GPC) requested that a meeting be scheduled to discuss our present plans to develop new Technical Specifications for Plant Hatch. As discussed in a telephone conversation with Mr. George Rivenbark of the NRC on May 20, 1986, successful implementation of this program will entail a significant expenditure of manpower and resources on the part of both GPC and the NRC. Because of the importance and the long-term ramifications of this program, GPC requests that the NRC personnel attending the meeting provide feedback regarding the acceptability of the various program elements and resources required to review the various submittals.

Mr. Rivenbark requested that additional detailed information regarding the program be submitted prior to the meeting, thereby allowing the NRC time to consider the acceptability of the program elements. The additional information is enclosed.

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Georgia Power A Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 June 10,1986 Page Two If you have questions regarding this matter, please contact Mr. J. D.

Heidt at (404) 526-4530 Sincerely, f &c _ ,

L. T. Gucwa JDH/lc Enclosure c: Georgia Power Company Nuclear Regulatory Commission Mr. t. P. O'Reilly Dr. J. N. Grace, Regional Administrator Mr. J. T. Beckham, Jr. Senior Resident Inspector Mr. H. C. Nix, Jr.

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Georgia Power A ENCLOSURE EDWIN I. HATCH TECHNICAL SPECIFICATIONS IMPROVEMENT PROGRAM

Background

From an industry point of view, Technical Specifications improvements have been needed for some time. Technical Specifications problems were identified during the industry's meeting with Mr. Denton of the NRC and his staff on March 1, 1985. Typical problem areas include Limiting Conditions for Operation (LCOs) on the following:

Systems that have minimal safety impact.

Surveillance intervals that are overly restrictive.

Allowable outage times that compromise overall plant safety.

Unnecessary design information and programmatic details contained within the Technical Specifications.

In further support of the need for Technical Specifications improvements, several problems were identified by NUREG-1024 The Technical Specifications for Pl ant Hatch exhibit the typical aforementioned problems and additionally, are presented in two different formats; that is, Unit 1 is presented in a custom format, and Unit 2 is presented in the standard format. Improving the Plant Hatch Technical Specifications and achieving a common format for both units are high-priority items for GPC.

Format and Content Georgia Power Company has been deeply involved in the ongoing NRC/ industry efforts to simplify plant Technical Specifications. The NRC/ industry efforts are aimed toward improving the plant Technical Specifications by:

1. Deleting the items which are of lesser safety significance (or are programmatic), thus enabling the reactor operator to focus his attention on those items which are of a more immediate safety concern. The net effect of this change is to enhance overall plant safety.

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Georgia Power d ENCLOSURE (Continued)

EDWIN I. HATCH TECHNICAL SPECIFICATIONS IMPROVEMENT PROGRAM i 2 Rewriting the Bases sections so that the need for the Technical Specifications is clearly defined. Adequate Bases tend to minimize confusion regarding the Technical Specifications requirements, with the net effect being an overall improvement in plant safety.

3 Utilizing human factors to make the Technical Specifications more user friendly.

Georgia Power Company believes that Plant Hatch is an ideal candidate for a " lead plant" application, as described in the NRC letter from D.

Eisenhut to the Chairman, AIF Technical Specifications Subcommittee, dated May 5,1986. Georgia Power Company is willing to coordinate this effort with the BWR Owners' Group (BWROG) and is willing to start work immediately, pending NRC agreement with our overall concept.

RPS/ECCS BWROG Improvements During late 1983, the BWROG formed a Technical Specifications Improvement (TSI) Committee. This committee subsequently established a program for the development of reliability analyses to identify improvements in test intervals and allowable out-of-service time specified in the BWR Standard Technical Specifications. The primary objective of revising the Technical Specifications was to minimize unnecessary testing and excessively restrictive out-of-service times that could potentially degrade the overall plant safety and availability. Examples of some of the problems experienced with current Technical Specifications are as follows:

Inadvertent scrams due to frequent testing.

Allowable downtimes which do not permit sufficient time for performing repairs on a reasonable basis.

Excessive actuation of equipment, contributing to wearout.

High-radiation exposure to personnel performing the testing.

The BWROG submitted three documents to the NRC in support of relaxing the ECCS/RPS Technical Specifications:

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Georgia Power A ENCLOSURE (Continu d EDWIN I. HATCH TECHNICAL SPECIFICATIONS IMPROVEMENT PROGRAM

1. Report Responding to NRC Generic Letter 83-28, Item 4.5.3 - This report, NEDG-3UBB4, which provided the reliability basis for existing RPS test intervals and allowable out-of-service times, was submitted to the NRC during January 1985. The report addressed uncertainties, reduced redundancy during testing or repair, operator errors, and component wearout.

2 Report on RPS Technical Specifications Improvement - This report, NEDC-30851 -P , dated May 1985, provides the base-case model for analyzing improvements to RPS test intervals and out-of-service times.

3 Report on ECCS Technical Specifications Improvement -

This report, NEDC-30936-P, dated November 1985, provides the representative BWR reliability models and methodology guidelines for establishing ECCS Technical Specifications changes. A demonstration case using ECCS instrumentation test interval and allowable out-of-service time is provided for each BWR product line.

Information contained in the three reports provides the basis for making improvements to the BWR RPS/ECCS Technical Specifications.

The overall effect of these Technical Specifications changes is to

! provide an increase in safety and improve plant operation. The l improvement is achieved by reducing the potential for:

1. Unnecessary plant scrams. (The changes reduce challenges to plant shutdown systems and improve plant availability).

2 Excessive test cycles on equipment. (The changes reduce wearout potential).

l 3 Diversion of plant personnel and resources to unnecessary l testing. (The changes enhance potential safety and operational

! improvement).

SAFER /GESTR I Georgia Power Company has recently purchased an Appendix K software analysis program (SAFER /GESTR) from General Electric. When compared to the older analytical models, the NRC-approved LOCA analysis models (SAFER l

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Georgia Power 1 ENCLOSURE (Continued)

EDWIN I. HATCH TECHNICAL SPECIFICATIONS IMPROVEMENT PROGRAM and GESTR) significantly decrease the calculated peak clad temperature (PCT) during the performance of required Appendix K LOCA evaluations.

The SAFER /GESTR models allow GPC to use new high-exposure, high-enrichment fuel which increases fuel cycle length. The added PCT margin can be used to increase plant operating flexibility, since PCT is virtually eliminated as a design consideration.

The SAFER /GESTR program will provide (at a minimum) the following:

1. Removal of PCT limitations on currently used fuel designs (13.4 kW/ft) and on new fuel designs (14.4 kW/ft). The fuel performance will be limited only by its thermal-mechanical design.

2 ECCS calculations which are valid for a variety of GE fuel and lattice types. New ECCS thermal limit calculations will not have to be performed each reload cycle. This should lead to a reduced reload licensing effort and simplified Technical Specifications.

3 A PCT margin to accommodate potential future plant changes or problems.

Based upon commercial considerations for potential future programs, GPC intends to have the baseline analysis performed with the following nonstandard initial conditions:

1. The initial power level will be consistent with that achievable for a power uprate program similar to the program recently performed (and approved by the NRC) for the Duane Arnold Plant.

2 Some selected equipment will be assumed to be inoperable or operating in a degraded condition. General Electric is in the process of running sensitivity analyses to determine the PCT impact of the following abnormal initial conditions:

Relaxed system or component performance requirements, e.g., longer valve stroke times or longer diesel-generator startup time.

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GeorgiaPower d ENCLOSURE (Continued)

EDWIN I. HATCH TECHNICAL SPECIFICATIONS IMPROVEMENT PROGRAM Relaxed instrument setpoints, e.g., water level setpoints or pressure permissive setpoints.

Continued power operation with ADS valve ( s) , MSIVs, and/or RHR pumps out of service.

Continued power operation with either the low-pressure or the high-pressure ECCS components out of service.

Once the sensitivity studies are complete, GPC will select the items to be included in the baseline analysis as a portion of the E q u i pme n t-o u t-o f-S e rvi c e/D e g ra de d Performance portion of the Technical Specifications Improvement Program.

Equipment-out-of-Service / Degraded Perf ormance Hi storically, when equipment is operating in a degraded or failed condition, continued plant operation is achievable provided:

1. Analyses are performed to determine the impact of the degraded / failed equipment on the safety anal These analyses include the impact on LOCA, ysis of the plant.MCPR, containm material stresses, fatigue, etc.

2 NRC approval to operate in the degraded condition is obtained.

Typically, these analyses demonstrate that the plant can continue operation, without exceeding applicable safety limits, at some reduced l power level . Frequently, because of NRC or ASME Code,Section XI, requirements, additional surveillance is required when operating in these degraded conditions. Having Technical Specifications in place to accommodate these situations presents the following advantages

1. The necessity of performing expedited reviews in response to requests for emergency Technical Specifications relief is obviated for those items that would be included in the Technical Specifications.

2 Repair / replacement activities can proceed in an orderly manner.

3 Unnecessary plant shutdowns can be avoided.

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Georgia Power A ENCLOSURE (Continued)

EDWIN 1. HATCH TECHNICAL SPECIFICATIONS IMPROVEMENT PROGRAM As previously stated, continued operation with failed / degraded equipment is dependent upon assuring that applicable safety criteria, including LOCA considerations, are not violated. The inclusion of the failed / degraded conditions in the baseline SAFER /GESTR analysis is more economical in evaluating the LOCA impact than in performing individual analyses and hence, is preferred. We believe that the integration of

' these failed / degraded conditions will significantly reduce the licensing burdens of both the NRC and GPC.

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