ML20205H818

Application for Amend to License NPF-5,revising Tech Specs to Adjust Setpoints for Main Steam Line Radiation Monitor Instruments to Allow Performance of Tests of Hydrogen Injection Into Primary Coolant.Fee Paid

ML20205H818
Person / Time
Site:	Hatch
Issue date:	03/20/1987
From:	James O'Reilly GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20205H824	List: ML20205H818 ML20205H831
References
SL-2126, NUDOCS 8704010154
Download: ML20205H818 (10)

Text

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GeorQG Ibwer Company 333 Pc1mont Avenue

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IE>r*v$c$r9'eTEen Nuclear Operatuans SL-2126 1197C March 20,1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN 1. HATCH NUCLEAR PLANT UNIT 2 PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS TO SUPPORT HYDROGEN INJECTIDN TEST 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 prcposes changes to the Technical Specifications, Appendix A to Operating License NPR-5.

The proposed changes would make the necessary adjustments to setpoints for the Main Steam Line Radiation Monitor (HSLRM) instruments as described in Tables 3.2.1 -1, 3. 3.1 -1, 3.3.2-1, 3.3.2-2, 3.3. 6.7-1, and 3.3.6.7-2, to allow performance of tests of hydrogen injection into the primary coolant. These tests will provide further information to augment the Unit I test series results as a prelude to installation of a permanent hydrogen injection system. In order to support test schedulos, NRC approval of this submittal is requested as soon as possible. This same change has been requested and granted for many BWRs including Plant Hatch Unit 1.

A typographical error in Table 3. 3. 6. 7 -1 is also proposed for correction.

Attachment I providos a detailed description of the proposed changes and circumstances necessitating the chango request.

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

Attachment 3 provides page chango instructions for incorporating the proposed changes.

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U. S. Nuclear Regulatory Commission March 20, 1987 Page Two The proposed changed Technical Specifications pages follow Attachment 3.

Payment of filing fee is enclosed.

Pursuant to 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. James P. O'Reilly states that he is Senior 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 this letter are true.

GEORGIA POWER COMPANY By: m uf C 90 $_ R i Jane P. O'Reilly Sworn to and subscribed before me this 20th daysof_ larch,1987.

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Enclosures c: Georgia Power Company U. S. Nuclear Regulatory Comission lir. s . T. Deckham, Jr. Dr. J. H. Grace, Regional Administrator Mr. H. C. Nix, Jr. Mr. P. Ilolmes-Ray, Senior Resident GO-NORitS Inspector - Hatch Mr. G. Rivenbark, Licensing Project Manager - ifatch 1197C

L ATTACHMENT 1 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS TO SUPPORT HYDROGEN INJECTION TEST PROPOSED CHANGE 1: Many BWRs are evaluating hydrogen water chemistry (HWC) as a potential mitigator of intergranular stress corrosion cracking (IGSCC) of stainless steel piping. Prior to installation of an HWC system, it is desirable to perform test injections. These tests provide information relative to required hydrogen flow rates and corresponding radiation increases within affected areas of the plant. Performance of these test injections requires changes to the Technical Specifications (TS).

Georgia Power Comaany has performed test injections on Plant Hatch Unit 1. Preliminary tnformation from the Unit 1 test sequence indicates that hydrogen injection rates necessary to achieve appropriate reductions in Electrochemical Potentials (ECP) are somewhat higher than expected.

(As requested in NRC's letter of May 21 , 1986, which transmitted Amendment 125 to the Unit 1 TS, a radiological assessment of the Unit 1 test effort will be provided to NRC under separato lotter. )

Correspondingly, shielding requirements to support a permanent installation are greater than anticipated. GPC now desires to perform a longer term injection test to determine if smaller hydrogen injection rates can provide effective mitigation of IGSCC. This will be evaluated through analysis of a stainless steel sample which has been exposed to the Unit 2 operating reactor coolant environment at a lower hydrogen injection rate, and for a longer time, than was employed for the Unit I test. It is desired to show that lower hydrogen injection ratos will produce accatable mitigation of IGSCC without incurring the radiation levels exper enced in the Unit I test. A permanent HWC system based on the lower injection rate would provide for lower plant radiation levels and require less extensive shielding additions. It is desired to perfona this test on Unit 2 since Unit I will be entering a refueling outage in late April, llydrogen will be trucked to the site for performance of these tests. As required by 10 CFR 50.59, a sosarate safety analysis will be prepared for any permanent install ation and Technical Specifications changes supporting permanent HWC installation would bo sought at that timo.

The test, which is performed with the assistance of General Electric, involves injecting hydrogen into the feedwater system at prodotermined increments when the plant is abovo 90 percent power. No increment is large enough to result in an unexpected chango in any plant parameter.

1197C El-1 3/20/87

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ATTACHMENT 1 PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS TO SUPPORT HYDROGEN INJECTION TEST Lessons learned by General Electric from previous pre-implementation tests at other plants and at Plant Hatch Unit I will be incorporated into the procedures for the test.

Extensive ALARA measures will be implemented for the duration of the test. The conduct of the test and radiological surveys during the test.

will ensure minimal increases in occupational exposure. Lessons learned during the Unit 1 test will be employed to ensure ALARA measures are mot.

The following paragraphs describe details of the radiation survey program to be followed for implementation of the test. Similar information was requested by NRC to support issuance of the TS amendment allowing HWC testing on Plant Hatch Unit 1.

A plant procedure addressing radiation and contamination surveys providos survey points for all potentially radioactive areas of the plant. This procedure is used in the development of the Hydrogen Water Chemistry Mini-Test procedure, which covers all phascs of test implementation and provides survey points to be used in the test. These specific survey points are determined in conjunction with General Electric using lessons learned from previous hydrogen water chemistry tests at other sitos and Plant Hatch Unit 1. Plant Hatch ALARA personnel are consulted for plant-specific details. In general, higher radiation levels are expected in those areas of the plant containing main steam piping or equipment, such as the turbino dock.

Any changes in radiation levels within the plant will be monitored by site personnel using conventional instruments. For survey points outside plant structures, a high-pressure ionization chamber will be used. The equipment for those exterior surveys util be operated by site (GPC) personnel under the direction of General Electric. All survey points will be individually marked to ensure that ongoing survey measurements are taken for the same locations. Roactor coolant samples will be analyzed and changes in chemistry monitored and recorded.

Standard Health Physics procedures will be followed, with additional personnel access limited during the test injections to minimize exposure due to changing radiation ficids. Personnel not associated with the test impicmentation or associated radiation measurements will be restricted from areas of potential increased radiation levels. generally In addition to the existing main steam line radiation monitor (MSLRM), additional remote nonitors (GH-Tube) will be placed on the turbine dock and in the condenser bay to dotect any changes in radiation 1197C El-2 3/20/87

ATTACMENT 1 PROPOSED CHANGE TO ' TECHNICAL SPECIFICATIONS TO SUPPORT HYDROGEN INJECTION TEST l

l l fields in these areas. As these are normally high-radiation areas, they l are not routinely monitored, in accordance with' ALARA goals to minimize radiation exposure to workers and Health Physics technicians.

As was the case for Plant Hatch Unit 1 (License Amendment 125),

l l performance of the hydrogen injection tests will require temporary l adjustments to setpoints and associated Technical Specifications. For L

Plant Hatch Unit 2, notes are proposed' for tables describing applicable l operational conditions, and setpoints, for instruments which provide reactor scram, containment-isolation, and Main Control Room Environmental

! System (MCRECS) activation on Main Steam Line - high radiation (TS Tables

3. 2.1 -1, 3.3.1 -1, 3. 3.2-1, 3.3.2-2, 3.3.6.7-1, and 3.3.6.7-2) . The notes j proposed for addition to the Technical Specifications will allow this l

adjustment only when above 20 percent rated power. The adjustments will allow for higher " background" MSL radiation setpoints during test periods of hydrogen injection to account for increased levels of short half life N-16 carryover into main steam. Hydrogen addition will result in an approximate 3 to 8-fold increase in the N-16 activity in the steam. The resultant increase in the background radiation level necessitates the l change to the Main Steam Line Radiation Monitor scram and isolation i setpoints.

The current setpoints are less than or equal to 3 times normal rated i power background. The only design basis accident which takes credit for main steam isolation valve (MSIV) closure on Main Steam Line high radiation is the design basis control rod drop accident (CRDA) (Hatch l Unit 2 FSAR Section 15.1.38). The CRDA is only of concern below 10 l percent of rated power. Since the current MSLRM setpoint will not be ,

changed when at or below 20 percent rated power, the MSLRM sensitivity to fuel failure is not impacted and the FSAR analysis for the CRDA remains valid.

1 A temporary increase in the Main Steam Line high radiation scram and isolation setpoints will not impact any other HNP-2 FSAR Chapter 15 accident or transient analyses since no credit is taken for this signal.

Consequently, the Technical Specifications exception to allow for an increase in the setpoints during hydrogen injection will not reduce overall plant safety margins. The Technical Specifications exception, which is added as a note to the affected tables, is as follows:

"Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to the planned start of the hydrogen injection test with the reactor power at greater than 20 percent rated power, the normal full power radiation background level and associated trip setpoints may be changed based on a calculated value of the radiation 1197C El-3 3/20/87

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b- l ATTAC MENT 1

..  : PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS TO SUPPORT HYDROGEN INJECTION TEST level expected during the test. The background radiation level and associated ! trip setpoints may be adjusted during the test' based on C either calculations or measurements of actual radiation levels resulting from hydrogen injection. -The background radiation level shall be determined, .and associated trip setpoints shall be ^ set within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of re-establishing normal radiation - levels after completion of hydrogen injection and prior to establishing reactor power levels below 20 percent rated power."

If, due to ~ a recirculation pump trip or other unanticipated . power reduction event, the reactor ~ drops below 20 percent rated power without setpoint readjustment, control rod withdrawal will be prohibited by procedures _ until the necessary setpoint readjustment is made. This ensures that fuel failures of the type concerning the MSLRM (specifically FSAR CRDA analysis) are unlikely.

The MSLRM also performs a general function of monitoring for failed fuel. This capability to monitor fuel failures is retained with the adjusted radiation " background" setpoint. Additionally, this capability is provided through the offgas radiation monitor, performance of primary coolant. analyses, and routine radiation surveys.

v PROPOSED CHANGE 2: Table 3.6.7-1 which was added as part of Amendment 71, describes instruments which actuate- the Main Control Room Environmental Control System (MCRECS). Item 6 " Control Room Air Inlet Radiation-High", of Table 3.3.6.7-1, contains a typographical error which is hereby proposed for correction. GPC's submittal of November 10,'1986

}; submitted changes to (MCRECS) Technical Specifications which resulted in issuance of Amendment 71. Part of this change moved the requirements for the control room air inlet radiation detectors, which actuate the control room pressurization mode'of MCRECS, ,from previous TS 4.7.2.e.3.g, to Item 6 of new table 3.3.6.7-1. .,This was strictly an administrative change.

.However, through a typographical error, Item 6 of Table 3. 3. 6. 7-1 incorrectly specified note (d). rather than note (c). Note (d) indicates

,y- that the subject instrument actuates the control room isolation mode of

MCRECS. The correct note is (c), which specifies that the control room pressurization mode is actuated. We now request, as an administrative changeggthat the previous and correct information be returned to the TS.

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t 1197C El-4 3/20/87

ATTACHMENT 2 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS TO SUPPORT HYDROGEN INJECTION TEST Fursuant 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. The basis for this determination is as follows:

PROPOSED CHANGE 1: Provide for temporary adjustments to setpoints for the Main steam Line Radiation Monitor (MSLRM) to accommodate tests of hydrogen injection.

Basis for proposed change 1: Performance of the hydrogen injection tests will require temporary adjustments to setpoints and associated Technical Specifications. For Plant Hatch Unit 2, notes are proposed for tables setpoints, describing applicable operational conditions, and for instruments which provide reactor scram, containment isolation, and Main Control Room Environmental System (fiCRECS) activation on Main Steam Line high radiation (TS Tables 3.2.1-1, 3. 3 .1 -1, 3. 3. 2-1, 3.3.2-2, 3.3.6.7-1, and 3.3.6.7-2). The notes proposed for addition to the

. Technical Specifications will allow this adjustment only when above 20 percent rated power. The adjustments will allow for higher " background" liSL radiation setpoints during test periods of hydrogen injection to account for increased levels of short half life N-16 carryover into main steam. Hydrogen addition will result in an approximate 3 to 8-fold increase in the N-16 activity in the steam. The resultant increase in the background radiation level necessitates the change to the Main Steam Line Radiation Monitor scram and isolation setpoints.

The current setpoints are less than or equal to 3 times normal rated power background. The only design basis accident which takes credit for main steam isolation valve (MSIV) closure on Main Steam Line high rattiation is the design basis control rod drop accident (CRDA) (Hatch Unit 2 FSAR Section 15.1.38). The CRDA is only of concern below 10 percent of rated power. Since the current MSLRf1 setpoint will not be '

changed when at or below 20 percent rated power, the MSLRM sensitivity to fuel failure is not impacted and the FSAR analysis for the CRDA remains valid.

A temporary increase in the Main Steam Line high radiation scram and isolation setpoints will not impact any other HNP-2 FSAR Chapter 15 accident or transient analyses since no credit is taken for this signal.

1197C E2-1 3/20/87

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ATTACH 4ENT'2.

PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS TO SUPPORT HYDROGEN INJECTION TEST Consequently, the Technical Specifications exception to allow . for ' an increase in the setpoints during hydrogen injection will not reduce-overall plant safety margins.

Accordingly,- Georgia Power . Company has reviewed the proposed

. temporary changes and has determined they do not involve a significant hazards consideration for the following reasons:

, 1. The proposed changes do not significantly increase the probability or consequences of an accident previously evaluated because operability of the MSLRM is required for compliance with the accident- analysis only when below 10 percent rated power.

This change is effective only when above 20 percent power.

2. -The proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated because this change allows for setpoint changes only during periods of hydrogen injection testing.

3. The proposed changes.do not involve a significant reduction in a margin of safety because the function of the MSLRM will be preserved.

PROPOSED CHANGE 2: Correct typographical error in Table 3.3.6.7-1.

Basis for proposed change 2: This change is consistent with Item (i) of the " Examples of Amenaments That are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the Federal Register, April 6,1983. Example -(i) of actions involving no significant hazards consideration is a purely administrative change; for example,

, correction of an error. This change corrects a typographical error which was introduced through Amendment 71. The proposed change corrects a note which was incorrectly specified in the submittal resulting in Amendment 71 . This change was not intended or addressed in that submittal.

Georgia Power Company has reviewed the proposed change and has determined it does not involve a significant hazards consideration for the following reasons:

1. The proposed change does not significantly increase the 1197C E2-2 3/20/87 -

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. ATTACHMENT 2 PROPOSED CHANGE TO TECHNICAL- SPECIFICATIONS TO SUPPORT HYDROGEN INJECTION TEST probability or consequences of an accident previously evaluated because plant operation is not affected by this entirely administrative change.

2. The proposed change does not create the possibility of a new or different kind of accident from any _ accident previously evaluated because this change does not affect plant operation.

3. The proposed change .does not involve a significant reduction in a margin of safety because it is purely administrative in nature and plant operation is not affected.

I 1197C E2-3 3/20/87 i l

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ATTACHMENT 3 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN 1. HATCH NUCLEAR PLANT UNIT 2 PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS TO SUPPORT HYDROGEN INJECTION TEST The proposed changes 7to the Technical Specifications ( Appendix A to Operating License NPF-5) would be incorporated as follows:

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