ML20206C285

Application for Amend to License NPF-68,revising Tech Spec 3.3.3.6 Re Containment Hydrogen Monitors.Fee Paid

ML20206C285
Person / Time
Site:	Vogtle
Issue date:	11/07/1988
From:	Hairston W GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20206C288	List: ML20206C285 ML20206C298
References
VL-76, NUDOCS 8811160205
Download: ML20206C285 (6)

Text

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i November 7,1988 l.

U. S. Nuclear Regulatory Commission i ATTN: Document Control Desk Washington, D. C. 20555 PLANT V0GTLE - UNIT 1 i NRC DOCKET 50-424 i 0PERATING LICENSE NPF-68 REQUEST TO REVISE TECHNICAL SPECIFICATION 3.3.3.6 '

CONTAI N NT HYOR0 GEN MONITORS [

Gentlemen: -

i l In accordance with the provisions of 10 CFR 50.90 as required by 10 CFR l l 50.59(c)(1), Georgia Power Company (GPC) hereby proposes to amend the Vogtle  !

l Electric Generating' Plant Unit 1 Technica; Specifications, Appendix A to i operating License NPF-68, t The proposed change revises the action requirements for inoperable i containment hydrogen concentration monitors. [

E l

Enclosure 1 provides a detailed descriptfon of the proposed e.hange and the l basis for the change.  ;

Enclosure 2 detatis the basis for our determination that the proposed change does not involve significant hazards considerations. .

Enclosure 3 provides instructions for incorporation of the proposed I amendment into the Technical Specification. The proposed revis 1 pages follow  !

i Enclosure 3. .

In accordance with 10 CFR 170.12, a check for $150.00 is enclosed in  !

payment of the required applicat*on fee. I t

The Vogtle Plant Review Board and the GPC Safety Review Board have f reviewed and concur with this proposed amendment.

3 A copy of this letter and all applicable enclosures will be sent to the l designated state official in accordance with 10 CFR 50.91. t gool 1 esitt6o20s estio7 '

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hDR ADOCK 05000424 gI c L yIGY

deorgia Power d U. S. Nuclear Regulatory Commission November 7,1988 Page Two M r. W. G. Hairston, III states that he is a Senior Vice President of Georgia Power Company and is authorized to execute this esth on behalf of Georgia Power Company and that to the best of his knowledge ana belief, the facts set forth in this letter and enclosures are true.

GEORGIA POWER COM9ANY By: LJ II. 3E.~.

W. G. Hairston, 1 0 ~

S rn to and subscribed before me this 7th day of November,1988.

MR k N tary PulT' c d g p g JH/11h G

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Enclosures:

1. Basis for Proposed Change l 2. 10 CFR 50.92 Evaluation l 3. Instructions for Incorporation 4 Check for Application Fee t

c: Georgia Power Company Mr. P. D. Rice l Mr. G. Bockhold, Jr.

GO-NORMS ,

l U. S. Nuclear Regulatory Comission i Reg 1onal Adatnistrator ,

Mr. J. B. Hopkins, Licensing Project Manager, NRR (2 copies)

Mr. J. F. Rogge, Senior Resident Inspector - Operations, Yogtle State of Georgia Mr. J. L. Ledbetter, Comissioner, Department of Natural Resources YL-76 l 0042e 11/07/88 l

Georgia Power JLa k

ENCLOSURE 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 REQUEST TO REVISE TECHNICAL SPECIFICATION 3.3.3.6 BASIS FOR PROPOSED CHANGE PROPOSED CHANGE Revise Specification 3.3.3.6 "Accident Monitoring Instrumentation", to make the action requirements for inoperable containment hydrogen concentration monitors consistent with the requirements of Specification 3.6.4.1, "Hydrogen Monitors". Specifically, add the following action requirement appitcable to the hydrogen monitors:

ACTION 31b - a. With the number of OPERABLE channels less than the Total Number of Channels requirement, comply with the provisions of Specification 3.6.4.1

b. The provisions of Specification 3.0.4 are not applicable. ,

Re-number existing ACTION 31 to ACTION 31a.

BASIS The two Technical Specifications which address containment hydrogen concentration monitors have different action requirements for the same f

monitors. Specification 3.3.3.6, "Accident Monitoring Instrumentation",  !

allows 7 days to restore an inoperable monitor to operable status before proceeding to a lower mode of operation. If two monitor s .re inoperable, 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> are allowed to restore at least one to operable status. Specification 3.6.4.1, "Hydrogen Monitors", allows 30 days and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, respectively. The 30 day requirement is consistent with Generic Letter 83-37 and is more appropriate given the function perfonned by the hydrogen monitors. GPC is therefore proposing to revise Specification 3.3.3.6 to refer to Specification 3.6.4.1 for action requirements when a hydrogen monitor is inoperable.

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El-1 VL-76 0042e 11/07/88

Georgia Power ~ h ENCLOSURE 2 PLANT YOGTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 REQUEST TO REVISE TECHNICAL SPECIFICATION 3.3.3.6 10 CFR 50.92 EVALUATION -

In accordance with 10 CFR 50.92, Georgia Power Company has evaluated the attached proposed amendment to the VEGP Unit 1 Technical Specifications and has detemined that operation of the facility in accordance with the proposed amendment would not involve significant hazards considerations. The basis for this determination is as follows:

BACKGROUND Generic Letter 63-37 provided guidance on technical specification revisions for certain TMI Action Plan Items. With respect to Item II.F.1.6, "Containment Hydrogen Monitor", the NRC staff position was to includ these monitors in the Containment Systems specification. The staff position was stated as follows:

"Two independent containment hydrogen monitors should be operable at all times when the reactor is operating in Power Operation or Startup modes.

• LCO for these monitors chould include the requirement that with one hydrogen monitor inoperable, the moultor should be restored to operable status within 30 days or the plant should be brought to at least a hot standby condition within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. If both monitors are ,

inoperable, at least one monitor should be restored to operable status i within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the plant should be brought to at least hot standby condition with the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Typical surveillance requirements are provided in Enclosure 3."

The generic letter also added several items to the Accident Monitoring Instrumentation specification; hewever, containment hydrogen monitors were not among the items added. The guidance of the generic letter was incorporated -

into the Westinghouse Standard Technical Specifications (STS).  !

The Yogtle Unit 1 Technical Specifications include the containment  !

hydrogen monitors in the Containment Systems specification (3/4.6.4.1),  :

1 consistent with the generic letter and the STS. The same monitors are also  !

included in the Accident Monitoring Instrumentation specification (3/4.3.3.6). Inclusion of the hydrogen monitors in the Accident honitorinq Instrumentation specification was based on the NRC staff position that .

Regulatory Guide 1.97, Category 1 instrumentation should be suNect to l technical specification requirements. The fact that the hydrogen monitors ,

were addressed by another specification may have been overlooked.

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.. 1 GI orgia Power aL* k ENCLOSURE 2 (Cont'd)

REQUEST TO REVISE TECHNICAL SPECIFICATION 3.3.3.6 l 10 CFR 50.92 EVALUATION j i

The Accident Moni toring Instrumentation specification places overly restrictive action requirements on the hydrogen monitors. With one of two monitors inoperable, 7 days are allowed to restore the inoperable monitor to operable status; with both monitors inoperable, 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> are allowed to restore one monitor. This is inconsistent with the staff position in the  :

generic letter and is ineppropriate given the function these monitors '

perform. The hydrogen monitors provide indication and recording of post-LOCA containment hydrogen concentration. They perform no control or trip functions and are not needed for immediate post-accident mitigative action. Buildup of hydrogen in containment following a LOCA is a slow process. As discussed in FSAR Section 6.2.5.2, with no recombiner operation, it takes 12 days for a combustible mixture (4 volume percent hydrogen) to occur. With a single recombiner started on the second day or when the bulk containment concentration reached 3.5 volume pe rt.ent, the hydrogen concentration is quickly reduced. If the subject monitors were not available following a LOCA, other means of hydrogen monitoring could be used. The Post-Accident Sample System (PASS) is capable of sampling and in-line analysis for containment hydrogen concentration within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> after a decision is made to take a sample. Grab samples can be obtained from the PASS for laboratory analysis as a backup to in-line analysis.

In view of the nature of the monitored variable and the availability of alternate methods for monitoring, GPC Selieves that a 30 day requirement for restoring an inoperable hydrogen monitor (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore one of two inoperable monitors) is acceptable to ensure post-accident hydrogen control.

ANALYSIS GpC has reviewed the above proposed change and has determined that the change does not involve significant hazards considerations. In support of this conclusion, the following analysis is provided:

1. The proposed change will not significantly increase the probability or conseqJences of an accident previously evaluated. The change affects only the time limit for restoring an inoperable containment l hydrogen concentration monitor to operable status. These monitors -

are provided for post - LOCA indication and recording. They perfom '

no control or trip functions and are not needed for insnediate I post-accident mitigative action. Hydrogen buildup following a LOCA l 1s a slow process and alternate means of hydrogen monitoring are available. Even in the total absence of hydrogen monitoring, the l hydrogen recombiners could still be operated. The change will,

! therefore, have no significant negative effect on post-accident hydrogen control and the consequences of a LOCA would remain within previously analyzed limits.

I E2-2 11/07/88

g Georgia l'ower z. ENCLOSURE 2 (Cont'd)

REQUEST TO REVISE TECHNICAL SPECIFICATION 3.3.3.6

~10 CFR 50.92 EVALUATION i

2. The proposed change does not create the possibility of a new or different kind of accident than any accident previously evaluated.

The change involves no physical alteration of the plant. The change does not introduce any new equipment into the plant or require any existing equipment to operate in a different manner from which it was designed to operate. The change, therefore, does not create a new failure mode, and a new or different kind of accident could not re sul t. ,

3. The proposed change does not significantly reduce a ;argin of safety. The change does not affect safety limits or limiting safety system settings. The proposed time limit for restoring an inoperable hydrogen concentration monitor to operable status is consistent with NRC Generic Letter 83-37. The proposed time limit is appropriate given the nature of the monitored variable and the availability of

, alternate means of monitoring. The change will, therefore, have no  :

significant effect on the availability of post-accident hydrogen l control and margins of safety are not reduced.

CCNCLUSION i

Based on the preceding analy s t e,, GPC has detemined that the proposed j change to the Technical Specifications will not significantly increase the probability or consequences of an accident previously evaluated, create the i possibility of a new or different kind of accident from any accident  :

previously evaluated, or significantly reduce a margin of safety. G)C

! therefore concludes that the proposed change meets the requirem.nts of 10 CFR  ;

50.92(c) and does not involve significant hazards considerations.

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