ML20210R605

Application for Amend to License NPF-61,delaying Applicability of Tech Spec 3.7.7 Re Piping Penetration Area Filtration & Exhaust Sys,Until Entry Into Mode 2 to Prevent Delay in Power Ascension.Fee Paid

ML20210R605
Person / Time
Site:	Vogtle
Issue date:	02/04/1987
From:	Beckham J GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20210R611	List: ML20210R605 ML20210R900
References
SL-1952, NUDOCS 8702170456
Download: ML20210R605 (5)

Text

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S Georg;a Power Company 333 P:cdmont Avenue At:anta. Georgia 30308 Teiephone 404 526-6526 Maing Address Post Off.ce Box 454 At:arta. Georgia 30302 GeorgiaPower Nuclear Operations Department ' s %'n M W V + '

February 4,1987 l

U. S. Nuclear Regulatory Commission SL-1952 Attention: Document Control Desk 0078m Washington, D.C. 20555 NRC DOCKET 50-424 OPERATING LICENSE NPF-61 YOGTLE ELECTRIC GENERATING PLANT - UNIT 1 REQUEST TO REVISE TECHNICAL SPECIFICATION 3.7.7 PIPING PENETRATION AREA FILTRATION AND EXHAUST SYSTEM Gentlemen:

In accordance with the provisions of 10 CFR 50.90 as required by 10 CFR 50.59(c), Georgia Power Company (GPC) hereby proposes changes to the Technical Specifications, Appendix A to Operating License NPF-61.

Technical Specification (TS) 3.7.7 currently requires operability of the Piping Penetration Area Filtration and Exhaust System in operating modes 1, 2, 3, and 4. The pre-operational testing of this system, as stated in our completion status letter dated January 2,1987, was planned for completion prior to entry into Mode 4. Unanticipated difficulties with system flow balancing have occurred, however, resulting in system testing becoming critical path to Mode 4 entry as of January 24, 1987. GPC expects to complete all prerequisites to Mode 4 entry by the scheduled date of February 14, 1987, with the exception of TS 3.7.7 and other exceptions noted in previous correspondence. Since the Piping Penetration Area Filtration and Exhaust System is intended for post-accident fission product removal, its operability can be delayed with no adverse safety consequences until fission products are generated after initial criticality. GPC, therefore, requests that the applicability of TS 3.7.7 be delayed until the initial entry into Mode 2. GPC expects that requirements for system operability will be satisfied at that time.

Since the proposed change is necessary to prevent a delay in power ascension, GPC requests approval of the change on an " emergency" basis pursuant to 10 CFR 50.91(a)(5). A response to this proposed change by February 13, 1987 is requested to support entry into Mode 4 on February 14, 1987.

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

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8702170456 DR 870204 ADOCK 05000424 eDn g en re co d oS M S'l

eorgia Power U. S. Nuclear Regulatory Commission

+ February 4,1987

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

Enclosure;3 provides page change instruct' ions for incorporating the

- _ proposed changes into the VEGP Unit.1 Technical Specifications. . The proposed changed VEGP Unit 1 Technical Specifications page follows Attachment 3.

' Payment of filing fee is enclosed.

We request that the proposed amendment, once approved by the NRC, be -

~ -

issued with an imediate effective date.

Pursuant to the requirements of 10 CFR 50.91, Mr. J. L. Ledbetter of the Environmentel Protection Division of the Georgia Department of Natural Resources will be sent a copy of this letter and all applicable attachments.

J. T. Beckham,.Jr., states that he is a Vice President of Georgia Power J Company and is authorized to execute this oath on behalf of Georgia Power Company, and that to the best of his knowledge and believe the facts set forth in this letter are true.

GEORGIA POWER COMPANY By =

. T. Beckham, Jr. /

1. VicePresident #

Sworn to and subscribed before me this 4th day of February, 1987.

/f_. 46NMeht. 1987 Notary Public Enclosure xc: (all with enclosure)

Georgia Power Company J. P. O'Reilly Nuclear Regulatory Comission R. E. Conway M. A. Miller G. Bockhold, Jr. NRC Regional Administrator L. T. Gucwa NRC Resident Inspector.

Vogtle Project File GO-NORMS Georgians Against Nuclear Energy D. Feig Southern Company Services C. Stangler J. A. Bailey R. A. Thomas Troutman, Sanders, Lockerman & Ashmore J. E. Joiner, Esquire Shaw, Pittman, et al .

B. W. Churchill, Esquire State of Georgia

d. L. Ledbetter roons

ENCLOSURE 1 T0'SL-1952 NRC DOCKET 50-424 0PERATING LICENSE NPF-61

.V0GTLE ELECTRIC GENERATING PLANT-UNIT 1 REQUEST TO REVISE TECHNICAL SPECIFICATION 3.7.7 PIPING PENETRATION AREA FILTRATION AND EXHAUST SYSTEM BASIS FOR CHANGE REQUEST The trplicability portion of Technical Specification 3.7.7 currently reads

" MODES .1, 2, 3, and 4". The proposed change would make it read, " MODES 1, 2, 3* and 4*"_ with a footnote stating "* The provisions of this specification are not applicable until the initial entry into MODE 2." This would result in the Piping Penetration Area Filtration and Exhaust System not being required to be operable during modes 3 and 4 prior to the first criticality.

.This change is needed to allow pre-operational testing of-the system during initial plant startup testing while the plant is in modes 3 and 4. Safety is .

not jeopardized because the change is 'only in effect prior to the production of fission products.

The safety design bases of the Auxilliary Building Emergency Ventilation System (as discussed in FSAR Section 9.4.3.2.1) is to maintain required air temperatures and to maintain negative pressure to prevent the release of radioactivity to the atmosphere outside the building during the following conditions: loss-of-coolant accident, loss-of-offsite power, and other postulated accidents including line rupture with release of radioactivity inside the building. Should any of these events occur during the testing in Modes 3 and 4 prior to initial criticality the pressure control would be unnecessary because of _the absence of fission products. The need for temperature control would be minimal because of the lack of decay heat and would be meaningless due to the lack of radiological consequences.

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GeorgiaPewer A U. S. Nuclear Regulatory Commission February 4,1987 Page 2 Enclosure 2 details the basis for our determination that the proposed changes do not involve significant hazards considerations.

Enclosure 3 provides page change instructions for incorporating the proposed changes into the VEGP Unit 1 Technical Specifications. The proposed changed VEGP Unit 1 Technical Specifications page follows Attachment 3.

Payment of filing fee is enclosed.

We request that the proposed amendment, once approved by the NRC, be issued with an imediate effective date.

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

J. T. Beckham, Jr., states that he is a 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 believe the facts set forth in this letter are true.

GEORGIA POWER COMPANY By - l gv. T. Beckham, Jr. / ~

VVice President //

Sworn to and subscribed before .me this 4th day of February,1987.

LL. h, h $e's$? ngt Notary Public Enclosure xc: (all with enclosure)

Georgia Power Company J. P. O'Reilly Nuclear Regulatory Commission R. E. Conway M. A. Miller G. Bockhold, Jr. NRC Regional Administrator L. T. Gucwa NRC Resident Inspector Vogtle Project File GO-NORMS Georgians Against Nuclear Energy D. Feig Southern Company Services C. Star.gler J. A. Bailey R. A. Thomas Troutman, Sanders, Lockerman & Ashmore J. E. Joiner, Esquire Shaw, Pittman, et al .

B. W. Churchill, Esquire State of Georgia

d. L. Ledbetter 7C077$

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i ENCLOSURE 1 TO SL-1952 NRC DOCKET 50-424 OPERATING LICENSE NPF-61 V0GTLE ELECTRIC GENERATING PLANT-UNIT 1 REQUEST TO REVISE TECHNICAL SPECIFICATION 3.7.7 PIPING PENETRATION AREA FILTRATION AND EXHAUST SYSTEM BASIS FOR CHANGE REQUEST l The applicability portion of Technical Specification 3.7.7 currently reads

" MODES 1, 2, 3, and 4". The proposed change would make it read, " MODES 1, 2, 3* and 4*" with a footnote stating "* The provisions of this specification are not applicable until the initial entry into MODE 2." This would result in the Piping Penetration Area Filtration and Exhaust System not being required to be operable during modes 3 and 4 prior to the first criticality.

This change is needed to allow pre-operational testing of the system during initial plant startup testing while the plant is in modes 3 and 4. Safety .i s not jeopardized because the change is only in effect prior to the production of fission products.

The safety design bases of the Auxilliary Building Emergency Ventilation System (as discussed in FSAR Section 9.4.3.2.1) is to maintain required air temperatures and to maintain negative pressure to prevent the release of radioactivity to the atmosphere outside the building during the following conditions: loss-of-coolant ~ accident, loss-of-offsite power, and other postulated accidents including line rupture with release of radioactivity inside the building. Should any of these events occur during the testing in Modes 3 and 4 prior. to initial criticality the pressure control would be unnecessary because of the absence of fission products. The need for temperature control would be minimal because of the lack of decay heat and I

would be meaningless due to the lack of radiological consequences.

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ENCLOSURE 2 TO SL-1952 NRC DOCKET 50-424 OPERATING LICENSE NPF-61 V0GTLE ELECTRIC GENERATING PLANT-UNIT 1 REQUEST TO REVISE TECHNICAL SPECIFICATION 3.7.7 PIPING PENETRATION AREA FILTRATION AND EXHAUST SYSTEM 10 CFR 50.92 EVALUATION Pursuant to _10 CFR 50.92, Georgia Power Company has evaluated the attached proposed amendment to the VEGP Unit 1 Technical Specifications and has determined that its adoption would not involve significant hazards considerations. The basis for the determination is as follows:

Proposed Change:

This change delays the required operability of the Piping Penetration Area Filtration and Exhaust System until initial entry into Mode 2.

Basis:

(1 ) The probability of the occurrence and the consequences of an accident or malfunction of equipment important to safety are not increased above those analyzed in the FSAR due to this change because it is only effective during the time prior to initial criticality when there are no

' fission products to be released.

(2) The possibility of an accident or malfunction of a different type than analyzed in the FSAR does not result from this change because it is only effective during a time when no fission products are available for release.

1 (3) The margin of safety as defined in the technical specifications is not reduced because the technical specifications are written for a plant containing fission products and this change to Technical Specifications is only valid prior to the presence of fission products.

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ENCLOSURE 3 TO SL-1952 NRC DOCKET 50-424 OPERATING LICENSE NPF-61 V0GTLE ELECTRIC GENERATING PLANT-UNIT 1 REQUEST TO REVISE TECHNICAL SPECIFICATICN 3.7.7 PIPING PENETRATION AREA FILTRATION AND EXHAUST SYSTEM INSTRUCTIONS FOR INCORPORATION The proposed change to Technical Specifications (Appendix A to Operating License NPF-61) would be incorporated as follows:

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