ML20211Q675
| ML20211Q675 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 02/17/1987 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 0101M, 101M, SL-2016, NUDOCS 8703030159 | |
| Download: ML20211Q675 (5) | |
Text
..
Georgia Pow:t Comp:ny 333 Piedmont Avenue Atlanta, Georgia 30308 Telephone 404 526-6526 Marling Address:
Post Office Box 4545 Atlanta, Georgia 30302 Georgia Power L T. Gucwa the southem dectnc system Manager Nuclear Safety and Ucensing 010lm February 17, 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555
-NRC DOCKET 50-424 OPERATING LICENSE NPF-61 V0GTLE ELECTRIC GENERATING PLANT UNIT 1 DEFERRAL OF SPECIFIC TECHNICAL SPECIFICATION REQUIREMENTS Gentlemen:
This letter documents Georgia Power Company's (GPC's) request and the NRC's agreement on February 12, 1987 to temporarily defer certain Vogtle Unit 1 Technical Specification requirements.
The applicable Technical Specifications are those associated with the Piping Penetration Area Filtration and Exhaust System, the Control Room Emergency Filtration System, and Containment Area High-Range Radiation Monitors RE-0005 and RE-0006.
This equipment is required by Technical Specifications to be operable in Operating Modes 1, 2, 3, and 4.
Despite extensive efforts by GPC, operability will not be achieved by the scheduled advancement to Operating Mode 4 on February 18, 1987.
GPC evaluated the deferral of the associated Technical Specification requirements until prior to the initial entry into Mode 2 and found that no adverse safety consequences would result.
By letter dated February 4,1987 and conference calls with NRC Region II and NRR personnel on February 12, 1987, GPC requested and received NRC approval to delay the applicabililty of the associated Technical Specifications until prior to the initial entry into Operating Mode 2.
l The enclosures to this letter provide detailed descriptions of the deferred requirements, the circumstances necessitating our relief request, and the basis for our determination that no unreviewed safety question or hazard to the public will result.
If you have any questions, please contact this office at any time.
Sincerely, y 2: _
i l
L. T. Gucwa JH/lm 9h B703030159 870217 i
- Enclosures PDR ADOCK 05000424 P
l l
l U. S. Nuclear Regulatory Commission February 17, 1987 Page Two c(w): Georgia Power Company Mr. F;. E. Conway Mr. J. P. O'Reilly Mr. G. Bockhold, Jr.
GO-NORMS Southern Company Services, Inc.
Mr. J. A. Bail ey Shaw, Pittman, Potts & Trowbridge Mr. B. W. Churchill, Attorney-at-Law Troutman, Sanders, Lockerman & Ashmore Mr. J. E. Joiner, Attorney-at-Law U. S. Nuclear Regulatory Commission Dr. J. N. Grace, Regional Administrator Mr. H. H. Livermore, Senior Resident Inspector-Construction, Vogtle Ms. M. Miller, Licensing Project Manager, NRR Mr. J. F. Rogge, Senior Resident Inspector-0perations, Vogtle Georgians Against Nuclear Energy 11r. D. Feig Ms. C. Stangler l
i l
l l
l l
0101m
ENCLOSURE 1 TO SL-2016 NRC DOCKET 50-424 OPERATING LICENSE NPF-61 V0GTLE ELECTRIC GENERATING PLANT UNIT 1 DEFERRAL 0F TECHNICAL SPECIFICATION REQUIREMENTS PIPING PENETRATION AREA FILTRATION AND EXHAUST SYSTEM Technical Specification 3/4.7.7 requires that two independent Piping Penetration -Area Filtration and Exhaust Systems be operable in Operating Modes 1, 2, 3, and 4.
GPC has requested and received NRC approval to delay the applicability of this requirement until prior to the initial entry into Operating Mode 2.
The pre-operational testing of this system, as stated in our completion status letter dated January 2,1987, was planned to be finished prior to the initial entry into Operating Mode 4.
Unanticipated difficulties with system flow balancing occurred, however, resulting in system testing becoming the critical path to Mode 4 entry.
The flow balance has been completed, but additional testing remains to be performed and will not be completed before the scheduled Mode 4 entry.
The safety design bases of the Auxiliary Building Emergency Ventilation System, as discussed in the FSAR, are to maintain required air temperatures and to maintain negative pressure to prevent the release of radioactivity from inside the building to the outside atmosphere.
If a line leak or break occurred prior to initial criticality, control of leakage to the outside environment would not be needed due to the lack of fission products, and the lack of decay heat or radiological consequences would obviate the need for air temperature control.
The probability or consequences of an accident or malfurction analyzed in the FSAR are therefore not increased.
The possibility of an accident or malfunction of a different type than any analyzed in the FSAR is not created because no new operating configuration or mode of failure is introduced.
The margin of safety as defined in the basis of any Technical Specification is not reduced because system function is not needed prior to initial criticality.
i i
l El-1
-l ENCLOSURE 2 TO SL-2016 NRC DOCKET 50-424 OPERATING LICENSE NPF-61 V0GTLE ELECTRIC GENERATING PLANT UNIT 1 DEFERRAL OF TECHNICAL SPECIFICATION REQUIREMENTS CONTROL ROOM EMERGENCY FILTRATION SYSTEM Technical Specification 3.7.6 requires operability of two independent Control Room Emergency Filtration Systems in Operating Modes 1, 2, 3, and 4.
GPC requested and received NRC approval to delay the initial applicability of this Technical Specification until prior to entry into Operating Mode ~ 2.
Technical Specifications 3/4.3.2 (Functional Unit 10 of Tables 3.3-2, 3.3-3, and 4.3-2) and 3/4.3.3.1 (Functional Unit 3 of Tables 3.3-4 and 4.3-3) address actuation instrumentation for this system and are hereby included in our deferral request.
As stated in our completion status letter dated January 9,
- 1987, pre-operational testing of the HEPA and carbon filter packages of this system was planned for completion prior to entry into Mode 4.
Unexpected testing problems have occurred due to inadequate air distribution through the carbon adsorbers.
GPC is currently working to establish an acceptable air-distribution through the adsorbers.
Following completion of that activity, surveillance testing must be performed.
Completion of system testing was recognized on February 9, 1987 as a constraint to the schedule for entry into Mode 4.
All possible efforts have been made to keep system testing off of the critical path to Mode 4.
Prior to entering Mode 4, the control room emergency filtration system will be essentially identical to its operable configuration, with the exception of the filtration packages.
The control room emergency filtration system provides three functions in the event of the applicable accidents described in the FSAR.
The functions are isolation for toxic gas (chlorine) releases, filtration for radiological releases and cooling for control room environment during accident conditions.
The isolation function will be operable and will be active during this time, filtration is not required prior to initial criticality as there is no radioactive material inventory and one train of the system can supply adequate cooling to maintain ambient air temperature at or below allowable.
E2-1
s ENCLOSURE 3 TO SL-2016 NRC DOCKET 50-424 OPERATING LICENSE NPF-61 V0GTLE ELECTRIC GENERATING PLANT UNIT 1 DEFERRAL OF TECHNICAL SPECIFICATION REQUIREMENTS CONTAIMENT AREA HIGH-RANGE RADIATION MONITORS l
Containment area high-range radiation monitors RE-0005 and RE-0006 are required to be operable in Operating Modes 1, 2,
3, and 4 by Technical Specifications 3/4.3.2, Engineered Safety Features Actuation System l
Instrumentation (Functional Unit 3.a.(4) of Tables 3.3-2, 3.3-3, and 4.3-2) and 3/4.3.3.1, Radiation Monitoring for Plant Operations (Functional Unit 1.a.
of Tables 3.3-4 and 4.3-3).
Technical Specification 3/4.3.3.6, Accident Monitoring Instrumentation (Item 14 of Table 3.3-8), requires operability of at least one of the monitors in Modes 1, 2, and 3.
GPC requested and received NRC approval to delay the applicability of these requirements until the initial entry into Operating Mode 2.
GPC has been conducting an extensive evaluation and investigation of difficulties experienced with the electrical cables which connect the radiation detectors inside containment to the Data Processing Module outside containment.
On February 10, 1987 it was decided to clean, dry, and environmentally seal these cables.
If this does not resolve the problems experienced, GPC will replace the cables.
The present schedule for resolving the cable problems extends beyond the olanned entry into Mode 4.
Delaying the operability of these monitors until entry into Mode 2 would have no safety consequences due to the lack of any significant fission products in the reactor core prior to initial criticality. A leak or break in the primary system prior to initial criticality would have no radiological consequences, therefore, the radiation monitoring and containment isolation functions provided by the monitors would not be needed.
The probability or consequences of an accident or malfunction analyzed in the FSAR are not increased because the monitors will be available to perform their safety functions when required, after the generation of fission products.
Prior to that time they are not needed.
The possibility of an accident or malfunction of a different type than any analyzed in the FSAR is not created because no new operating configurations or modes of failure are introduced.
The margin j
of safety as defined in the basis of any Technical Specification is not reduced because radiation detection is not a concern before fission products are generated.
E3-1
_ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _