ML20214A253

Application for Amend to License NPF-5 Changing Tech Specs to Provide More Explicit Info & Surveillance Requirements for Main Control Room Environ Control Sys Actuation Instrumentation.Fee Paid

ML20214A253
Person / Time
Site:	Hatch
Issue date:	11/10/1986
From:	James O'Reilly GEORGIA POWER CO.
To:	Muller D Office of Nuclear Reactor Regulation
Shared Package
ML20214A254	List: ML20214A253 ML20214A261
References
SL-1503, TAC-63412, NUDOCS 8611190342
Download: ML20214A253 (14)

Text

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= Ge'orga Power Cornpany

. 333 Piedmont Avenue At:anta, Georgia 30308 Telephone 404 5264526 Ma:hng Address:

Post Othee Box 4545 Atlanta. Georgia 30302 James P. O'Rellly the southem electrc system Senor Vice President Nuclear Operations 0855C  !

November 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 DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS REGARDING MAIN CONTROL ROOM ENVIRONMENTAL CONTROL SYSTEM 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 proposes changes to the Plant Hatch Unit 2 Technical Specifications (TS), Appendix A to Operating License NPF-5.

As you are aware, Georgia Power Company is involved in a significant effort which involves an upgrade of the entire body of plant procedures at Plant Hatch. As a part of the upgrade process for each procedure, a detailed review is conducted to determine technical requirements and commitments which are to be fulfilled by the procedure. This review includes Technical Specifications requirements. This Procedure Upgrade Program, now underway at Plant Hatch, has identified discrepancies in the Plant Hatch Unit 2 TS regarding instrumentation which actuates the control room pressurization mode of the Main Control Room Environmental

, Control System (MCRECS). The proposed changes will amend the TS to accurately reflect the plant design and Final Safety Analysis Report. In addition, the proposed changes will provide more explicit information and surveillance requirements for MCRECS actuation instrumentation.

Unit 2 is currently shut down for a refueling outage. Due to the discrepancies in the current Unit 2 TS, the MCRECS cannot currently be declared OPERABLE pursuant to TS 3.7.2. This prohibits re-entry into Operational Conditions 1, 2 or 3. It is anticipated that Plant Hatch Unit 2 will enter Operational Condition 3 on November 19, 1986. GPC has gOO (

8611190342 861110 .. ' St/ w # ,\t PDR ADOCK 05000366 P PDR

L Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 November 10, 1986 Page Two requested discretionary enforcement from NRC Region II to allow unit operation in Operational Conditions 1, 2, and 3 while the proposed TS changes are under review by NRR.

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

Enclosure 2 details the bases for our determination that the proposed changes do not involve a significant hazards consideration.

Enclosure 3 provides page change instructions for incorporating the proposed changes.

The proposed changed Technical Specifications pages follow Enclosure 3.

Payment of filing fee is enclosed.

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

Mr. J. 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 h (9 kk (TJamesP.O'Reilly Sworn to and subscribed before me this 10thMy of November ' 6.

Nofary Public REB /lc ,

p , W M h M &t gMWMS,NW Enclosures - ~ - - = 'e'h -

Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 November 10, 1986 Page Three c: Georgia Power Company Nuclear Regulatory Commission Mr. c. T. Beckham, Jr. Dr. J. N. Grace, Regional Administrator Mr. H. C. Nix, Jr. Mr. P. Holmes-Ray, Senior Resident Inspector Hatch GO-NORMS State of Georgia Mr. J. L. Ledbetter 0855C

~

k ENCLOSURE 1 i NRC DOCKET 50-366 j OPERATING LICENSE NPF-5 .

EDWIN I. HATCH NUCLEAR PLANT UNIT 2 PROPOSED CHANGES TO TECllNICAL SPECIFICATIONS REGARDING MAIN CONTROL ROOM ENVIRONMENTAL CONTROL SYSTEM BASIS FOR CHANGE REQUEST i

The Procedure Upgrade Program, currently underway at Plant Hatch, includes a detailed review to determine technical requirements and commitments which are to be fulfilled by the procedures. This review includes Technical Specifications requirements. This review has recently identified certain discrepancies in the Unit 2 TS relative to instrumentation which actuates operation of the Main Control Room

Environmental Control System (MCRECS) in the control room pressurization mode. Information appearing in sections 3/4 3.2, Isolation Actuation Instrumentation, and 3/4 7.2, Main Control Room Enviror. mental Control

. System, has been found to be inconsistent with the as-built plant and the FSAR.

The inconsistencies are as follows:

1. TS Table 3.3.2-1, items 1.a.2, 2.c, and 3.e provide that various, I

specified isolations occur due to a reactor vessel water level low-low (level 2) signal from instrument 2821-N682. This information l is correct except for the reference to "#". The notes for Table  ;

3. 3. 2-1 specify that "#" indicates that the instrument actuates '

operation of the MCRECS in the control room pressurization mode.

This actuation actually occurs on a reactor vessel water level low low low (level 1) signal from instrument 2B21-N691,

2. TS Table 3. 3. 2-1, items 1.b and 2.b provide that various, specified isolations occur due to a high drywell pressure signal from instrument 2C71 -N650. This information is correct except for the reference to "#" (MCRECS actuation). The high drywell pressure signal for MCRECS actuation in the control room pressurization mode is actually provided by instrument 2E11-N694. The only inconsistency is with the instrument number.

I' 3. TS Table 3.3.2-1, item 2.d provides that different, specified  ;

i isolations occur due to a high radiation signal from the refueling '

l floor exhaust radiation monitor 2011-K611. This information is correct except for the reference to "#" (MCRECS actuation). The refueling floor high radiation signal for MCRECS actuation actually l occurs from refueling floor area radiation monitor 2D21-K002.

4. TS 4.7.2.e.3 provides surveillance requirements for verifying MCRECS actuation in the control room pressurization mode for 0855C El-1 11/10/86

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h 1- ENCLOSURE 1 j

i PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS l REGARDING MAIN CONTROL ROOM ENVIRONMENTAL CONTROL SYSTEM I BASIS FOR CHANGE REQUEST t

specified actuation signals. This specification contains errors which are consistent with the errors in the instrumentation table described above. Item a. of this specification indicates that MCRECS i' actuation occurs on a reactor vessel water level low low (level 2) signal. MCRECS actuation actually occurs on a reactor vessel water level low low low (level 1) signal, as specified correctly in item b.

j of this specification. Item d. indicates that MCRECS actuation i occurs on a high radiation signal from the refueling floor exhaust radiation monitor. This actuation actually occurs from the refueling floor area radiation monitor.  ;

A review of the above inconsistencies has been performed by Georgia Power Company and our architect engineer. These reviews indicate that the

• l system configuration as described in the FSAR, and as exists in the

~

plant, is correct with respect to the design basis. Plant Hatch Unit 2 FSAR Section 6.4.1.2.2.2 discusses the design basis radiological i accidents for which the control rocn pressurization mode is intended to protect plant operators. One design basis is a loss of coolant accident (LOCA). The FSAR specifies that a LOCA signal will actuate the MCRECS in the control room pressurization mode. A LOCA signal is defined as

. reactor vessel water level low low low (level 1) signal or a high drywell pressure signal. Unit 2 FSAP. Figure 7.3.2, sheet 12, further shows that

these parameters correctly provide the MCRECS actuation signal. Another design basis radiological accident, from Section 6. 4.1. 2. 2. 2 of the Unit i 2 FSAR, is the fuel handling accident. This accident is further

, described in Unit 2 FSAR Section 1 5.1 .41 . FSAR Section 6. 4.1. 2. 2. 2 l describes that a refueling floor high radiation signal will actuate the l MCRECS. Figure 7.3.2, Sheet 12, shows that this signal is provided from i the refueling floor area radiation monitor. The two remaining design

! basis radiological accidents are a main steam line break and a control

[ rod drop accident. These accidents are addressed by initiating the control room pressurization mode from main steam line high flow or from i main steam line high radiation. In addition, the pressurization mode is

initiated by main control room air intake high radiation.

The proposed changes will correct the TS to provide consistency with the i FSAR and actual plant configuration. The proposed changes will additionally provide new tables depicting MCRECS actuation

! instrumentation, setpoints, and surveillance requirements, and will remove the current notational references to other tables for MCRECS

actuation. A new section, Main Control Room Environmental Control System

! Actuation Instrumentation, is provided to replace and encompass the

! current Section 3/4 3.6.7, Chlorine Detectors. Finally, the proposed i

changes will provide more stringent reauirements for Operational l

Conditions in which the NCRECS is required to be operable.

l 0855C El -2. 11/10/86

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i ENCLOSURE 1

PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS l REGARDING MAIN CONTROL ROOM ENVIRONMENTAL CONTROL SYSTEM BASIS FOR CHANGE REQUEST Proposed Change 1:

j This proposed change will replace instrument 2B21-N682 (reactor vessel

!- water level low-low) in items 1.a.2, 2.c, and 3.e of Table 3.3.2-1, with

! the correct instrument 2B21-N691 (reactor vessel water level low-low-low) j as item 1. of new Table 3.3.6.7-1.

j As described above, this change corrects the TS to provide consistency

i. with the actual plant design and FSAR. The proposed change does not allow the use of a less conservative setpoint in the plant than is I analyzed in the FSAR. The proposed change simply corrects an error in j the TS to properly reflect the plant design. Action statements and Surveillance requirements provided in Tables 3.3.6.7-1 and 4.3.6.7-1, respectively, are unchanged from the current TS.

Proposed Change 2:

This proposed change will replace instrument 2C71-N650 (drywell pressure

high) in items 1.b and 2.b of Table 3.3.2-1, with the correct instrument 2E11-N694. This instrument performs the same function as the instrument presently listed in the TS. Action statements, Setpoints, and Surveillance reqJirements provided in Tables 3. 3. 6. 7-1, 3. 3. 6. 7-2, and i 4.3.6.7-1, respectively, are unchanged from the current TS. This change

simply corrects the part number for the instrument which performs the trip function.

Proposed Change 3:

This proposed change will replace instrument 2D11-K611 (refueling floor exhaust radiation high) in item 2.d of Table 3.3.2-1, with the correct instrument, refueling floor area radiation monitor 2D21-K002. This instrument performs the same function as the instrument presently listed i in the TS, which is to detect excessive radiation on the refueling 2

floor. The area radiation monitor is located closer to the potential source of radiation than the refueling floor exhaust radiation monitor, and thus gives conservative assurance that the MCREC will be actuated appropriately. Figure 1 of this enclosure provides the location of area radiation monitors 2D11-K002 A and D. The primary radiation concern on 1 the refueling floor is gamma exposure, which is a line of sight phenomenon rather than an airborne concern. The 2D11-K002 A and D

! detectors provide line of sight detection of postulated gammas emmitted  :

l from the refueling pool or reactor cavity, and will actuate prior to the 2D11-K611 detectors, which are located in the exhaust ventilation 0855C El-3 11/10/86 4

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ENCLOSURE 1 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS lEGARDING t%IN CONTROL ROOM ENVIRONMENTAL CONTROL SYSTEM BASIS FOR CHANGE REQUEST ductwork. Both 2D11-K611 and 2021-K002 are procured from General Electric to the same requirements, so no downgrading of equipment quality is involved. Action statements, Setpoints, and Surveillance requirements provided in Tables 3.3.6.7-1, 3.3.6.7-2, and 4.3.6.7-1, respectively, are unchanged from the current TS. The proposed change simply corrects an error in the TS to properly reflect the plant design and FSAR.

Proposed Change 4:

Several instruments are relocated to the new Tables 3. 3. 6. 7-1, 3. 3. 6. 7-2, and 4.3.6.7-1. Instruments 2Dll-K603, main steam line radiation high, and 2B21-N686, 2B21-N687, 2B21-N688, and 2B21-N686, main steam line flow high, are relocated from the "#" reference for Table 3.3.2-1.

Requirements pertaining to instrument 1241-N022, control room inlet air chlorine high, are relocated from the current Section 3.3.6.7 to the new tables, and the Operational Conditions in which operability is required are expanded (see Proposed Change 5). Action statements, Setpoints, and Surveillance requirements provided for the above instruments in Tables 3.3.6.7-1, 3.3.6.7-2, and 4.3.6.7-1, respectively, are unchanged from the current TS. Setpoints and surveillance requirements for instrument 1241-R615, control room air inlet radiation high, are added to the TS for completeness and consistency.

Proposed change 5:

Several conservative changes are proposed to correctly. specify the Operational Conditions in which the control room isolation and pressurization modes of the MCRECS are required to be operable, and to require demonstration of isolation mode actuation. Present TS 3/4.7.2 requires operability of the MCRECS in Operational Conditions 1, 2 and 3, and only addresses the control room pressurization mode of MCRECS.

Present TS 3/4.3.6.7 requires operability of the chlorine detectors in operational conditions 1, 2 and 3, and does not explicitly require that MCRECS isolation mode actuation be demonstrated. Proposed change 5 will require, under new Section 3.3.6.7, operability of the MCRECS pressurization mode in Operational Conditions 1, 2, 3, and 5, and when irradiated fuel is being moved in secondary containment. This provides consistency with the FSAR and the design basis for the system.

Operability of the MCRECS in the isolation mode will be required in operational conditions 1, 2, 3, 4 and 5, since a postulated chlorine accident is independent of Operational Condition. Finally, proposed new TS 4.7.2.e.4 will require once per cycle demonstration of actuation of the MCRECS in the isolation mode. These changes all represent new requirements in the TS and are clearly conservative.

0855C El-4 11/10/86

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ENCLOSURE 2 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS REGARDING MAIN CONTROL ROOM ENVIRONMENTAL CONTROL SYSTEM 10 CFR 50.92 EVALUATION Pursuant to 10 CFR 50.92, Georgia Power Company has evaluated the enclosed proposed amendment to the Plant Hatch Unit 2 Technical Specifications and has determined that its adoption would not involve a significant hazards consideration. The basis for this determination is as follows:

Proposed Change 1:

This proposed - change will replace instrument 2B21-N682 (reactor vessel water level low-low) in items 1.a.2, 2.c, and 3.e of Table 3.3.2-1, with the correct instrument 2B21-N691 (reactor vessel water level low-low-low) as item 1. of new Table 3.3.6.7-1.

Basis For Proposed Change 1:

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

A. The probability of occurrence or the consequences of an accident or malfunction of equipment important to safety would not be increased above those analyzed in the FSAR, because the change merely corrects the Technical Specifications (TS) to provide consistency with the FSAR.

B. The possibility of an accident or malfunction of a different type than any previously analyzed in the FSARs would not be created, because the change would not introduce any new modes of plant equipment operation or failur e.

C. Margins of safety would not be significantly reduced because the change only corrects the TS to reflect the correct margins of safety as provided in the FSAR.

0855C E2-1 11/10/86

• L ENCLOSURE 2 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS REGARDING MAIN CONTROL ROOM ENVIRONMENTAL CONTROL SYSTEM 10 CFR 50.92 EVALUATION Proposed Change 2:

This proposed change will replace instrument 2C71-N650 (drywell pressure high) in items 1.b and 2.b of Table 3.3.2-1, with the correct instrument 2E11-N694. This instrument performs the same function as the instrument presently listed in the TS. Action statements, Setpoints, and Surveillance requirements provided in Tables 3.3.6.7-1, 3.3.6.7-2, and 4.3.6.7-1, respectively, are unchanged from the current TS. This change simply corrects the part number for the instrument which performs the trip function.

Basis For Proposed Change 2:

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

A. The probability of occurrence or the consequences of an accident or malfunction of equipment important to safety would not be increased above those analyzed in the FSAR, because the change merely corrects the Technical Specifications (TS) to provide consistency with the FSAR.

B. The possibility of an accident or malfunction of a different type than any previously analyzed in the FSARs would not be created, because the change would not introduce any new modes of plant equipment operation or failure.

C. Margins of safety would not be significantly reduced because the change only corrects descriptive information (part numbers) and has no effect on margins of safety

Proposed Change 3

This proposed change will replace instrument 2011-K611 (refueling floor exhaust radiation high) in item 2.d of Table 3.3.2-1, with the correct instrument, refueling floor area radiation monitor 2D21-K002, in proposed new Table 3.3.6.7-1. Action statements, Setpoints, and Surveillance requirements provided in Tables 3. 3. 6. 7 -1, 3.3.6.7-2, and 4. 3. 6. 7-1, respectively, are unchanged from the current TS.

0855C E2-2 11/10/86

ENCLOSURE 2 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS REGARDING MAIN CONTROL P0OM ENVIRONMENTAL CONTROL SYSTEM 10 CFR 50.92 EVALUATION Basis For Proposed Change 3:

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

A. The probability of occurrence or the consequences of an accident or malfunction of equipment important to safety would not be increased above those analyzed in the FSAR, because the change merely corrects the Technical Specifications (TS) to provide consistency with the FSAR.

B. The possibility of an accident or malfunction of a different type than any previously analyzed in the FSARs would not be created, because the change would not introduce any new modes of plant equipment operation or failure.

C. Margins of safety would not be significantly reduced because the change only corrects the TS to reflect the correct instrument as provided in the FSAR. This instrument preserves equivalent margins as the instrument presently listed in the TS.

Proposed Change 4:

Several instruments are relocated to the new Tables 3.3.6.7-1, 3.3.6.7-2, and 4.3.6.7-1. Instruments 2011-K603, main steam line radiation high, and 2821-N686, 2B21-N687, 2B21-N688, and 2B21-N686, main steam line flow high, are relocated from the "#" reference for Table 3.3.2-1.

Requirements pertaining to instrument lZ41-N022, control room inlet air chlorine high, are relocated from the current Section 3.3.6.7 to the new tables, and the Operational Conditions in which operability is required are expanded. Action statements, Setpoints, and Surveillance requirements provided for the above instruments in Tables 3.3.6.7-1, 3.3.6.7-2, and 4.3.6.7-1, respectively, are unchanged from the current TS. Setpoints and surveillance requirements for instrument lZ41-R615, control room air inlet radiation high, are added to the TS for completeness and consistency.

0855C E2-3 11/10/86

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4 1

i ENCLOSURE 2 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS REGARDING MAIN CONTROL ROOM ENVIRONMENTAL CONTROL SYSTEM l

10 CFR 50.92 EVALUATION j

Basis For Proposed Change 4:

l Georgia Power Company has reviewed the proposed change and has detennined that it does not involve a significant hazards consideration for the

. following reasons:

i A. The probability of occurrence or the consequences of an accident 4 or malfunction of equipment important to safety would not be i increased above those analyzed in the FSAR, because the change only moves the location of requirements and adds certain additional requirements.

B. The possibility of an accident or malfunction of a different

type than any previously analyzed in the FSARs would not be

created, because the change would not introduce any new modes of plant equipment operation or failure.

1

C. Margins of safety would not be significantly reduced because the

change only moves the location of requirements and adds certain additional requirements.

l Proposed Change 5:

, Several conservative TS modifications are proposed to correctly specify the Operational Conditions in which the control room isolation and pressurization modes of the MCRECS are required to be operable, and to require demonstration of isolation mode actuation. Present TS 3/4.7.2 l requires operability of the MCRECS in Operational Conditions 1, 2 and 3, i and only addresses the control room pressurization mode of MCRECS.

Present TS 3/4.3.6.7 requires operability of the chlorine detectors in j operational conditions 1, 2 and 3, and does not explicitly require that j MCRECS isolation mode actuation be demonstrated. Proposed change 5 will require, under new Section 3.3.6.7, operability of the MCRECS

. pressurization mode in Operational Conditions 1, 2, 3, and 5, and when irradiated fuel is being moved in secondary containment. Tnis provides consistency with the FSAR and the design basis for the system.

Operability of the MCRECS in the isolation mode will be required in

operational conditions 1, 2, 3, 4 and 5, since a postulated chlorine accident is independent of Operational Condition. Finally, proposed nee TS 4.7.2.e.4 will require once per cycle demonstration of actuation of the MCRECS in the isolation mode. These changes all represent new l l requirements in the TS and are clearly conservative.

i 0855C E2-4 11/10/86

ENCLOSURE 2 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS REGARDING MAIN CONTROL ROOM ENVIRONMENTAL CONTROL SYSTEM 10 CFR 50.92 EVALUATION Basis For Proposed Change 5:

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

A. The probability of occurrence or the consequences of an accident or malfunction of equipment important to safety would not be increased above those analyzed in the FSAR, because the change involves additional requirements.

B. The possibility of an accident or malfunction of a different type than any previously analyzed in the FSARs would not be created, because the change would not introduce any new modes of plant equipment operation or failure.

C. Margins of safety would not be significantly reduced because the change invalves additional requirements 0855C E2-5 11/10/86

i L

ENCLOSURE 3 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS REGARD SYSTEM

, IN5IRUCTIONS FOR INCORPORATION The proposed changes to the Technical Specifications (Appendix A to Operating License NPF-5) would be incorporated as follows:

REMOVE PAGE INSERT PAGE V V 3/4 3-11 3/4 3-11 3/4 3-12 3/4 3-12 3/4 3-15 3/4 3-15 3/4 3-58 3/4 3-58 3/4 3-58a 3/4 3-58b I

3/4 3-58c i

i ---

3/4 3-58d 3/4 3-58e l

3/4 7-6 3/4 7-6 3/4 7-8 3/4 7-8 l

I I

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i -

0855C E3-1 11/10/86 l

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