ML20214S243

Application for Amends to Licenses NPF-5 & DPR-57,revising Tech Specs 4.6.L.2 for Unit 1 & 4.7.4.b for Unit 2,to Determine Operability of Hydraulic Snubbers on Loss of Fluid.Fee Paid

ML20214S243
Person / Time
Site:	Hatch
Issue date:	11/20/1986
From:	James O'Reilly GEORGIA POWER CO.
To:	Muller D Office of Nuclear Reactor Regulation
Shared Package
ML20214S247	List: ML20214S243 ML20214S295
References
GL-84-13, SL-1624, TAC-64157, TAC-64158, NUDOCS 8612080230
Download: ML20214S243 (6)

Text

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Georgia Power Company 333 Piedmont Avenue i eph 6 26 Mailing Address:.

Post Oftce Box 4545 Atlanta Georgia 30302 James P. O'Reiny the southern electnc system Senior %ce President Nuclear Operahons SL-1624 0922C-November 20,.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 DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR-PLANT UNITS 1 AND 2 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

HYDRAULIC SNUBBER OPERABILITY REQUIREMENTS 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 Technical Specifications, Appendix A to Operating Licenses DPR-57 and NPF-5 for Plant Hatch Units 1 and 2.

These proposed changes would revise the criteria for determining operability of a hydraulic snubber on discovery of loss of fluid, as provided in Unit'l Technical Specification 4.6.L.2 and Unit 2 Technical Specification 4.7.4.b, such that snubbers showing visible signs of fluid leakage need not be considered inoperable as long as they contain the minimum volume of reserve fl uid. The change would make the Plant Hatch Technical Specifications consistent in this regard with the Model Technical Specifications as provided in NRC Generic Letter 84-13, dated May 3,1984.

Enclosure 1 provides detailed descriptions of the proposed changes and the bases for the changes.

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 Technical Specifications.

The proposed changed Technical Specification pages follow Enclosure 3.

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Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 Director of Nuclear Reactor Regulation November 20, 1986 Page 2 Payment of the filing fee in the amount of one hundred and fifty dollars is enclosed.

In order to allow time for procedure revision and orderly incorporation into copies of the Technical Specifications, we request that the proposed amendment, once approved by the NRC, be issued with an effective date to be no later than 60 days from the issuance of the amendment.

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 the letter and enclosures are true.

GEORGIA POWER COMPANY by: %James8P. W kk O'Reilly Sworn to and subscribed before me this day of November g

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• • 1$7 Notary Public REB /lc Enclosures c: Georgia Power Company U. S. Nuclear Regulatory Commission Mr. J. T. Beckham, Jr. Dr. J. N. Grace, Regional Administrator Mr. L. T. Gucwa Mr. P. Holmes-Ray, Senior Resident Mr. H. C. Nix, Jr. Inspector - Hatch G0-NORMS State of Georgia Mr. J. L. Ledtetter 0922C

ENCLOSURE 1 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

HYDRAULIC SNUBBER OPERABILITY REQUIREMENTS Proposed Change: >

Provide revised visual inspection acceptance criteria for determination of inoperability of a hydraulic snubber. <

Basis:

This change proposes to revise Unit 1 Technical Specifications surveillance requirement section 4.6.L.2 and Unit 2 Technical Specifications surveillance requirement section 4.7.4.b (visual inspection acceptance criteria for hydraulic snubbers) in the following manner:

Current Specifications:

"However, if a hydraulic snubber is found to contain less than the required minimum volume of reserve fluid or if visible signs of leakage are present, the snubber shall be determined inoperable and cannot be determined OPERABLE via functional ~ testing for the purpose of establishing the next visual inspection interval."

Proposed Specification:  ;

"However, if a hydraulic snubber is found to contain less than the required minimum volume of reserve fluid, the snubber shall be determined inoperable and cannot be determined OPERABLE via functional testing for the purpose of establishing the next visual inspection interval."

Currently, any hydraulic snubber found to have visible signs of fluid leakage must be considered inoperable. This proposed change provides a more appropriate criterion for determination of hydraulic snubber inoperability.

That is, a snubber showing visible signs of leakage may be considered operable as long as the required minimum volume of reserve fluid is contained. This change is appropriate because the inspection of the fluid port or other fluid level indicating device singularly determines whether a hydraulic snubber contains the working medium necessary to perform its function. As long as the fluid port or level indicating device shows an acceptable fluid level, the "

presence of visible leakage does not render a hydraulic snubber inoperable because the required minimum volume of fluid which enables the snubber to perform its function is contained within the snubber's fluid reservoir.

0922C El-1 11/20/86

n ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

HYDRAULIC SNUBBER OPERABILITY REQUIREMENTS BASIS FOR CHANGE REQUEST Therefore, this change provides the proper criterion which ensures that the operability of a hydraulic snubber is correctly maintained.

Additionally, this change is consistent with section 4.7.9.b, " Visual Inspection Acceptance Criteria," of the Model Technical Specifications provided with NRC Generic Letter 84-13. The proposed change would preclude unnecessary determination of inoperability and snubber repair caused by the current overly restrictive criterion, and would consequently reduce personnel radiation exposures as well as preclude potential shutdowns for snubber inspections.

The last sentence in Model Technical Specification section 4.7.9.b, "All snubbers connected to an inoperable common hydraulic reservoir shall be counted as inoperable snubbers.," is not included in this proposed change because it is not applicable. Neither of the Hatch units has hydraulic snubbers connected to a common hydraulic fluid reservoir.

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0922C El-2 11/20/86

L ENCLOSURE 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

HYDRAULIC SNUBBER OPERABILITY REQUIREMENTS 10 CFR 50.92 EVALUATION Pursuant to 10 CFR 50.92, Georgia Power Company has evaluated the attached proposed license amendments for Plant Hatch Units 1 and 2, and has determined that their adoption would not involve a significant hazards consideration. The basis for this determination is as follows:

Proposed Change:

Provide revised visual inspection acceptance criteria for determination of inoperability of a hydraulic snubber for performance of Unit 1 surveillance requirement 4.6.L.2 and Unit 2 surveillance requirement 4.7.4.b. The proposed criterion would require a hydraulic snubber showing visible signs of fluid leakage to be determined inoperable only if the snubber is found to contain less than the required minimum volume of reserve fluid. The proposed criterion is consistent with Model Technical Specification surveillance requirement 4.7.9.b provided with NRC Generic Letter 84-13, dated May 3,1984.

Basis:

This change does not involve a significant increase in the probability or consequences of an accident, because neither plant operation nor design is affected by the proposed change. The proposed criterion will ensure the inspection and continued maintenance of the operability of the hydraulic snubbers at the current required level of safety.

The possibility of a different kind of accident from any analyzed previously is not created by this change, because no new modes of plant operation or change in design are involved.

Margins of safety are not significantly reduced by this change, because the proposed criterion will ensure the continued operability of the hydraulic snubbers at the current required level of safety, and is consistent with section 4.7.9.b of the Model Technical Specifications provided with NRC Generic Letter 84-13.

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L ENCLOSURE 3 NRC 00CKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

HYDRAULIC SNUBBER OPERABILITY REQUIREMENTS The proposed changes to the Unit 1 Technical Specifications (Appendix A to Operating License DPR-57) would be incorporated as follows:

Remove Page Insert Page 3.6-10b 3.6-10b The proposed changes to the Unit 2 Technical Specifications (Appendix A to Operating License NPF-5) would be incorporated as follows:

Remove Page Insert Page 3/4 7-12 3/4 7-12 0922C E3-1 11/20/86