ML20235A357

Application for Amend to License NPF-5,changing Tech Specs to Allow Performance of Sys Hydrostatic or Leakage Pressure Testing W/Noncritical Reactor Core at Reactor Coolant Temp Above 212 F.Fee Paid

ML20235A357
Person / Time
Site:	Hatch
Issue date:	01/04/1988
From:	James O'Reilly GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20235A359	List: ML20235A357 ML20235A395
References
SL-3864, TAC-66947, NUDOCS 8801120215
Download: ML20235A357 (11)

Text

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Georgia Power Company 333 Piedrnont Avenue Atlanta, Georgra 30308

~* Telephone 404 526-7851 Maihng Address' Post Ofhce Box 4545 Atlanta, Georgia 30302 James P. O'Reilly IW wof wn rwh < istern Senior Vice President Nuclear Operahons SL-3864 1790C X7GJ17-H600 January 4, 1988 1

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D. C. 20555 i

PLANT HATCH - UNIT 2 NRC DOCKET 50-366 l OPERATING LICENSE NPF-5 l REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

HYDROSTATIC AND LEAK TESTING 680VE 212*F USING NON-NUCLEAR HEAT Gentlemen:

In accordance with the provisions of 10 CFR 50.90, as required by 10 CFR 50.59(c)(1), Georgia Power Company hereby proposes changes to the Plant Hatch Unit 2 Technical Specifications, Appendix A to Operating License NPF-5.

These proposed changes are necessary to allow performance of system hydrostatic or leakage pressure testing with a non-critical reactor core at reactor coolant temperatures above 212*F.

Enclosure 1 provides a detailed description of the proposed changes and the bases for the change request.

Enclosure 2 details the bases 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 Plant Hatch Unit 2 Technical Specifications.

The proposed changed Technical Specifications pages follow Enclosure 3.

Payment of a filing fee in the amount of one hundred and fifty dollars is enclosed.

In order to allow time for procedure revisions and orderly incorporation into copies of the Technical Specifications, we request that the proposed amendment, once approved by the NRC, be issued with an 8801120215 080104 6 g PDR ADOCK 050 P y e gc g h g

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l U.S. Nuclear Regulatory Commission January.4, 1988 Page Two-I effective date to be no later than 60 days 'from the date of issuance of

'the amendment. )

The changes described in Enclosure. I are necessary to facilitate the startup of Plant Hatch Unit 2 from the upcoming refueling . outage (the outage is . scheduled to begin January 13, 1988). Without approval of'

these- changes, . the . required hydrostatic and leak testing (which are ,

performed on critical path) will take longer and result in capacity '

factor losses. Therefore, we request priority approval of these changes by February 28, 1988, a

In accordance with 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.

1 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 this letter and enclosures are true.

1 GEORGIA POWER COMPANY

.l By: %u PJ9 Pd 0 James P. O' eilly Sworn to and subscribed before me this 4th day of Jan 1 8.

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d)YYNotary Public 1%a ,, , , . _  :

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.. Enclosures :

1. Basis for Change Request

'2. 10 CFR.50.92 Evaluation

3. Page Change Instructions

4. Filing Fee - $150.00 '

c: (See next page.)

1790C 4

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U.S' Nuclear Regulatory Commission January 4, 1988 Page three c: .Georaia Power Comoany

Mr. J. T. Beckham, Jr., Vice President Plant Hatch GO-NORMS.

U.S. Nuclear Reaulatory Commission. Washinaton~. 0 1 Mr. L. P. Crocker, Licensing Project Manager - Hatch L S. Nuclear Reaulatory Commission. Region II Dr.: J. N. Grace, Regional Administrator l- Mr. P. Holmes-Ray, Senior Resident Inspector.- Hatch State of Georgia .

Mr. J. L. Ledoetter, Commissioner - Department of Natural Resources 1790C

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ENCLOSURE 1 PLANT HATCH - UNIT 2 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

HYDROSTATIC AND LEAK TESTING ABOVE 212*F USING NON-NUCLEAR HEAT BASIS FOR CHANGE REQUISI Georgia Power Company (GPC) has historically used nuclear heat for performance of inservice hydrostatic and leak testing for the Plant Hatch units. This testing has been performed with a critical core at elevated reactor coolant temperatures (i.e., greater than 212*F). Because of the elevated temperatures and reduced pressures used for such tests, and the fact that nuclear steam is being produced, these tests may be performed l under the requirements of the current Plant Hatch Unit 2 Technical Specifications.

The Nuclear Regulatory Commission (NRC) recently required that inservice hydrostatic testing and systems leakage pressure tests required by Section XI of the ASME Boiler and Pressure Vessel Code be performed prior to the reactor going critical from a refueling outage. Therefore, recirculation pump operation and a water-solid reactor pressure vessel (except for an ' air bubble for pressure control) must be used to achieve the necessary temperatures and pressures required for these tests. The minimum temperatures (at the required pressures) allowed for these tests are determined from the reactor pressure vessel pressure / temperature limit curves contained in the Technical Specifications. These curves are conservatively based upon the fracture toughness of the reactor vessel, taking into account anticipated vessel neutron fluence. As vessel irradiation increases, the minimum tempera ture allowed at a given pressure also increases.

The following proposed Technical Specifications changes are required when hydrostatic or leak testing is being performed with non-nuclear heating at temperatures greater than 212*F.

PROPOSED CHANGE 1:

Proposed Change 1 modifies the Operational Conditions definitions of HOT SHUTDOWN and COLD SHUTDOWN in the current Unit 2 Technical Specifications by adding a footnote to Table 1.2. This change will allow the reactor to be considered in the COLD SHUTDOWN condition with reactor coolant temperature above 212*F during the performance of inservice hydrostatic or leak testing with all control rods fully inserted. At present, Technical Specifications require average reactor coolant temperature to  !

be 1212*F for the reactor to be considered in COLD SHUTDOWN. Proposed Change 1 also states that a reactor coolant temperature of 1212*F is 1790C El-1 01/04/88 SL-3864 2

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ENCLOSURE 1 (Continued) l RE0UEST TO REVISE TECHNICAL SPECIFICATIONS:

HYDR 0 STATIC AND LEAK TESTIRG_

AB0VE 212*F USING NON-NUCLEAR HEAT BASIS FOR CHANGE REOUEST required to comply with an ACTION statement requiring the reactor to be j i in COLD SHUTDOWN. This proposed change effectively provides an exemption to operability requirements for the High Pressure Coolant Injection '

(HPCI) System, the Reactor Core Isolation Cooling (RCIC) System, the i Automatic Depressurization System (ADS), and the Safety / Relief Valve (S/RV) System, as well as primary containment integri ty, during ,

hydrostatic and system leak testing when reactor coolant temperature is '

greater than 212*F.

Basis for Prooosed Chance 1:

Hydrostatic or leak testing using non-nuclear heat is performed above the lowest temperature allowed by the reactor pressure vessel pressure /

temperature limit curve (Technical Specifications Figure 3.4.6.1-3), and at a pressure equal to (leak testing) or greater than (hydrostatic testing) normal operating pressure. With increased reactor vessel fluence over time, the minimum allowable vessel temperature (at a given i pressure) increases. (Periodic updates to the Technical Specifications reactor pressure vess?1 pressure / temperature limit curves are performed, as necessary, based upon the results of analyses of irradiated surveillance specimens removed from the vessel). Future hydrostatic and leak testing will eventually be performed with minimum reactor coolant temperatures above 212*F.

The HPCI, RCIC, ADS, and S/RV Systems are required to be operable by Technical Specifications 3. 5.1, 3. 7. 3, 3. 5.2, and 3.4.2.1, respectively, and primary containment integrity is required to be maintained by Technical Specification 3.6.1.1, whenever the reactor is in the POWER OPERATION, STARTUP, or HOT SHUTDOWN (i.e., reactor coolant temperature greater than 212*F) conditions with reactor vessel steam dome pressure greater than 150 psig. During hydrostatic and leak testing, when the minimum allowed coolant temperature is above 212*F, these criteria are met. However, when performing these tests with non-nuclear heat, the primary system will be water solid, and no steam will be available to drive the HPCI and RCIC turbines. Thus, the HPCI and RCIC Systems cannot be physically operable for performance of the tests. In addition, i performance of non-nuclear hydrostatic testing will require test pressures greater than the lift pressures for the S/RVs. In order to '

perform the test, the S/RVs must be gagged to prevent their opening.

Because of this, the Technical Specifications requirements for the S/RVs and the ADS must be addressed. Finally, to allow frequent and 1790C El-2 01/04/88 SL-3864

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! ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

HYDROSTATIC AND LEAK TESTING AB0VE 212*F USING NON-NUCLEAR HEAT BASIS FOR CHANGE RE0 VEST unobstructed access to potential leakage points inside containment during primary system leakage inspections, Technical Specifications relief is necessary to allow continued unimpeded access to containment. The footnote added to Technical Specifications Table 1.2, allowing the reactor to be considered in COLD SHUTDOWN during hydrostatic or leak testing when reactor coolant temperature is above 212*F, will effectively provide an exemption to the requirements that the HPCI, RCIC, ADS, and S/RV Systems be operable and that primary containment integrity be maintained during these tests. Since the hydrostatic or leak tests are performed water solid, with all control rods fully inserted, at low decay heat values (no critical operation for the length of the outage), and at or near COLD SHUTDOWN conditions, the stored energy in the reactor core will be very small. Under these conditions, the potential for failed fuel and subsequent increase in coolant activity above Technical Specifications limits is mitigated. In addition, the secondary containment will be operable in accordance with Technical Specifications 3.6.5.1, 3.6.5.2, and 3.6.6.1 (Proposed Change 2) and will be capable of handling any airborne radiation or steam leaks that could occur during the performance of hydrostatic or leak testing. It should also be noted that the Technical Specifications operability requirements for the Low Pressure Coolant Injection (LPCI) System, Section 3.5.3.2, and for the Core Spray (CS) System, Section 3.5.3.1, will not be affected by this change. In the event of a large primary system leak, the reactor vessel would depressurize to a level allowing the low-pressure core cooling systems to operate. 'The capability of LPCI and CS would be more than adequate to keep the core cool under this low decay heat load condition.

Small system leaks would be detected by leakage inspections before significant inventory loss occurred.

Therefore, the intended function of the HPCI, RCIC, ADS and S/RV Systems, as well as primary containment integrity, are not required when hydrostatic or leak tests are being performed. This proposed change is consistent with previous NRC-approved Plant Hatch Unit 1 Technical Specifications changes (Reference 1) which eliminated the requirement for system operability during testing when the reactor coolant temperature is above 212*F.

PROPOSED CHANGE 2:

Proposed Change 2 modifies the Technical Specifications to require the integrity of secondary containment, as well as the operability of the Standby Gas Treatment (SBGT) System, during the performance of 1790C El-3 01/04/88  ;

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ENCLOSURE 1 (Continued)

REOUEST TO REVISE TECHNICAL SPECIFICATIONS:

HYDROSTATIC AND LEAK TESTING AB0VE 212*F USING NON-NUCLEAR HEAT BASIS FOR CHANGE REOUEST hydrostatic or leak testing when the reactor coolant temperature is above 212*F. This proposed change is required due to the redefining of HOT

-SHUTDOWN and COLD SHUTDOWN proposed in Change 1. Specifically, notes requiring operability when coolant temperature is above 212*F during pressure testing will be added to Table 3.3.2-1 (Isolation Actuation Instrumentation), Section 3.6.5.1 (Secondary Containment Integrity).

Section 3.6.5.2 (Secondary Containment Autcmatic Isolation Dampers), and Section 3.6.6.1 (Standby Gas Treatment System).

Basis for Procosed-ChangeJ :

As discussed in Proposed Change 1, primary containment integrity will no longer be required when performing hydrostatic or leak tests with reactor coolant temperature above 212*F. The consequences of testing above 212*F are potential steam, rather than water, leaks. Under the testing conditions of a non-critical core with low decay heat, the amount of radioactivity contained in postulated steam leaks will be very small and well within the capabilities of the secondary containment and the SBGT System. The consequences of a steam leak under pressure testing conditions with secondary containment integrity will be conservatively bounded by the consequences of the main steam line break (outside of secondary containment) accident analysis described in Subsection 15.1.40 of the Plant Hatch Unit 2 Final Safety Analysis Report (FSAR).

Therefore, requiring secondary containment integrity will ensure that any potential airborne radiation from steam leaks will be filtered through the SBGT System to limit radiation releases to the environment. The NRC staff has previously approved (Reference 1) a similar Technical Specifications change for Plant Hatch Unit I which concluded that the i

secondary containment is capable of containing, with minimal consequences, any potential leakage under the proposed hydrostatic or leak test conditions.

PROPOSED CHANGE 3:

Technical Specifications Section 3.7.1.1, Residual Heat Removal Service Hater (RHRSU) System, requires, in part, that the system be operable when in the HOT SHUT 00HN condition (i.e., with average reactor ccolant temperature greater than 212*F). The modifications to the definitions of HOT SHUTDOWN and COLD SHUTDOWN proposed in Change 1 will result in the RHRSH System no longer being required to be operable when performing a hydrostatic or leak test with coolant temperatures above 212*F. Proposed 1790C El-4 01/04/88 SL-3864

l ENCLOSURE 1 (Continued)

REQMESLIO REVISE TECHNICAL SPECIFICAJ10NS:

HYDROSTATIC AFLD LEAK TESTING _

AA0VE_21R*E.1SLN_Ci NON-NUCLEAR HEAT BASLS FOR CHANGE REQRESI Change 3 effectively reimposes the operability requirement on the RHRSW System when performing these tests at elevated temperatures. Proposed Change 3 also adds appropriate ACTION statements for the pressure test j conditions. '

E_qsi Lfor Procoig.d Chamge_3:

As described in Proposed Change 1, CS and the LPCI mode of the Residual Heat Removal (RHR) System will be operable during pressure testing above 212*F and, in tne event of a- primary system leak, are more than adequate to keep the core cool. The operability of the RHRSW System ensures that sufficient cooling capacity is available for continued operation of the low-pressure cooling systems. Since the stored energy in the reactor core, under pressure testing conditions (e.g., low decay heat loads, large heat sink with the vessel water solid), is small; large RHRSW capacity is not required. Therefore, allowing three RHRSW pumps to be inoperable for up to 7 days is acceptable under hydrostatic and leak testing conditions.

REFERfJLCf:

1. Letter, L. P. Crocker (NRC) to J. P. O'Reilly (GPC), " Issuance of Amendment No.137 to Facility Operating License DPR-57-Edwin I. Hatch Nuclear P? ant, Unit 1," May 26, 1987.

1790C El-5 01/04/88 SL-3864 1

L l ENCLOSURE 2 i PLANT HATCH - UNIT 2 NRC DOCKET 50-366 OPERATING 1.ICENSE NPF-5 RE00EST TO REU1LIEGNICAL SPECIFICATIONS 1 H1DRO. STATIC.JND_ LEAK TfSTING ABQVE 2.12*F USING NON-NUCLEAR HEAT 10 CFR 50.92 EXALUATION PROPDSED CHANGE 1:

This proposed change adds a footnote to Technical Specifications Table 1.2, modifying the Operational Conditions definitions of HOT SHUTDOWN and COLD SHUTDOWN. This change effectively provides exemption to the l operability requirements for the HPCI, RCIC, ADS, and S/RV Systems, as well as primary containment integrity, during non-nuclear hydrostatic and leak testing when reactor coolant temperatures are above 212*F. Since the hydrostatic or leak test is performed water solid, with all rods inserted into the reactor core, at low decay heat values, and at or near COLD SHUTDOHN conditions, the stored energy in the reactor core will be very small. The high-pressure emergency core cooling and overpressurization protection functions mentioned above are incapable of ft;nctioning because of test conditions that are NRC mandated. Thus, the effective change io the operability requirements of the above mentioned systems is necessary and appropriate.

Under the conditions of the pressure testing, the amount of reactivity contained in any postulated steam leak will be very small and well within the capabilities o f_ the secondary containment and the SBGT System.

Therefore, primary containment integrity need not be maintained so that potential leakage points inside containment can be readily inspected during pre:sure tests.

Basis for No Significant Hazards Consideration Determingiip_n:

The proposed change does not involve a significant hazards consideration for the following reasons:

1. It does not involve a significant increase in the probability or consequences of an accident previously evaluated, because the hydrostatic and leak tests to which this change apply, occur with minimal primary system energy due to the fact that all control rods are inserted, and that low temperature and low fuel decay heat values are established. Under these test conditions, the LPCI and CS systems will function to ensure that a significant increase in the consequences or the probability of  ;

an accidert will not occur. Emergency Core Cooling, j overpressure protection, and primary containment functions are '

not required.

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ENCLOSURE 2 (Continued)

EfDREST TO REVISLTLCHNICAL SPECIFICATIONS 1_

HYOR0 STATIC ANRMAK TESTING AB0VE 212*F USING NON-NV_ CLEAR HE_AT JO CFR 50.91_EVALQATION l 2. The proposed change does not create the possibility of a new or l different kind of accident from any previously analyzed, because l

no change in plant design or operation will occur as a result of this change. This change only provides for performance of ASME Code-required hydrostatic and leak testing with all control rods 5 inserted.

3. The proposed change does not involve a significant reduction in the margin of safety, because plant operation is not affected and analyzed margins of safety are unchanged.

RRDPQSEQ CHANGE 2:

This proposed change will require secondary containment integrity and operability of the SBGT System during the performance of hydrostatic and leak testing when reactor coolant temperature is above 212*F. The consequences of testing above 212*F are potential steam, rather than water, leaks. Under the conditions of the pressure tests, the amount of radioactivity contained in postulated steam leaks will be very small and well within the capabilities of secondary containment cnd the SBGT System. The secondary containment is designed to handle the consequences of airborne radiation and steam leaks and will te operable (per this proposed change) for the performance of hydrostatic and leak testing.

The consequences of a steam leak under pressure testing conditions, with secondary containment integrity, are conservatively bounded by the consequences of the main steam line break (outside of containment) accident described in the Plant Hatch Unit 2 FSAR, Subsection 15.1.40.

fbsis for NQ SigD_ificant HazardLConsideration Determination:

The proposed change does not involve a significant hazards consideration for the following reasons:

1. It does not involve a significant increase in the probability or consequences of an accident previously evaluated, because the pressure tests occur with minimal primary system energy, and the secondary containment systems are capable of containing any potential leakage under the test conditions.

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ENCLOSURE 2 (Continued)

REQUEST TO FiVISE TECHNICAL SPECIFICATIONS:

HYDROSTATIC AND LEAK TESTING AB0VE 212*F USR G NON-NUCLEAR HEAT 10 CFR 50.92 EVALUATION

2. The proposed change does not create the possibility of a new or different kind of accident from any previously evaluated, because the change does not represent a change to plant design or operation. The proposed change only requires the operability of existing plant systems under hydrostatic and leak testing conditions.

3. The proposed change does not involve a significant reduction in i the margin of safety, because plant operation is not affected and analyzed margins of rty are unchanged. '

i ERQEQS_E0 CHANGE 3:

This proposed change requires the operability of the RHRSH System (with appropriate ACTION statements) during pressure tests when reactor coolant temperature is above 212*F.

Basis for No Significant Hazards Consideration Determination:

The proposed change does not involve a significant hazards consideration for the following reasons:

1. It does not involve a significant increase in the probability or consequences of an accident previously evaluated, because of the minimal primary system stored energy present during the pressure tests. The existing low-pressure cooling systems and the RHR System are more than adequate to keep the core cool in the event of a primary system leak under test conditions.

2. The proposed change does not create the possibility of a new or di fferent kind of accident from any previously evaluated, because this proposed change does not represent a change to plant design or operation. The change only requires the ;

operability of an existing plant system under hydrostatic and  ;

leak testing conditions. '

3. The proposed change does not involve a significant reduction in the margin of safety, because plant operation is not affected and analyzed margins of safety are unchanged.

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