ML20235J734

Application for Amend to License NPF-68,revising Tech Spec 3/4.3.2 to Remove Refs to Phase a Containment Isolation on High Containment Area Radiation Signal & Tech Spec 3/4.3.3.1 to Correct Ref to ESFAS Spec.Fee Paid

ML20235J734
Person / Time
Site:	Vogtle
Issue date:	07/07/1987
From:	James O'Reilly GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20235J738	List: ML20235J734 ML20235J748
References
SL-2791, NUDOCS 8707150706
Download: ML20235J734 (9)

Text

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, , Georgia Fbwer Company 333 Piedmont Avenue Atlanta, Georgia 30308 Telephone 404 526 7851 Mathng Address:

. Post Office Box 4545 Atlanta, Georgia 30302 rVC re dent Nucluar Operations SL-2791 0392m X7GJ17-V600 July 7,1987 U. S. Nuclear Regulatory Commission ATTN: Docunent Control Desk Washington, D.C. 20555 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 REQUEST TO REVISE TECHNICAL SPECIFICATIONS 3/4.3.2, 3/4. 3.3.1 Gentlemen:

In accordance with the provisions of 10 CFR 50.90 and 10 CFR 50.59, Georgia Power Company (GPC) hereby proposes changes to the Vogtle Electric Generating Pl ant Unit 1 Technical Specifications, Appendix A to Operating License NPF-68.

FeaturesThe first proposed Actuation changESFAS)

System (e revises Specificationto Instrumentation, 3/4.3.2, removeEngineered references Safety to phase "A" containment isolation on a high containment area radiation signal.

This isolation signal, which is derived from high range containment area radiation monitors RE-0005 and RE-0006, is neither required by regulations nor is it necessary to mitigate the consequences of any accident or malfunction analyzed for Plant Vogtle. GPC is proposing to physically remove this feature from the containment isolation system design pending NRC approval of this proposed revision to the Technical Specifications.

The second proposed change revises Specification 3/4.3.3.1, Radiation ibnitoring for Plant Operations, to correct a reference to the ESFAS specification which would no longer be applicable as a result of the first change. This revision is proposed to achieve consistency within the Technical Specifications.

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

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

Enclosure 3 provides instructions for incorporating the proposed changes into the Technical Specifications. The proposed revised Technical Specification pages follow Enclosure 3.

8707150706 870707 PDR ADOCK 05000424 P pyg ggc ry g,ycgM OM f 960ScR7 lll

l V. S. - Nuclear Regulatory Commission July 7,1987 l Page-Two 1

Payment of the. required filing fee is enclosed.

We request that the proposed amendment, once approved by the NRC, be issued with an allowable implementation period of 60 days.

Pursuant to 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 enclosures.

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.

GEORGIA POWER COMPANY

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By; . om L D Sc$-A dames P. O'Reilly Sworn to and subscribed before me this 7th o July 1987.

/_. Notary Public Casia. SW at Large gj ,j .

My Conmission bpires Sept.18,1987

' .Notar'y Public JH/lm

Enclosures:

1. Basis for Proposed Changes

2. 10 CFR 50.92 Evaluation 3.- Instructions for Incorporation c: (see next page) l l

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U. S. Nuclear. Regulatory Commission July 7,1987 i Page Three i

c: ' Georgia Power Company Mr. R. E. Conway Mr. J. P. O'Reilly Mr. G. Bockhold, Jr. .

Mr. J. F. D'Amico. 1 Mr. C. W. Hayes i

GO-NORMS Southern Company Services ,

I Mr. R. A. Thomas Mr. J. A. Bailey.

Shaw, Pittman, Potts & Trowbridge Mr. B. W. Churchill . Attorney-at-Law Troutman, Sanders, Lockerman & Ashmore Mr. A. H. Domby, Attorney-at-Law U. S. Nuclear Regulatory Commission Dr. J. N. Grace, Regional Administrator Ms. M. A. Miller, Licensing Project Manager, NRR (2 copies)

Mr. J. F. Rogge, Senior Resident Inspector-Operations, Vogtle Georgians Against Nuclear Energy Mr. D. Feig Ms. C. Stangler i

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I ENCLOSURE 1 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 BASIS FOR PROPOSED CHANGES PROPOSED CHANGE 1 Revise Tables 3.3-2, 3.3-3, and 4.3-2 to delete references to containment phase "A" isolation on high containment area radiation (monitors RE-0005 and RE-0006).

BASIS

Background

Four area radiation monitors are located inside the containment building to continuously indicate radiation levels at the operating deck. These monitors function as part of the Area Radiation Monitoring System (ARMS) as discussed in Section 12.3.4 of the FSAR. They are considered to be safety-related and are Class lE qualified.

In addition to their ARMS function, these monitors function as part of the Engineered Safety Features Actuation System (ESFAS). The low-range monitors, RE-0002 and RE-0003, are used to initiate containment ventilation system isolation. The high-range monitors, RE-0005 and RE-0006, are used to initiate phase "A" containment isolation. In their role of initiating containment isolation, monitors RE-0005 and RE-0006 provide redundancy to the automatic containment isolation initiated by any signal which initiates safety injection. These signals are:

- manual safety injection actuation

- high containment pressure

- low pressurizer pressure

- low steamline pressure Containment isolation may also be initiated manually.

0392m E1 -1 07/07/87 SL-2791

ENCLOSURE 1 (Continued)

BASIS FOR PROPOSED CHANGES The Technical Specifications contain limiting conditions for operation (LCO) and surveillance requirements for monitors RE-0005 and RE-0006. Specification 3/4.3.2, ESFAS Instrumentation, requires that both channels be operable in Modes 1, 2, 3, and 4. With one channel inoperable, Action 27 requires that the inoperable channel be restored to operable status within 7 days or that the plant be in at least hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, at least hot standby within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and cold shutdown within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Speci fication 3/4.3.3.1, Radiation Monitoring for Plant Operations , ,

lists monitors RE-0005 and RE-0006 and refers to the ESFAS specification for LC0 and surveillance requirements. Specification 3/4.3.3.6, Accident ;

Monitoring Instrumentation, includes monitors RE-0005 and RE-0006 and specifies LC0 and surveillance requirements consistent with an accident monitoring function.

Basis for Proposed Technical Specification Change GPC has reviewed the safety functions of high-range radiation monitors RE-0005 and RE-C006 to determine the impact of their inoperability on plant safety. l This review included a review by Westinghouse and covered all postulated accidents for which the monitors woul d be called upon to function.

Containment phase "A" isolation on high radiation is not a protective function and is not used as a basis in the FSAR Chapter 15 accident analyses. Phase "A" isolation initiation by radiation monitors RE-0005 and RE-0006 is redundant to other features that isolate containment (as discussed above).

For postulated accidents, one of these other features would initiate phase "A" isolation prior to initiation by monitors RE-0005 and RE-0006.

Indeed, phase "A" isolation by these radiation monitors is not included in the Westinghouse standard design basis, and therefore, not included in the blestinghouse Standard Technical Specifications (NUREG-0472). Inclusion of this feature in the Vogtle design, therefore, represents what we believe to be a unique application. l Based on the above, GPC believes that removal of the phase "A" containment isolation function of monitors RE-0005 and RE-0006 from the VEGP containment isolation system is justified. We are therefore proposing to physically remove this feature from the containment isolation system and remove references to this function from the Technical Specifications. We note that the accident monitoring function of monitors RE-0005 and RE-0006 is not affected by the proposed change and will be maintained in accordance with Specification 3/4.34.6. We also note that containment purge and vent valve 0392m El-2 07/07/87 SL-2791 )

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, -j ENCLOSURE 1 (Continued)

BASIS FOR PROPOSED CHANGES isolation on high containment radiation as required by NUREG-0737 Item II.E.4.2(7) is unaffected by the proposed change. This function is provided by monitors RE-0002, RE-0003, RE-2565A, RE-25658, and RE-2565C which remain in the Technical Specifications.

GPC will revise the VEGP FSAR to reflect the removal of the phase "A" isolation on high containment area radiation following NRC review and approval  ;

of the change.

. PROPOSED CHANGE 2 Revise Item la of Table 3.3-4 to_ refer to Specification 3.3.3.6 for operability and action requirements for containment area high range radiation monitors RE-0005 and RE-0006. Revise Item la of Table 4.3-3 to refer to Specification 4.3.3.6 for surveillance requirements for monitors RE-0005 and RE-0006'.

BASIS This ' change - is proposed to achieve consistency within the Technical Specifications. . Specification 3/4.3.3.1, Radiation Monitoring for Plant Operations, lists containment area high range radiation monitors RE-0005 and RE-0006 in Tables 3.3-4 and 4.3-3. Reference is made in- those tables to the ESFAS specification for limiting conditions for operation (LCO). and surveillance requirements. Specification 3/4.3.3.6, Accident Monitoring Instrumentation, lists monitors RE-0005 and RE-0006 in Table 3.3-8 and specifies LC0 and surveillance requirements based on an accident monitoring function. Since proposed change 1 removes the containment isolation function of these monitors from the Technical Specifications, leaving accident monitoring as their primary function, the appropriate LC0 and . surveillance requirements are those contained in the Accident Monitoring Instrumentation specification. The references contained in Specification 3/4. 3. 3.1 are revised accordingly.

0392m El-3 07/07/87 SL-2791

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L ENCLOSURE 2 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 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 implementation woul d not involve significant hazards ,

considerations. The basis for this determination is as follows:

PROPOSED CHANGE 1 Revise Tables 3.3-2, 3.3-3, and 4.3-2 to remove references to phase "A" containment isolation on a high containment area radiation signal (monitors RE-0005 and RE-0006).

BASIS This change does not involve significant hazards considerations for the following reasons:

1. The change does not increase the probability or consequences of an accident or malfunction previously analyzed. Phase "A" containment isolation on a high contain.nent area radiation signal is not required to mf tigate the consequences of any accident or malfunction analyzed for Plant Vogtle. No credit is taken for this isolation signal in the accident analyses described in Chapter 15 of the VEGP FSAR. Containment phase "A" isolation at VEGP is initiated by the redundant and diverse signals which initiate safety injection, i .e. , manual safety injection .

initiation, high containment p"ressure, low pressurizer pressure, and low i steam line pressure. Phase "A isolation can also be initiated manually.

In all accidents and malfunctions analyzed for VEGP, phase "A" isolation is initiated by one of these signals before the high area radiation isolation setpoint is reached. Removal of phase "A" isolation on high containment area radiation from the VEGP containment isolation system design will therefore have no significant safety consequences.

2. The change does not create the possibility of an accident or malfunction j different from any previously analyzed. No new system configuration or j failure mode is created by the change. The high containment area j radiation input to the VEGP containment isolation system will be physically removed such that an unanalyzed malfunction of the containment isolation system could not occur. Operation of the containment isolation system using other automatic or manual initiation signals is not affected by the change.

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l ENCLOSURE 2 (Continued) 10 CFR 50.92 EVALUATION

3. The margin of safety as defined in the basis of the Technical l Specifications is not reduced by the change. The basis for the ESFAS '

Instrumentation Technical Specification is not affected because phase "A" containment isolation on a high containment area radiation signal is not a protective function. It is not required and takes no part in the f mitigation of any accident or malfunction analyzed for VEGP.

Redundant and diverse signals ensure phase "A" isolation in accordance with the FSAR Chapter 15 safety analyses.

PROPOSED CHANGE 2 Revise Item la of Table 343-4 to refer to Specification 3.3.3.6 for operability and actic,n requirements for containment area high range radiation monitors RE-0005 and RE-0006. Revise Item la of Table 4.3-3 to refer to Specification 4.3.3.6 for survefilance requirements for monitors RE-0005 and RE-0006.

BASIS This change is proposed to achieve consistency within the Technical Specifications. It is therefore consistent with Item (1) of " Examples of Amendments That Are Considered Not Likely to Involve Significant Hazards Considerations", listed on page 7751 of the Federal Register, March 6,1986.

This change does not involve significant hazards considerations for the following reasons:

1. The proposed change does not increase the probability or consequences of an accident or malfunction previously analyzed because it is a strictly administrative change which does not affect the operation or testing of i plant equipment. The change corrects a reference to achieve internal consistency.

2. The proposed change does not create the possibility of an accident or malfunction of a different type than any previously analyzed because it is an administrative change which does not introduce any new system configurations or failure modes.

3. The proposed change does not involve a reduction in the margin of safety as defined in the basis of the Technical Specifications because it does not affect the operation or testing of plant equipment. The Technical Specification bascs are therefore not affected.

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ENCLOSURE 3 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 l OPER/; TING LICENSE NPF-68 INSTRUCTIONS FOR INCORPORATION The proposed amendment to the VEGP Unit 1 Technical Specifications (Appendix A  !

to Operating License NPF-68) would be incorporated as follows:

Remove Page Insert Page i

3/4 3-18 3/4 3-18 3/4 3-27 3/4 3-27 '

3/4 3-29 3/4 3-29 3/4 3-38 3/4 3-38 3/4 3-46 3/4 3-46 ,

3/4 3-48 3/4 3-48 l

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