ML20237C779

Safety Evaluation Supporting Amends 149 & 86 to Licenses DPR-57 & NPF-5,respectively

ML20237C779
Person / Time
Site:	Hatch
Issue date:	12/01/1987
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20237C778	List: ML20237C775 ML20237C779
References
GL-83-43, TAC-55713, TAC-55714, NUDOCS 8712220168
Download: ML20237C779 (8)

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENTS NOS.149 AND 86 TO FACILITY OPERATING LICENSES DPR-57 AND NPF-5 GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECIRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-321 AND 50-366 7

1.

INTRODUCTION By submittal dated February 13,1987 (Reference 1) Georgia Power Company (GPC, the licensee) proposed changes to the Technical Specifications (TS) for the Edwin I. Hatch Nuclear Plant, Units 1 and 2, to revise the reporting requirements to conform to Sections 50.72 and 50.73 of 10 CFR Part 50; and to revise the reporting requirements regarding the iodine activity level in the primary coolant and delete the requirement for plant shutdown in the event iodine activity level in the primary coolant exceeds the limits for more than 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12-month period. The proposed changes to the reporting requirements to bring the TS into conformance with 10 CFR Part 50, Sections 50.72 and 50.73 are in response to NRC Generic Letter 83-43 (Reference 2), while the proposed changes regarding reporting and plant shutdown as a result of high iodine activity levels are in response to NRC Generic Letter 85-19 (Reference 3).

II.

EVALUATION The proposed changes are divided into 12 parts as discussed and evaluated below:

2.1 Proposed Change 1:

This proposed change would add to the Unit 1 Technical Specifications Definitions Section the term REPORTABLE EVENT.

This proposed change would also delete from the Unit 2 Technical Specifications Definitions section the term REPORTABLE OCCURRENCE and replace it with the term REPORTABLE EVENT, as follows:

A " REPORTABLE EVENT" shall be any of those conditions specified in Section 50.73 to 10 CFR Part 50.

This change would appear in Unit 1 Technical Specifications Section 1.0, item III.

The change would also appear in Unit 2 Technical Specifications Section 1.0 These changes are administrative in nature, changing the definitions appearing in the TS of the two units to conform to the wording presented in Generic Letter 63-43.

They are. therefore, acceptable.

871222016e 871201 PDR ADOCK 05000321 PDR

i l 2.2 Proposed Change 2:

This proposed change would relocate the reporting requirements for the failure or malfunction of any safety / relief valve from Section 6.9.1.12 of the Units 1 and 2 Technical Specifications to Section 3.6.H.1.a of the Unit 1 Technical Specifications and section 3.4.2.1.f of Unit 2 Technical Specifications. The written followup report requirement would be changed from 14 days to 30 days.

This reporting requirement is being relocated rather than deleted, because certain types of safety / relief valve malfunctions (e.g., the opening of a relief valve at a pressure lower than the setpoint) do not fall under the provisions of 10 CFR 50.72(b)(1)(ii) or 10 CFR Part 50.73(a)(2)(ii). These types of malfunctions should still be reported 1

in accordance with ' Item II.K.3.3 of NUREG 0737 Failures or l

malfunctions of safety / relief valves, which do not fall under the provisions of 10 CFR 50.72 and 10 CFR 50.73, would still be subject to the reporting requirements contained herein. The change in the written I

followup report requirement from 14 to 30 days is made to be consistent with the requirements of 10 CFR 50.73.

These proposed changes modify the reporting requirements to be consistent with 10 CFR 50.72 and 10 CFR 50.73, while still retaining the requirement for near-term reporting of safety / relief valve malfunctions that do not fall under the provisions of 10 CFR 50.72 and 10 CFR 50.73.

They are, therefore, acceptable.

2.3 Proposed Change 3:

This proposed change would delete from the Unit 2 Technical Specifications the Special Report requirements for:

(1) High Pressure Coolant Spray System (CSS)ystem actuation contained in Section 3.5.1.c. (2) Core Injection (HPCI) s 1

actuation contained in Section 3.5.3.1.a.3, and (3)

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Low Pressure Coolant Injection (LPCI) system actuation contained in Section 3.5.3.2.a.4.

These Special Reports are no longer required and may be deleted, because any actuation of these Emergency Core Cooling Systems (ECCS) is required to be reported under the:

1.

Immediate notifications provisions of 10 CFR 50.72(b)(1)(iv) for "Any event that results or should have resulted in l

Emergency Core Cooling System (ECCS) discharge into the reactor coolant system as a result of a valid signal."

2._

Immediate notification provisions of 10 CFR 50.72(b)(2)(ii) for l

"Any event or condition that results in manual or automatic actuation of an Engineered Safety Feature (ESF)." Each system identified above as part of the ECCS is also an ESF system.

Also, written notification within 30 days is required by 10 CFR 50.73 (a)(2)(iv), which states that the licensee shall report "Any event or condition that resulted in manual or automatic actuation of any Engineered Safety Feature (ESF)."

10 CFR 50.73(g) states: "The requirements contained in this section replace all existing requirements for licensees to report " Reportable Occurrences" as defined in individual plant Technical Specifications." Deletion of these Special Reports from the TS is in accordance with the requirements of 10 CFR 50.73 and, therefore, is acceptable.

2.4 Proposed Change 4:

This proposed change would relocate the reporting requirements for Type B and Type C Leakage Tests from Unit I and Unit 2 Technical Specifications Sections 6.9.1.13 (which are proposed for deletion) to

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Sections 4.7. A.2.f and 4.7. A.2.g of the Unit 1 Technical Specifications and to Section 4.6.1.2.d of the Unit 2 Technical Specifications. The reporting requirements will continue to reflect the fact that one 30-day written report may be submitted within 30 days of the first leakage test failure which occurs during the outage, and that all other leakage test failures discovered during the outage will be reported in a revision to the original report, due within 30 days following the completion of the outage.

This relocation of reporting requirements is consistent with the requirements of 10 CFR 50.73, is clarifying in nature, and does not represent any change to the design, operation, or safety of the plant.

It is, therefore, acceptable.

2.5 Proposed Change 5 Existing TS 3.3.6.2.a for Unit 2 requires a special 10 day report to be submitted in the event any of the required seismic monitoring instrumen-tation is inoperable for a period of more than 30 days.

Existing TS 4.3.6.2.2 for Unit 2 requires a special report to be submitted within 10 days describing the magnitude, frequency spectrum and resultant effect of any seismic event on the features of the plant that are important to safety.

In each case, a clause in these existing TS states that these reports are to be submitted "in lieu of any other report required by Specification 6.9.1."

Generic Letter 83-43 stated that:

"Sor Technical Specifications currently require Special Reports or other routine reporting of events in lieu of a Licensee Event Report. Such reports are still required but the technical specification wording will need revision.

These changes, where applicable, should also be included in your amendment request to modify your technical specifications."

TS 6.9.1.11, " Reportable Occurrences", in the existing TS is to be deleted by this amendment. Thus, consistent with the instructions in the generic letter, the licensee proposes to substitute "10 CFR 50.73" for the words

" Specification 6.9.1" in the clauses of TS 3.3.6.2.a and TS 4.3.6.2.2.

However, seismic monitoring instrumentation is not subject to the reporting requirements of 10 CFR 50.73. Therefore, rather than make the wording

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i substitution requested by the licensee, the NRC staff has elected simply to delete the clauses. The resultant wording still requires the special 10-day reports as required by the existing TS and thus represents no change to the TS requirements.

The changes are, therefore, acceptable.

This change to the licensee's request has been discussed with and is acceptable to the licensee.

It does not represent a substantive change from the licensee's original request (Reference 1) as noticed in the Federal Register on July 15, 1987.

2.6 Proposed Change 6:

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This proposed change would revise the wording of TS Section 4.8.1.1.4 to require that all diesel generator failures be reported pursuant to the new 10 CFR 50.73 rather than pursuant to the existing Specification 6.9.1.

The change also provides for submission of the reports to the Regional office as well as to NRC headquarters. This change is in accordance with the instructions of Generic Letter 83-43 and is, therefore, acceptable.

2.7 Proposed Change 7:

This proposed change would delete Section 3.11.D and Bases 3.11.D from the Unit 1 Technical Specifications.

Section 3.11.D presently provides that a Reportable Occurrence report shall be submitted for any event in which any of the limiting values of the Average Planar Linear Heat Generation Rate (APLHGR), the Linear Heat Generation Rate (LHGR), or the Minimum Critical Power Ratio (MCPR) are exceeded.

In accordance with 10 CFR 50.73(g), it is no longer necessary to retain a specific section in the Unit 1 Technical Specifications delineating the reporting requirements for this type of event.

If a limiting value of APLHGR, LHGR, or MCPR is exceeded, and the required Technical Specification Action statement is not met, reporting under 10 CFR 50.73 (a)(2)(1)(B) is appropriate. This change, therefore, is acceptable.

2.8 Proposed Change 8:

This proposed change would revise the Unusual or Important Events reporting requirements listed in Section 4.2 of the Unit I and 2 Environmental Technical Specifications (ETS) so that reports are made as required by 10 CFR 50.72 and 10 CFR 50.73 rather than in accordance with ETS Section 5.6.2 which would be deleted. Also, the proposed change would reword the reporting requirements stated in Section 4.3 of the Unit I and 2 ETS so that in the case of a reportable event in which a limit specified in a relevant permit or certificate issued by another Federal, State, or local agency is exceeded, the report would be submitted within the time limit specified by the reporting requirements of the corresponding certification or permit issued pursuant to Section 401 or 402 of PL 92-500.

The report which would be sent to the NRC l

would consist of a copy of the report which would be made to the Georgia Departmert of Natural Resources, Environmental Protection Division.

l These reportable event reporting requirements are currently contained in l

- _ - _ _ _ - _ _ i Section 5.6.2.

In addition, the proposed change would delete Sections j

5.6.2 of the Unit 1 and 2 ETS which contain the reporting requirements i

for non-routile reports.

1 Reporting requirements for unusual or important environmental events are i

covered under the provisions of 10 CFR 50.72(b)(2)(vi),10 CFR 50.73 (a)(2)(fii) and 10 CFR 50.73(a)(2)(x). Therefore, the reference to the reporting requirements presented in 10 CFR 50.72 and 10 CFR 50.73 is appropriate. The rewording of the reporting requirements stated in Section 4.3 does not constitute a change in the reporting requirements.

l but is merely a relocation of those requirements from Section 5.6.2 to i

Section 4.3, and a replacement of the term REPORTABLE OCCURRENCE with l

the term REPORTABLE EVENT. This change is consistent with 10 CFR 50.73 and

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is, therefore, acceptable.

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2.9 Proposed Change 9:

This change would modify Section 3.4.4.a.1 of the Unit 2 Technical Specifications by deleting the reference to Section 6.9.1.9 reporting requirements and adding a reference to the Special Report requirements of Section 6.9.2 of the TS. This change is consistent with the

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instructions of Generic Letter 83-43 and is acceptable.

2.10 Proposed Change 10:

This proposed change would delete from Section 4.6.1.5 of the Unit 2 Technical Specifications the sentence:

"Any abnormal degradation of the primary containment detected during the required inspections shall be reported to the Commission pursuant to Specification 6.9.1."

The

" required inspections" occur during shutdown.

Basis for Proposed Change:

This reporting requirement would be deleted because any event such as this, found while the reactor is shut down, that, had it been found while the reactor was in operation, would have resulted in the nuclear power plant, (including its principal safety barriers) being seriously degraded, requires a Four-Hour Report under the provisions of 10 CFR 50.72(b)(2)(i).

In addition, any event or conditions such as this which resulted in the condition of the nuclear power plant, including its principal safety barriers being seriously degraded would require a Licensee Event Report written notification within 30 days under the provisions of 10 CFR 50.73 (a)(2)(ii). Deletion of this sentence is consistent with 10 CFR 50.73(g1 and is, therefore, acceptable.

2.11 Proposed Change 11:

This proposed change would revise the ADMINISTRATIVE CONTROLS sections and associated TABLE OF CONTENTS and INDEX to reflect the revised immediate notification requirements of 10 CFR 50.72 and the Licensee Event Report system requirements of 10 CFR 50.73. Unit 1 Technical Specifications Sections 6.5.1.6.f. 6.5.2.7.g. 6.6, 6.6.1.a. 6.6.1.b,

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6.7.1.b, 6. 7.1.c, 6. 7.1.d. 6. 9, 6.10.1.c and Tabl e 6.9.1.7-1 woul d be appropriately reworded; and Sections 6.9.1.11, 6.9.1.12 and 6.9.1.13 l

would be deleted. Unit 2 Technical Specifications Section 6.9 of the Index, Sections 6. 5.1. 6.f, 6. 5. 2. 7.g, 6. 6, 6. 6.1.a. 6. 6.1.b

6. 7.1.b,

6.7.1.c. 6.7.1.d, 6.9, 6.10.1.c. and Table 6.9.1.7-1 would be appropriately reworded; and sections 6. 9.1.11, 6.9.1.12, and 6.9.1.13 would be deleted.

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These changes would make modifications of an administrative nature to the Unit I and 2 Technical Specifications, as specifically directed by Generic Letter 84-43, in order to incorporate the current reporting requirements stated in 10 CFR Part 50, Sections 50.72 and 50.73. These

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changes are consistent with the model technical specification presented in Standard Technical Specifications format in NRC Generic Letter 83-43, and are in accordance with 10 CFR 50.73(g).

They are, therefore, acceptable.

2.12 Proposed Change 12:

This proposed change would make the following revisions to the Technical Specifications pursuant to Generic Letter 85-19, " Reporting Requirements on Primary Coolant Iodine Spike,":

l In the Unit 1 Technical Specifications:

1.

Delete the second paragraph of Section 3.6.F.1 which specifies iodine activity limits within a 12-month period.

2.

Change the third paragraph of Section 3.6.F.1 to redefine the activity concentration limits.

3.

Change the last paragraph of Section 4.6.F.1 to remove the 30-day reporting requirement.

4.

Add paragraph 6.9.1.5.c (relocate existing paragraph 6.9.1.5.c to 6.9.1.5.d) to include requirements for an Annual Report.

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In the' Unit 2 Technical Specifications:

I 1.

Delete paragraph 3.4.5.a.1 which limits iodine activity limits in a 12-month period.

2.

Renumber paragraph 3.4.5.a.2 to 3.4.5.a.1 and redefine the activity concentration limits.

3.

Renumber paragraph 3.4.5.a.3 to 3.4.5.a.2.

4 Change paragraph 3.4.5.b.1 to remove the REPORTABLE OCCURRENCE report requirement.

I 5.

Change paragraph 3.4.5.b.2 to remove the 92-day Special Report j

requirement, j

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Add paragraph 6.9.1.5.c (relocate existing paragraph 6.9.1.5.c

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to 6.9.1.5.d) to include requirements for an Annual Report.

This change would make modifications to the Technical Specifications, as directed by Generic Letter 85-19. The reporting requirements for iodine spiking contained in the Technical Specifications would be changed from a short-tem report to an item for inclusion in the Annual report.. The infomation to be included in the Annual Report is similar to that previously required but has changed to more clearly designate the results to be included from the specific activity analysis and to delete the information regarding fuel burnup by core region. Also, the existing requirements contained in the Technical Specifications for plant shutdown, if coolant iodine activity limits are exceeded for 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12-month period, would be removed.

These changes are justified because, as discussed in Generic Letter 85-19, the quality of nuclear fuel has been greatly improved over the past decade with the result that normal coolant iodine activity (i.e.,

in the absence of iodine spiking) is well below the limit. Appropriate actions would be initiated long before accumulating 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> above the iodine activity limit.

In addition, 10 CFR 50.72 (b)(1)(ii) requires the NRC to be immediately notified of fuel cladding failures that exceed expected values or that are caused by unexpected factors.

Therefore,

this Technical Specification limit is no longer necessary on the basis that proper fuel management and existing reporting requirements should preclude ever approaching the limit.

Plant Hatch would continue to monitor iodine activity in the primary coolant and take responsible actions to maintain it at a reasonably low level (i.e., accumulated time with high iodine activity would not approach 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br />). These changes are, therefore, acceptable.

3.0' ENVIRONMENTAL CONSIDERATION The amendments involve a change in use of facility components located within the restricted area as defined in 10 CFR Part 20 and changes in reporting requirements. The staff has detennined that the amendments involve no signif-icant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there should be no signif-icant increase in individual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration and there has been no public connent on such finding. Accordingly, the amendments meet the eligibility to 10 CFR 651.22(gorical exclusion set forth in 10 CFR 651.22(c)(9).

criteria for cate Pursuant b), no environmental impact statement or environmental assess-ment need be prepared in connection with the issuance of the amendments.

4.0 CONCLUSION

The Commission made a proposed determination that the amendments involve no significant hazards consideration which was published in the Federal Register (52 FR 26587) on July 15, 1987, and consulted with the state of Georgia. No public comments were received, and the state of Georgia did not have any comments.

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' I We have concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be en-dangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations, and the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

REFERENCES 1.

Letter from James P. O'Reilly, Georgia Power Company. to the NRC, dated February 13, 1987.

2.

Letter from Darrel G. Eisenhut, NRC, to all licensees and applicants for operating power reactors and holders of construction permits for operating reactors, " Reporting Requirements of 10 CFR Part.50, Sections 50.72 and 50.73, and Standard Technical Specifications (Generic Letter 83-43), dated December 19, 1983.

3.

Letter from Hugh L. Thompson, NRC, to all licensees and applicants for operating power reactors and holders of construction permits for power reactors, " Reporting Requirements on Primary Coolant Iodine Spikes (GenericLetter85-19), September 27, 1985.

Principal Contributor:

L. Crocker i

Dated:

December 1, 1987 l

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