ML20237H865

Application for Amends to Licenses DPR-57 & NPF-5,revising Tech Specs to Provide Consistency & Clarity to Definition of Term Operability in Definitions Sections.Fee Paid

ML20237H865
Person / Time
Site:	Hatch
Issue date:	08/19/1987
From:	James O'Reilly GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20237H869	List: ML20237H865 ML20237H884
References
SL-2604, TAC-66099, NUDOCS 8708250177
Download: ML20237H865 (11)

Text

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Georgia Power Company j 333 thedmont Avenue  !

. Atlanta, Georgia 30308 Te!ephone 404 526 7851 I Ma*ng Address: l Post office Box 4545 l Atlanta, Georgia 30302 James R O'Reilly the sc>athern ee:tre s clern Senior Vice P:esident Nuclear Operations j

SL-2604 1411C X7GJ17-H600 August 19, 1987

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U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D. C. 20555 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

DEFINITION OF OPERABILITY 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 Units 1 and 2 Technical Specifications, Appendix A to Operating Licenses DPR-57 and NPF-5.

The proposed changes would serve to provide consistency and clarity to the definition of the term " operability" as contained in the Definitions sections of the Plant Hatch Units 1 and 2 Technical Specifications.

Enclosure 1 provides a detailed description of the proposed changes and the basis for the changer.

Enclosure 2 details the basis for our determination that the I

proposed changes do not involve a significant hazards consideration.

Enclosure 3 provides page change instructions for incorporating the proposed changes into the Unit I and Unit 2 Technical Specifications.

The proposed changed Technical Specifications pages follow Enclosure 3.

B708250177 070819 R$d N PDR P

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9 U. S. Nuclear Regulatory Commission August 19, 1987 Page Two 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 amendments, 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

~ E. 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 this letter and enclosures are true.

GEORGIA P0HER COMPANY By: AM- D hk James P. O'Reilly Sworn to and subscribed before me t dat day of August 19 .

m1 JJ 7]f ~

V/ ~ Notary Putilic " ' ~

Notary Pubhc. Clayton County, Georgia REB /1c  % Commission Enires Dec. 10,1989

Enclosures:

1. Basis for Proposed Change

2. Significant Hazards Consideration

3. Change Instructions

4. Filing Fee - $150.00 c: '(see next page) 1411C

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I U. S. Nuclear Regulatory Commission l August 19, 1987 Page Three 1

l c: Georaia Power Comoany Mr. J. T. Beckham, Jr., Vice President - Plant Hatch GO-NORMS U. S. Nuclear Reaulatory Commission. Washinaton Mr. L. P. Crocker, Licensing Project Manager - Hatch U. S. Nuclear Regulatory Commission. Reaion II Dr. J. N. Grace, Regional Administrator Mr. P. Holmes-Ray, Senior Resident Inspector - Hatch State of Georaia Mr. J. L. Ledbetter 1411C

1 ENCLOSURE 1 PLANT HATCH - UNITS 1, 2 NRC 00CKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

DEFINITION OF OPERABILITY BASIS FOR CHANGE RE00EST The NRC has previously requested that the definition of operability, contained in the Technical Specifications, be updated to reflect operability requirements for support systems. For plants, such as Hatch Unit 1, which do not utilize Standard Technical Specifications (STS),

this change would be effected through adoption of the Standard Technical Specifications (STS) operability definition, which provides for explicit requirements for support systems. For all plants, including plants such as Hatch Unit 2 which do utilize STS, NRC provided section 3.0.5 of the STS to allow an exception to the STS operability definition addressing unavailability of normal or emergency power supplies.

Prooosed Change for Unit 1:

Plant Hatch Unit 1 Technical Specifications were issued with the original definition of operability, which does not take into account functionality of support systems. Georgia Power Company's (GPC's) submittal of May 4, 1984, as supplemented September 12, 1984, proposed to update the Plant Hatch Unit 1 operability definition to incorporate the STS definition and Section 3.0.5 exceptions as described above. A Technical Specifications Amendment incorporating the proposed Unit 1 changes has not yet been issued. GPC now requests that the following minor revision be made to the previous change request:

Since Plant Hatch Unit 1 Technical Specifications are not in STS format, and contain no Section 3/4.0 Specifications, the 3.0.5 exceptions were proposed to be added to the body of the definition in the above submittals. The LC0 added to the definition in GPC's September 12, 1984, submittal was 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to Hot Shutdown, followed by Cold Shutdown in the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. However, Specification 3.0.5 of the Unit 2 Technical Specifications was added by Amendment 49 with a "6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to Hot Shutdown and 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> to Cold Shutdown" LCO. In order to provide for consistency between the units, it is hereby requested that the September 12, 1984 submittal for Plant Hatch Unit 1 be modified to reflect the same LC0 times as the existing Unit 2 Specification 3.0.5. The changed page provided following Enclosure 3 reflects this revision and serves to replace the like page contained in the September 12, 1984, submittal.

The enclosed page reflects additional changes proposed in the September 12, 1984 submittal. Since no further revisions are being reauested to those changes, they remain as described in the previous submittal.

1411C El-1 8/19/87 SL-2604

ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

DEFINITION OF OPERABILITY BASIS FOR CHANGE RE00EST Propmftd_ Changes for Unit 2:

Minor revisions are requested to Specification 3.0.5 of the Plant Hatch Unit 2 Technical Specifications to provide for clarification and ensure consistency with the Unit 1 Operability definition as proposed by letter of September 12, 1984. Three areas of change are requested as specified below:

Section 3.0.5 now begins "When a system, subsystem, train, component, or device is determined to be inoperable...". The fi rst change would add clari fying words to this statement to explicitly state that the scope of this requirement applies only {

to those systems "having Technical Specifications operability '

requirements." This editorial change provides for clari ty and consistency with the previously proposed Unit 1 changes and does I not affect the intent of this Specification.

The second change would add a provision allowing the option of entry into the LC0 contained in the body of the Technical Specifications, for a specific system which loses operability of its normal and emergency power supplies, rather than entry into the Specification 3.0.5 LCO. For certain types of power supply failures, the LC0 provided in Specification 3.0.5 may conflict i with the LC0 provided in the body of the Technical Specifications, '

which covers inoperability of the specific affected equipment. To avoid this potential for conflicting requirements, an allowance is proposed to " enter the applicable Limiting Condition for Operation ,

as specified by the Technical Specifications" or to enter the l l Specification 3.0.5 LCO. This change preserves the safety basis for Specification 3.0.5, but eliminates the potential for conflicting action requirements.

The third change would remove the current provision that Section 3.0.5 is not applicable in the Cold Shutdown and Refuel modes. He believe this provision existed because the 3.0.5 LC0 statement is inappropriate when in the cold shutdown condition. Certain equipment is required to be operable in the cold shutdown and refuel modes. By providing the above allowance to " enter the applicable Limiting Condition for Operation as specified in Technical Specific 1tions," the provisions of 3.0.5 may be extended to this equipment, since the Technical Specifications will contain appropriate actior statements for the cold shutdown and refuel modes. Thus, failures of normal or emergency power supplies alone 1411C El-2 8/19/87 SL-2604

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ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL. SPECIFICATIONS:

DEFINITION OF OPERABILITY BASIS FOR CHANGE RE0 VEST Proposed Chanaes for Unit 2: (Con't) ,

will not result in declarations of equipment inoperability when in the cold shutdown and refuel modes. The safety basis for this allowance is the same as that for the other operating modes where Specification 3.0.5 presently applies. As provided in the Basis for- Plant Hatch Unit 2 Specification 3.0.5, ...The safety analyses are performed assuming .the loss of function of a critical piece of equipment; thus, with a source .of electrical power unavailable, a single failure is still required to reach the conditions analyzed in the FSAR...."

1411C El-3 8/19/87 SL-2604

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

DEFINITION OF OPERABILITY 10 CFR 50.92 EVALUAJION Pursuant to the requirements of 10 CFR 50.92, Georgia Power Company has evaluated the proposed 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 for Plant Hatch Unit 1:

This change would revise the proposed definition of operability, as submitted on September 12, 1984, to change proposed LCO for inoperability of normal and emergency power sources from "12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to hot shutdown - 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to cold shutdown" to "6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to hot shutdown - 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> to cold shutdown."

Basis:

This change is administrative in nature and only serves to provide for consistency with the other 3.0 STS specifications and the Plant Hatch Unit 2 Technical Specifications. There is no safety basis for this change. The ultimate time to cold shutdown of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> is unchanged from the previous submittal. Moreover, since the current Unit 1 Technical Specifications do not contain a definition of operability which requires the exception containing this LCO, the proposed change constitutes an additional requirement. Thus, this change is consistent with Example (ii) of " Examples of Amendments That Are Considered Not Likely to Involve Significant Hazards Considerations..." as provided in the Federal Register, March 6, 1986.

The proposed change does not involve a significant increase in the probability or consequences of an accident because the required action time to achieve cold shutdown is consistent with the approved STS definition and represents an additional requirement.

The possibility of a different kind of accident from those analyzed previously is not created by this change, since the design function of systems, as described in the FSAR, is not affected.

Margins of safety are not significantly reducel by this change. No margins of safety are proposed to be changed. This change only provides a shutdown LC0 consistent with NRC guidance, to complement the new definition of operability.

1411C E2-1 8/19/87 ,

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l ENCLOSURE 2 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

DEFINITION OF OPERABILITY j 10 CFR 50.92 EVALUATION j 1

1 ProDosed Change 1 for Plant Hatch Unit 2:

Specification 3.0.5 now begins "When a system, subsystem, train, l

component, or device is determined to be inoperable...". This change would add clarifying words to this statement to explicitly state that the scope of this requirement applies only to those systems "having Technical Specifications operability requirements." This change provides for j l clarity and consistency and does not affect the intent of this Specification.

Basis:

This change is editorial in nature and serves to explicitly define the scope of the requirement. Thus, this change is consistent with Example (i) of " Examples of Amendments That Are Considered Not Likely to Involve Significant Hazards Considerations..." as provided in the Federal Register, March 6, 1986.

The proposed change does not involve a significant increase in the probability or consequences of an accident because the change only serves to clarify and has no effect on design or operation of equipment. '

The possibility of a different kind of accident from those analyzed previously is not created by this change, since this change does not affect plant operation.

Margins of safety are not significantly reduced by this change. No margins of safety are proposed to be changed. This change only provides clarification of an existing requirement.

Procosed Change 2 for Plant Hatch Unit 2:

This change would add a provision allowing the option of entry into the LC0 contained in the body of the Technical Specifications, for a specific system which loses operability of its normal and emergency power supplies, rather than entry into the Specification 3.0.5 LCO.

Basis:

For certain types of power supply failures, the LC0 provided in Specification 3.0.5 may conflict with the LC0 provided in the body of the <

Technical Specifications, which covers inoperability of the specific affected equipment. To avoid this potential for conflicting requirements, 1411C E2-2 8/19/87 SL-2604 l

ENCLOSURE 2 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

DEFINITION OF OPERABILITY 10 CFR 50.92 EVALUATION an allowance is proposed to " enter the applicable Limiting Condition for Operation as specified by the Technical Specifications" or to enter the Specification 3.0.5 LCO. This change preserves the safety basis for Specification 3.0.5, but eliminates the potential for conflicting action requirements. This change is administrative and clarifying in nature.

The proposed change does not involve a significant increase in the probability or consequences of an accident because the change only serves to eliminate the potential for conflicting action requirements for certain types of equipment failures. The option of entry into the LC0 for the specific equipment is appropriate because that LCO has been reviewed by NRC and found acceptable for the circumstances.

The possibility of a different kind of accident from those analyzed previously is not created by this change, since this only clarifies the applicability of requirements previously analyzed and found acceptable .

l Margins of safety are not significantly reduced by this change. No I

margins of safety are proposed to be changed. This change only provides clarification as to the applicability of a requirement.

Pr_oposed Change 3 for Plant Hatch Unit 2:

This change would remove the current provision that Section 3.0.5 is not applicable in the Cold Shutdown and Refuel modes. Certain equipment is required to be operable in the cold shutdown and refuel modes. By j providing the allowance (See proposed change 2 above.) to " enter the l applicable Limiting Condition for Operation as specified in Technical '

Specifications," the provisions of 3.0.5 may be extended to this equipment, since the Technical Specifications will contain appropriate 1 action statements for the cold shutdown and refuel modes. Thus, failures of normal or emergency power supplies alone will not result in declarations of equipment inoperability when in the cold shutdown and refuel modes.

Basis:

The safety basis for this allowance is the same as that for the other operating modes where Specification 3.0.5 presently applies. As provided in the Basis for Plant Hatch Unit 2 Specification 3.0.5, "...The safety analyses are performed assuming the loss of function of a critical piece 1411C E2-3 8/19/87 SL-2604 i

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e ENCLOSURE 2 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

DEFINITION OF OPERABILITY 10 CFR 50.92 EVALUATION of equipment; thus, with a source of electrical power unavailable, a single failure is still required to reach the conditions analyzed in the FSAR...."

The- proposed change does not involve a significant ' increase in the probability or consequences of an accident because the change only extends the accepted definition of operability to cover the cold shutdown and refuel modes of plant operation.

The possibility of a different kind of accident from those analyzed previously is not created by this change, since the accident analyses are unaffected by the application of the new definition of operability.

Margins of safety' are not significantly reduced by this change. No margins of safety are proposed to be changed. This change only extends the applicability of an accepted requirement to all plant operating modes.

1411C E2-4 8/19/87 SL-2604

e ENCLOSURE 3 PLANT HATCH - UNITS 1 AND 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSE NOS. DPR-57, NPF-5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

DEFINITION 0F OPERABILITY PAGE CHANGE INSTRUCTIONS The proposed changes to the Technirsi Specifications (Appendix A to Operating License DPR-57 and NPF-5) would be incorporated as follows:

UNIT 1 Remove Paae Insert Paae 1.0-3 1.0-3 UNIT 2 Remove Page Insert Page 3/4 0-1 3/4 0-1 l'

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