ML20245J599

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Application for Amends to Licenses NPF-68 & NPF-81,revising Tech Spec 3.4.9 & Associated Bases Re Heatup & Cooldown Curves
ML20245J599
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 07/28/1989
From: Hairston W
GEORGIA POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20245J601 List:
References
ELV-00571, ELV-571, GL-88-11, NUDOCS 8908180083
Download: ML20245J599 (5)


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ELV-00571 1222D July 28,.1989 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 YOGTLE ELECTRIC GENERATING PLANT NRC DOCKETS 50-424, 50-425 OPERATING LICENSES NPF-68, NPF-81 REQUEST TO REVISE TECHNICAL SPECIFICATIONS HEATUP AND C00LDOWN CURVES Gentlemen: ,

In accordance with 10 CFR 50.90 and 10 CFR 50.59, Georgia Power Company hereby proposes to amend the Vogtle Electric Generating Plant Technical Specifications, Appendix A to Operating Licenses NPF-68 and NPF-81.

The proposed amendment revises Specification 3.4.9 and the associated bases concerning the applicable number of effective full power years of plant operation for Vogtle Unit 1. Based upon an analysis performed b/ Westinghouse Electric Corporation in response to Generic Letter 88-11, the applicability of the Unit 1 heatup and cooldown curves decreased from 16 EFPY to 13 EFPY. (See letter ELV-00014 dated November 28, 1988). Enclosure 1 provides a detailed description of the proposed change and the basis for the change. Enclosure 2 provides our 10 CFR 50.92 evaluation showing that the proposed change does not involve significant hazards, considerations. Enclosure 3 provides instructions for. the incorporation of the proposed amendment into the Technical Specifications and includes the proposed revised pages.

A copy of this letter and all applicable enclosures will be sent to the designated state official in accordance with 10 CFR 50.91.

890s1e0083 890728 /}001 PDR ADOCK 05000424 P PDC ,

m-: ..----.m,.,

GeorgiaPower d g Mr. W. G. Hairston, III stater that he is a Serfor Vice President of Georgia I 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 By:' (d. .

Ig W. G. Hai rston, 'III Sworn to and subscribed before me this ff I day of July,1989.

14 LM utY Notarf Public

.88MMIS510N EXPlRES DEC 15.1992

- WGH,III/PAH/gm

Enclosures:

1. Basis for Proposed Change
2. 10 CFR 50.92 Evaluation
3. Instructions and Revised Pages cc w/ enclosures:

Georgia ~ Power Company Mr. C. K. McCoy Mr. P. D. Rushton Mr. G. Bockhold, Jr.

NORMS U.'S. Nuclear Regulatory Commission Mr. 5. D. Ebneter, Regional Administrator Mr. J. B. Hopkins, Licensing Project Manager, NRR Mr. J. F. Rogge, Senior Residence Inspector, Yogtle State of Georgia Mr. J. L. Ledbetter, Commissioner, Department of Natural Resources l

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ENCLOSURE 1 V0GTLE ELECTRIC GENERATING PLANT NRC DOCKETS 50-424, 50-424 OPERATING LICENSES NPF-68, NPF-81 REQUEST TO REVISE TECHNICAL SPECIFICATION BASIS FOR~ PROPOSED CHANGE Proposed Change Revise the applicable number of effective full power years (EFPY) on Figures 3.4-2a and 3.4-3a from 16 to 13 years. Revise the bases for the heatup and cooldown curves on pages B 3/4 4-8 and 4-10 to change EFPY from 16 to 13.

Revise reference from Regulatory Guide 1.99, Revision 1, to Regulatory Guide 1.99, Revision 2.

Basis NRC Generic Letter 88-11 indicated that licensees and holders of construction permits should use the methods described in Regulatory Guide (R.G.) 1.99, Revision 2, to predict the effect of neutron radiation on reactor vessel material s. Pursuant to the generic letter, Georgia Power Company has evaluated the attached proposed amendment to the Vogtle Technical Specifications and has determined that operation of the facility in accordance with the proposed amendment would not involve a significant hazard consideration. The protection to ,, ant systems is provided by the heatup and cooldown curves in the Technical Specifications. Operation within the allowable limits of these curves ensures the reactor coolant system is adequately protected against non-ductile failure. The number of Effective Full Power Years (EFPY) is an indication of the length of time these curves are applicable. New curves are periodically generated as a result of the analysis of metallurgical data obtained fron the testing of material samples located in surveillance capsules around the reactor core as required by 10 CFR 50, Appendix H.

i Georgia Power d ENCLOSURE 2 YOGTLE ELECTRIC GENERATING PLANT NRC DOCKETS 50-424, 50-425 OPERATING LICENSES NPF-68, NPF-81 REQUEST TO REVISE TECHNICAL SPECIFICATIONS 10 CFR 50.92 EVALUATION Pursuant to 10 CFR 50.92, Georgia Power Company has evaluated the attached proposed amendment to the Vogtle Technical Specifications and has determined that operation of the facility in accordance with the proposed amendment would not involve significant hazards considerations. The basis for this determination is as follows: >

Background:

Generic Letter 88-11 indicated that licensees and holders of construction permits should use the methods described in R.G.1.99, Revision 2 to predict the effect of neutron radiation on reactor vessel materials as required by Paragraph V. A. of 10 CFR Part 50, Appendix G. Within 180 days of the effective date of Revision 2, licensees were requested to submit the results of their technical analysis and a proposed schedule for whatever actions they proposed to take.

The Vogtle Technical Specifications contain 10 CFR 50, Appendix G heatup and cooldown curves. The Unit 1 curves are provided on pages 3/4 4-31 and 3/4 4-32, while the Unit 2 curves are provided on pages 3/4 4-31a and 3/4 4-32a.

Both the Unit 1 and the Unit 2 curves were generated by Westinghouse using Westinghouse Copper Trend Curves as a basis for specific copper and initial ,

reference nil-ductility transition temperature (RTNDT) values. GPC contracted with Westinghouse to conduct a technical analysis of the effects of utilizing the methodology of R.G.1.99, Revision 2, to determine whether the curves provided in the- Technical Specifications remain acceptable for their specified time limit of 16 EFPY. A comparison of the RTNDT .!a lues calculated utilizing R.G.1.99, Revision 2, versus the values provided in the Technical Specifications was performed. The results indicated that the Unit 1 curves were applicable for 13 EFPY instead of 16 EFPY and that the Unit 2 curves remained applicable for 16 EFPY. Theste results were submitted to the NRC in our letter ELV-00014 dated November 28, 1988.

. - Georgia Power b ENCLOSURE 2 (CONT'D)

, REQUEST TO REVISE TECHNICAL SPECIFICATION 10 CFR 50.92 EVALUATION Analysis:

GPC has reviewed the proposed amendment with respect to the requirements of 10 CFR 50.92 and has determined that the change does not involve significant hazards considerations. In support of this conclusion, the following analysis is provided:

1) The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated. The change in the number of effective full power years only indicates the length of time the curves in the Technical Specifications are applicable. The actual heatup and cooldown curves are not changed.

As long as the heatup and cooldown curves are adhered to, there is no danger of non-ductile failure to the reactor vessel or reactor i coolant system.

2) The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

There is no change to the existing heatup or cooldown curves. Since 1 a new failure mode, or non-conservative curve is not introduced by the change, a new or different kind of accident could not result.

3) The proposed change does not involve a significant reduction in a margin of safety. The margin of safety is provided in the heatup and cooldown curves. The number of applicable effective full power years j only indicates the number of years that the heatup and cooldown j curves can be utilized. Operating within the existing curves does i not reduce the level of protection.

Conclusion:

j Based on the preceding analysis, GPC has determined that the proposed change to the Technical Specifications does not involve a significant increase in the i

probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in a maroin of safety. GPC therefore concludes that 'the proposed change meets the requirements of 10 CFR 50.92 (c) and does not involve significant hazards considerations. ,

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