NL-08-0013, Units 1 and 2, Editorial Revision to Standby Liquid Control Solution Figure
| ML081210467 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 04/29/2008 |
| From: | Stinson L Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-08-0013 | |
| Download: ML081210467 (15) | |
Text
L. M. Stinson (Mike) Southern Nuclear Vice President Operating Company, Inc.
Fleet Operations Support 40 Inverness Center Parkway Post Office Box 1295 Birmingham. Alabama 35201 Tel 205.99251 81 Fax 205.992.0341 SOUIHERNA COMPANY April 29, 2008 Energy to Serve lbur ~rlJ'"
Docket Nos.: 50-321 NL-08-0013 50-366 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant - Units 1 and 2 Editorial Revision to Standby Liquid Control Solution Figure Ladies and Gentlemen:
Pursuant to 10 CFR 50.90 Southern Nuclear Operating Company (SNC) hereby requests a change to the Plant Hatch Units 1 and 2 Technical Specifications, Appendix A to Operating Licenses DPR-57 and NPF-5, respectively.
SNC requests a revision to LCO 3.1.7, "Standby liquid Control System."
Specifically, an editorial change is sought for Figure 3.1.7-1 which provides the requirements for the solution concentration versus volume requirements.
Enclosure 1 provides a description and justification of the proposed change, the significant hazards evaluation, and the justification for the exclusion from performing an environmental evaluation. Enclosures 2 and 3 provide the marked up and clean typed Technical Specifications pages. There are no associated Bases changes.
Approval of the proposed amendment is requested by March 30, 2009. Once approved the amendment shall be implemented within 60 days.
(Affirmation and signature are provided on the following page.)
U. S. Nuclear Regulatory Commission NL-08-0013 Page 2 Mr. L. M. Stinson states he is a Vice President of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.
This letter contains no NRC commitments. If you have any questions, please advise.
Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY L. M. Stinson Vice President Fleet Operations Support Sworn to and subscribed before me this ;/tf:d day of ~f'1- / ,2008.
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Notary Public My commission expires: J:.v/v
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Enclosures:
- 1. Basis for Proposed Change
- 2. Technical Specifications Markup Pages
- 3. Technical Specifications Clean Typed Pages cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. D. R. Madison.* Vice President - Hatch Mr. D. H. Jones, Vice President - Engineering RTYPE: CHA02.004 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Acting Regional Administrator Mr. R. E. Martin, NRR Project Manager - Hatch Mr. J. A. Hickey, Senior Resident Inspector - Hatch State of Georgia Mr. N. Holcomb, Commissioner - Department of Natural Resources
Edwin I. Hatch Nuclear Plant Editorial Revision to Standby Liquid Control Solution Figure Enclosure 1 Basis for Proposed Change
Edwin I. Hatch Nuclear Plant Editorial Revision to Standby Liquid Control Solution Figure Enclosure 1 Basis for Proposed Change Table of Contents 1.0 Summary Description 2.0 Detailed Description 3.0 Technical Evaluation 4.0 Regulatory Evaluation 4.1 Significant Hazards Consideration 4.2 Applicable Regulatory Requirements/Criteria 4.3 Precedent 4.4 Conclusions 5.0 Environmental Consideration 6.0 References
Enclosure 1 Basis for Proposed Change 1.0 Summary Description This evaluation supports a request to amend Operating Licenses DPR-57 and NPF-5 of the Plant Hatch Units 1 and 2 Technical Specifications The proposed change would revise Technical Specifications Figure 3.1.7-1, Sodium Pentaborate Solution Volume Versus Concentration requirements to re-label the horizontal axis.
2.0 Detailed Description LCO 3.1.7, Standby Liquid Control System, provides the requirements for the Standby Liquid Control (SLC) System. The system consists of a sodium pentaborate solution storage tank, two positive displacement pumps, two explosive valves that are provided in parallel for redundancy, and associated piping and valves used to transfer borated water from the storage tank to the reactor pressure vessel (RPV). The borated solution is discharged near the bottom of the core shroud, where it then mixes with the cooling water rising through the core. A smaller tank containing demineralized water is provided for testing purposes.
The system provides back-up capability for reactivity control independent of normal reactivity control provisions provided by the control rods. The SLC system is used in the event that enough control rods cannot be inserted to accomplish shutdown and cooldown in the normal manner. The system injects borated water into the reactor core to add negative reactivity to compensate for the various reactivity effects that could occur during plant operation. Adherence to Figure 3.1.7-1 of LCO 3.1.7, Sodium Pentaborate Solution vs. Concentration, ensures that the necessary concentration of borated solution is injected into the reactor vessel.
Recently approved Amendments 247 and 191 to the Units 1 and 2 Technical Specifications revised this plot to increase the required concentration of solution that would be injected into the reactor following an Anticipated Transient Without Scram (ATWS) event. This was necessary to support longer fuel cycles and new fuel designs. The horizontal axis is labeled with the volume of the solution. The first labeled volume on the horizontal axis is 1000 gallons and then each tic mark represents an additional 200 gallons over the previous mark. Due to the size of the plot, however, one of the tic marks was not labeled. Specifically, the plot goes from 3600 gallons directly to 4000 gallons. The 3800 gallon tic mark is not labeled.
SNC proposes to enlarge the plot such that all the tic marks can be labeled.
Consequently, the new plot presented in this amendment is exactly the same, substantively, as the current Tech Spec plot except that it is larger and each tic mark is labeled.
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Enclosure 1 Basis for Proposed Change 3.0 Technical Evaluation The changes being made to Technical Specifications Figure 3.1.7-1 are to increase legibility and functionality. The graph is being enlarged to enable labeling all the tic marks on the horizontal axis. These figures were last changed under Amendments 247 and 191 for the Unit 1 and 2 Tech Specs, respectively.
The figures remain substantively unchanged. The plotted data is exactly the same as the graph approved under those amendments. Therefore, the ATWS event analysis and SLC system design analyses will not change as a result of this editorial Tech Spec revision.
Increasing the plot size will enhance the labeling of the volume numbers on the horizontal axis, thus making it easier for the operators to read the graph.
4.0 Regulatory Evaluation 4.1 Significant Hazards Consideration This amendment proposes to revise Figure 3.7.1-1, Sodium Pentaborate Solution Volume Versus Concentration Requirements. The revision is editorial in that the plot is being made larger to facilitate labeling of the horizontal axis.
Southern Nuclear has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of Amendment, as described below:
- 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated.
Response: No This proposed Technical Specifications change will not result in any changes to the operation, maintenance, or surveillance of any plant systems, structures, or components designed for the prevention or mitigation of previously evaluated events. This amendment proposes editorial changes to the Figure 3.1.7-1, Sodium Pentaborate Solution Volume Versus Concentration Requirements. The plot will be enlarged such that all the tic marks on the horizontal axis can be labeled. The plotted data remains the same. Therefore the response to an ATWS event or to any other event requiring use of the SLC system is unaffected.
For the above reasons, the proposed amendment does not involve a significant increase in the probability or consequences of a previously evaluated accident.
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Enclosure 1 Basis for Proposed Change
- 2. Does the proposed amendment create the possibility of a new or different kind of accident from any previously evaluated?
Response: No This proposed amendment does not make any changes to the operation testing, maintenance, or surveillance of any safety related, or otherwise important to safety, system. These systems will all continue to be operated, surveilled and maintained within their design bases. The proposed changes to the SLC system figure is editorial and will improve the readability of the plot.
For the reasons noted above, this proposed amendment will not introduce the possibility of a new or different kind of accident.
- 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No This proposed amendment makes an editorial revision to the Technical Specifications. Specifically, the plot of Sodium Pentaborate solution volume versus concentration is being enlarged to enable the proper labeling of all the tic marks on the horizontal axis, which indicates the volume. The plotted data is not changing. Therefore, the Technical Specifications assumptions and margins to safety remain unaffected.
4.2 Applicable Regulatory Requirements/Criteria 10 CFR 50.62, the ATWS rule, requires a Standby Liquid Control System at all boiling water reactors. Furthermore, General Design Criteria 26 requires two independent reactivity control systems, of different design principles. The Standby Liquid Control system and the control rods satisfy these requirements.
4.3 Precedent This amendment is an editorial change to the Unit 1 and 2 plots of the standby liquid control sodium pentaborate solution volume versus concentration plot (Figure 3.1.7-1). These figures were last revised via Tech Spec Amendments 247 and 191 for Units 1 and 2, respectively. The revision is made to enlarge the plot, thus enhancing labeling of the volume requirements on the horizontal axis. The figures are not changing in any substantive manner. Therefore, the conclusions of the Safety Evaluation Reports for the above references amendments will not be affected.
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Enclosure 1 Basis for Proposed Change 4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is a reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
5.0 Environmental Consideration A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental assessment need be performed in connection with the proposed amendment.
6.0 References
- 1. Hatch Technical Specifications LCO 3.1.7, Standby Liquid Control (SLC)
System and Bases section B 3.1.7.
- 2. Code of Federal Regulations, Title 10, Part 50.62, Requirements for Reduction of Risk from Anticipated Transients Without Scram (ATWS) Events for Light Water Cooled Reactors.
- 3. Safety Evaluation for Hatch Units 1 and Technical Specifications Amendments 247 and 191.
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Edwin I. Hatch Nuclear Plant Editorial Revision to Standby Liquid Control Solution Figure Enclosure 2 Technical Specifications Markup Pages
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Sodium Pentaborate Solution Volume Versus Concentration Requirements HATCH UNIT 1 3.1-20 Amendment No. 247
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Sodium Pentaborate Solution Volume Versus Concentration Requirements HATCH UNIT 2 3.1-20 Amendment No. 191
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Edwin I. Hatch Nuclear Plant Editorial Revision to Standby Liquid Control Solution Figure Enclosure 3 Technical Specifications Clean Typed Pages
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Sodium Pentaborate Solution Volume Versus Concentration Requirements HATCH UNIT 1 3.1-20 Amendment No.
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Sodium Pentaborate Solution Volume Versus Concentration Requirements HATCH UNIT 2 3.1-20 Amendment No.