ML20207J690

Application for Amend to License NPF-5,revising Tech Specs to Update Valve Listings Contained in Table 3.6.3-1, Primary Containment Isolation Valves. Fee Paid

ML20207J690
Person / Time
Site:	Hatch
Issue date:	07/18/1986
From:	Beckham J GEORGIA POWER CO.
To:	Muller D Office of Nuclear Reactor Regulation
Shared Package
ML20207J693	List: ML20207J690 ML20207K376
References
0620C, 620C, SL-950, TAC-62030, NUDOCS 8607290227
Download: ML20207J690 (11)

Text

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Georgia Power Company 333 Piedmont Avenue ephone 526 26 Mailing Address:

Fbst Othee Box 4545 Atlanta, Georgia 30302 h

Georgia Power a ager$uclear Safety and Licensing July 18,1986 0620C Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 Division of Boiling Water Reactor Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 REQUEST TO REVISE PRIMARY CONTAINMENT VALVE LISTING TECHNICAL SPECIFICATIONS Gentlemen:

In accordance with the provisions of 10 CFR 50.90, as required by 10 CFR 50.59(c)(1), Georgia Power Company (GPC) hereby proposes changes to the Technical Specifications, Appendix A to Operating License NPF-5 for Plant Hatch Unit 2.

Georgia Power Company has conducted a comprehensive review and update of primary containment isolation valves. The proposed changes would update valve listings contained in Table 3.6.3-1, " Primary Containment Isolation Val ves. " Four valves are proposed for deletion from the table. Fi fteen valves are proposed for addition to the table. One additional valve is proposed to be deleted and replaced with another val ve. Valve part numbers are proposed to be corrected or added for 16 valves. Nine valves are proposed to be moved from one section of the table to another.

The Plant Review Board and the Safety Review Board Subcommittee have reviewed the proposed changes.

We request NRC approval of this change within 90 days of the submittal date, since modifications are to be performed during the upcoming refueling outage (September 1986) which will modify the current primary containment isolation valves.

Enclosure 1 provides a detailed description of each proposed change and the basis for the change.

Enclosure 2 details the bases for our determination that the proposed changes do not involve a significant hazards consideration.

I Enclosure 3 provides page change instructions for incorporating the g 0

proposed changes into the Technical Specifications. p0,

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I I 8607290227 860718 PDR ADOCK 05000366 i l

$fSO-00

GeorgiaPower d Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 Director of Nuclear Reactor Regulation July 18, 1986 Page Two The proposed changed Technical Specifications pages follow Enclosure 3.

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 amendment, 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 Environmental Protection Division of the Georgia Department of Natural Resources.

Mr. J. T. Beckham, Jr. states that he is Vice President of Georgia Power Company and is authorized to execute this oath on be5alf of Georgia Power Company, and that to the best of his knowledge and belief, the facts set forth in the letter and enclosures are true.

GEORGIA POWER COMPANY By:

^

h g T. Beckham, Jr.'

Sworn to and subscribed before me this 18th day of July 1986.

/4 V / Notary Public Notary Pubhe. Clayton County, Georgia l REB /1f mnms n Exprn Da 12. M Enclosures l

c: Georsia Power Company Nuclear Regulatory Commission Mr. s . P. O'Reilly Dr. J. N. Grace, Regional Administrator Mr. H. C. Nix, Jr. Senior Resident Inspector G0-NORMS l

State of Georgia Mr. J. L. Ledbetter l

0620C

, rwirs }

GeorgiaPower d ENCLOSURE 1 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 REQUEST TO REVISE PRIMARY CONTAINMENT VALVE LISTING TECHNICAL SPECIFICATIONS BASIS FOR CHANGE REQUt.ST Changes are proposed to clarify and correct Plant Hatch Unit 2 Technical Specifications Table 3.6.3-1, " Primary Containment Isolation Valves." These changes result from a comprehensive review of Technical Specifications Table 3.6.3-1 versus plant leak rate test and inservice inspection (ISI) procedures, as-built plant drawings, and Plant Hatch Unit 2 FSAR Table 6.2-5, " Lines Penetrating the Primary Containment." This review was performed by GPC with assistance from the Architect / Engineer. Based upon the results of this review, six areas of changes to the Plant Hatch Unit 2 Technical Specifications were identified and are hereby proposed:

Proposed Change 1: Delete four primary containment isolation valves (PCIVs) from Table 3.6.3-1.

Yalves 2T43-F159 and 2T43-F160 are proposed for deletion from penetration X-76. These valves isolated a 3-inch fire protection line into the drywell.

This line has been capped through a design modification and the subject valves subsequently removed from the plant. Valves 2B21-F065A and 2B21-F065B provided excess flow protection for 1-inch instrument lines that were capped prior to initial plant operation. These valves have likewise been subsequently removed from the plant.

Deletion of these four valves from the table is appropriate for the reasons given above. These changes only serve to correctly define the primary containment boundary and ensure that valve listings are properly and consistently provided in the Technical Specifications. Implementation of this change will not result in increased probabilities or consequences of analyzed accidents.

In each case where deletion of a valve (and associated testing requirements) is proposed, the affected line has been capped and will still perform the required function of preserving containment integri ty. No new types of accidents are created. Margins of safety are not reduced, since primary containment integrity will be properly maintained.

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Georgia Power d ENCLOSURE 1 (Continued)

NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 REQUEST TO REVISE PRIMARY CONTAINMENT VALVE LISTING TECHNICAL SPECIFICATIONS BASIS FOR CHANGE REQUEST Proposed Change 2: Add 15 primary containment isolation valves (PCIVs) to Table 3,6.3-1.

Our review has identified 15 valves which should be added to Table 3.6.3-1.

In some cases, these valves (or blind flanges) have been added to the plant through design modifications. In other cases, the valves have existed since plant operation began but have never been listed in Technical Specifications, even though they are tested per plant procedures and identified as containment isolation valves in the ISI plan. In either case, the addition of Technical Specifications requirements for these valves represents a clearly conservative change. Probabilities and consequences of analyzed accidents are not increased. No new accident types are created. Margins of safety are not reduced. Again, these changes only serve to correctly define the primary containment boundary and ensure that valve listings are properly and consistently provided in the Technical Specifications.

Proposed Change 3: Add or correct part numbers for 16 valves.

This change either corrects part numbers for valves presently listed with incorrect part numbers or adds part numbers for valves which are presently listed without part numbers. This change is strictly administrative and does not reflect changes to the listed valves. Addition or correction of part numbers provides easier identification of Technical Specifications requirements for particular valves. Accident probabilities and consequences are not increased by this administrative change. No new types of accidents are created. Margins of safety are not reduced by this change.

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i GeorgiaPower d ENCLOSURE 1 (Continued)

NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 REQUEST TO REVISE PRIMARY CONTAINMENT VALVE LISTING TECHNICAL SPECIFICATIONS BASIS FOR CHANGE REQUEST Proposed Change 4: Move eight valves from Table 3.6.3-1 Section B (Manual  ;

Isolation Valves) to section A ( Automatic Isolation Yalves). l As a result of post-TMI modifications, automatic isolation signals (reactor building or refueling floor high radiation) have been added to drywell and suppression pool purge bypass line valves 2T48-F332A, B; 2T48-F333A, B; 2T48-F334A, B; and 2T48-F335A, B. Thus, it is appropriate to move these valves to the " Automatic Isolation Valve" listing. This change reflects

, implementation of a design modification made pursuant to NRC requirements and analyzed pursuant to 10 CFR 50.59. As detailed in the safety evaluation for that change, the change does not increase probabilities or consequences of analyzed accidents. The change does not create new types of accidents.

Margins of safety are not reduced by the change.

Proposed Change 5: Move RPV head spray valve from Table 3.6.3-1, Section A (Automatic Isolation Valves) to Tabl e 3.6.3-1, Section C (Other Isolation Yalves).

The RPV head spray line will be cut and fitted with a blind flange inside containment during the upcoming (September 1986) refueling outage. Head spray isolation valve 2E11-F023 will remain as the inboard isolation barrier, since this valve is easier to leak rate test than the to-be-installed blind fl ange. The outboard isolation barrier is a closed system. Valve 2E11-F023 will be deactivated and locked closed. No automatic isolation provisions will remain. Thus, it is appropriate to move this valve from the " Automatic Isolation Yalve" listing to the "Other Isolation Yalve" listing. The modification resulting in this change will be analyzed pursuant to 10 CFR 50.59. No analyzed accidents assume operability of the RPY head spray system. Thus, removal of the system and deactivation of the isolation valve does not result in any increase in analyzed accident probabilities or consequences. No new accident types are created. Margins of safety are not reduced.

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GeorgiaPower d ENCLOSURE 1 (Continued)

NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 REQUEST TO REVISE PRIMARY CONTAINMENT VALVE LISTING TECHNICAL SPECIFICATIONS BASIS FOR CHANGE REQUEST Proposed Change 6: Change the isolation boundary for the fission product monitoring system sample line.

A 1-inch fission products monitoring sample line, provided with hand-operated, normally closed globe valves for isolation, utilizes penetration X-217C. Presently the 2Dll-F065 valve is listed as the inboard isolation barrier, and valve 2D11-F061 is listed as the outboard isolation barrier.

Our review identified that valve 2Dll-F061 is a non-nuclear-grade (ASME) valve and is, therefore, inappropriate for performance of the containment isolation function. It is proposed that this valve be replaced by valve 2011-F065, which is a nuclear-grade valve and meets all other criteria for inclusion as a PCIV. Site procedures will be modified to reflect this change. Since the valve proposed for replacement meets all criteria for inclusion as a PCIV, this change will have no adverse effect on the ability to provide primary containment integrity and should provide increased assurance. This change, therefore, does not increase probabilities or consequences of analyzed accidents. No new accident types are created.

Margins of safety are not reduced.

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GeorgiaPower A ENCLOSURE 2 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 REQUEST TO REVISE PRIMARY CONTAINMENT VALVE LISTING TECHNICAL SPECIFICATIONS 10 CFR 50.92 EVALUATION Pursuant to 10 CFR 50.92, Georgia Power Company has evaluated the attached l proposed amendment for Plant Hatch Unit 2 and has determined that its adoption would not involve a significant hazards consideration. The basis for this determination is as follows:

Proposed Change 1:

This proposed change would delete four primary containment isolation valves (PCIVs) from Table 3.6.3-1.

Basis The valves proposed for deletion from the table have been removed from the plant and the associated lines capped. These changes only serve to correctly define the primary containment boundary and ensure that valve listings are properly and consistently provided in the Technical Specifications.

This change does not involve a significant increase in the probability or consequences of an accident, because, in each case where deletion of a valve (and associated testing requirements) is proposed, the affected line has been capped and will still perform the required function of preserving containment integrity.

The possibility of a different kind of accident from any analyzed previously is not created by this change, because plant design and operation are not affected.

Margins of safety are not significantly reduced by this change, because the plant safety analyses are not affected, and primary containment integrity will be properly maintained.

Proposed Change 2:

This proposed change would add 15 additional valves to the listings in Table

3. 3. 6-1.

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GeorgiaPower d ENCLOSURE 2 (Continued)

NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 REQUEST TO REVISE PRIMARY CONTAINMENT VALVE LISTING TECHNICAL SPECIFICATIONS 10 CFR 50.92 EVALUATION

. Basis:

The valves proposed for inclusion in Table 3.3.6-1 are added as a result of a comprehensive review of PCIVs performed by GPC with assistance from the

architect / engineer. Certain of these valves have been added to the plant due to design changes. Our review identified other valves which meet the criteria for inclusion in Table 3.3.6-1 but were not previously listed in the table. These valves are now proposed for addition to the table.

This change does not involve a significant increase in the probability or l consequences of an accident, because it is conservative in nature and will result in additional Technical Specifications requirements.

i The possibility of a different kind of accident from any analyzed previously is not created by this change, because plant design and operation are not

. affected.

Margins of safety are not significantly reduced by this change, because the plant safety analyses are not affected.

This change is consistent with Item (ii) of the " Examples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the Federal Register, April 6,1983. The proposed change is conservative, since it adds valves to the- table and additional i

Technical Specifications requirements.

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1 Proposed Change 3:

This proposed change would modify the Unit 2 Technical Specifications Table 3.3.6-1, " Primary Containme't Isolation Valves," to correct part numbers for listed valves and add part ,1bers for valves currently listed without part I

numbers. No changes to the valves themselves are involved.

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GeorgiaPower d ENCLOSURE 2 (Continued)

NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 REQUEST TO REVISE PRIMARY CONTAINMENT VALVE LISTING TECHNICAL SPECIFICATIONS 10 CFR 50.92 EVALUATION Basis:

The proposed change corrects inaccurate descriptive information and also adds descriptive infonnation. No changes to plant operation will result from this change.

This change does not involve a significant increase in the probability or

consequences of an accident, because it is administrative in nature.

The possibility of a different kind of accident from any analyzed previously is not created by this change, because plant design and operation are not affected.

Margins of safety are not significantly reduced by this change, because the plant safety analyses are not affected.

This change is consistent with Item (1) of the " Examples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the Federal Register, April 6,1983. The proposed editorial change corrects errors and adds clarification to the Technical i Specifications. Therefore, the proposed change meets the requirements of f

Item (i) for an amendment involving no significant hazards considerations.

Proposed Change 4:

This proposed change would move eight valves from Table 3.6.3-1, Section B (Manual Isolation Valves) to section A ( Automatic Isolation Yalves).

1 Basis:

As a result of modifications resul ting from NRC requirements, automatic isolation signals have been added to drywell and suppression pool purge

bypass line valves. This administrative change' reflects the adoption of this design modification and moves these valves to the " Automatic Isolation l Valve" listing.

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GeorgiaPower d ENCLOSURE 2 (Continued) 1-NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 REQUEST TO REVISE PRIMARY CONTAINMENT VALVE LISTING TECHNICAL SPECIFICATIONS 10 CFR 50.92 EVALUATION 4

This change does not involve a significant increase in the probability or consequences of an accident, because it reflects the adoption of design changes made pursuant to NRC requirements.

The possibility of a different kind of accident from any analyzed previously is not created by this change. This change merely provides administrative corrections to the Technical Specifications to properly reflect adaptation of new NRC requirements already implemented in the plant.

! Margins of safety are not significantly reduced by this change, 'because the

plant safety analyses are not affected.

i I

Proposed Change 5:

This proposed change would move the RPV head spray valve from Table 3.6.3-1, Section A (Automatic Isolation Valves) to Table 3.6.3-1, Section C (Other Isolation Valves).

Basis:

This change does not involve a significant increase in the probability or i

consequences of an accident, because: 1) no analyzed accidents assume operability of the head spray system, and 2) primary containment integrity l

will be correctly maintained by the locked-closed, deactivated valve and a closed system outside containment.

j The possibility of a different kind of accident from any analyzed previously 1s not created by this change, because no new modes of plant operation are l

{

involved.

l Margins of safety are not significantly reduced by this change, because the plant safety analyses are not affected.

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ENCLOSURE 3 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 REQUEST TO REVISE PRIMARY CONTAINMENT VALVE LISTING TECHNICAL SPECIFICATIONS PROPOSED CHANGE TO TECHNICAL SPECIFICATIONS The proposed changes to the Technical Specifications (Appendix A to Operating License NPF-5) would be incorporated as follows:

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