ML20204H319

Responds to 860623 Request for Addl Info Re Proposed Tech Spec Change on Rod Worth Minimizer & Rod Sequence Control Sys Submitted on 860415.Proposed Changes Would Enforce Use of Banked Position Withdrawal Sequences

ML20204H319
Person / Time
Site:	Hatch
Issue date:	07/25/1986
From:	Gucwa L GEORGIA POWER CO.
To:	Muller D Office of Nuclear Reactor Regulation
References
0592C, 592C, SL-902C, TAC-61283, TAC-61284, NUDOCS 8608080077
Download: ML20204H319 (4)

Text

. Georgia Power company 333 Piedmont Avenue Atlanta, Georgia 30308 a Telephone 404 526-6526 MaMng Address-Post Office Box 4545 Atlanta, Georgia 30302 b Georgia Power L. T. Gucws Ite sotoen e4rtre system and 7c'e'n$"n'g**' * ** SL-902c 0592C July 25,1986 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 DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2 TECHNICAL SPECIFICATIONS REVISIONS FOR RWM AND RSCS OPERATION, FUEL STORAGE REQUIREMENTS FUELASSEMBLYDESIGN,MAPLHGRLIMITS,EDITORIALCRANGES SUPPLEMENTAL INFORMATION Gentlemen:

The following is provided in response to your request (Reference 1) for additional information regarding the proposed Technical Specifications change on the Rod Worth Minimizer (RWM) and Rod Sequence Control System (RSCS) submitted on April 15, 1986. The proposed changes would enforce the use of Banked Position Withdrawal Sequences (BPWS) in the RWM from 100- to 50-percent rod density in order to take credit for a generic control rod drop accident (CRDA) analysis. The NRC requested that Georgia Power Company (GPC) indicate specific intent to maintain maximum operability of the RWM. Al so, the NRC requested information regarding the effectiveness of the second operator in the monitoring of control rod movements (if RWM is inoperable).

I. RWM Operability Reduced rod notch worth has been implemented procedurally at Plant Hatch for several years. The increased reliance upon the RWM has resulted in efforts by GPC personnel to improve the system's reliability. Software changes were implemented on both units in 1985, and operations personnel were instructed on the methods to reinitialize the RWM system. In addition, the procedural modifications discussed under "Second Operator Effectiveness" help clarify when and how the RWM may be bypassed. Specifically, the procedures would allow the RWM to be bypassed only in the event that it was shown to be inoperable or for testing purposes, and then only 8608080077 e60725 N

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Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director l BWR Project Directorate No. 2 2

July 25,1986 Page Two i with the permission of the. on-shift operations shift supervisor.

Thus, GPC's specific intent to maintain RWM operability is now clearly reflected in the procedures.

P'. ease note that the proposed change to the Technical Specifications still requires the RSCS to be operable from 50-percent r)d density up to 20-percent power. The plant procedures will still involve the

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testing of the RSCS, and there is a high degree of probability that the RSCS will be operable through the entire startup range. This will provide still another degree of mitigation against the highly j improbable CRDA. However, operability of the RSCS should not be i required by the Technical Specifications prior to achieving

50-percent rod density, since it cannot enforce BPWS. On the other

hand, the RWM not only prevents improper rod selection as does the

, RSCS, but it also enforces BPWS. Thus, in the pre-checkerboard

! range, only the RWM, not the RSCS, is sufficient and necessary to ensure that the plant is operated within the constraints of the generic licensing approach to the analysis of the CRDA.

j II. Second Operator Effectiveness The proposed changes would use the RWM as the primary operator backup for rod pattern control from 100- to 50-percent rod density (black and white). Use of a second operator to verify rod pulls would be l

necessary only in the event that the RWM was bypassed. The operators at Plant Hatch are aware of the importance of following Rod Movement Procedures as a resul t of the GPC action taken in response to l

l Enforcement Action 83-86 (Reference 2). This incident involved the improper manipulation of control rods. A complete review and update of applicable procedures and procedure forms, as well as extensive retraining, was part of the GPC resolution of this incident. A description of some of the actions taken is described below:

A. Plant management conducted a session with Operations supervisors to emphasize GPC's commitment to following procedures and to operating within analyzed regions.

B. Procedures 42FH-ENG-010-15 and 42FH-ENG-010-25 (HNP-1 and -2, respectively), " Control Rod Movement Procedures,"

and the procedure forms (data packages) were reviewed and modified to clarify the conditions for bypassing the RWM and the responsibilities and duties of the backup operator in the event of a RWM bypass.

0592C 7C0775

Georgia Power d Director of Nuclear Reactor Regulation Atten tion: Mr. D. Muller, Project Director BWR Project Directorate No. 2 July 25,1986 Page Three C. Training was provided in the following areas to improve quality control and to ensure accurate verification of rod movements:

1. A control room management course was presented to licensed Operations supervisory personnel, senior reactor operators, and selected site management personnel.

2. A special seminar, in which the NRC position regarding plant operations was discussed, was held by the USNRC for licensed personnel and other site personnel.

3. The manager of the Core Analysis Section of Southern Company Services presented a lecture to licensed control room supervisors on Final Safety Analysis Report (FSAR) transient and accident analyses, procedure compliance, and the consequences of operations outside of analyzed areas.

4. Site personnel were retrained in procedure compliance through the use of Departmental Directives.

D. Training classes for licensed operators and shift technical advisors (STAS) now include special "FSAR Analyzed Regions of Operation" topics.

E. New employee training and annual retraining now include the subject of plant operating philosophy and the necessity to follow procedures.

Since the implementation of the revised procedures and training, no

instances of rod movement errors similar to those described in Reference l 2 have been identified. GPC believes that the second operator will continue to provide an effective substitute for the RWM (if needed) to verify control rod movements for the first 50 percent of rod movement.

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0592C 700775

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GeorgiaPower d Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 July 25,1986 Page Four Georgia Power Company is prepared to respond promptly to any questions you may have on this subject.

Sincerely, f 61-+

L. T. Gucwa

REFERENCES:

1. Letter, G. W. Rivenbark (NRC) to J. T. Beckham, Jr. (GPC), " Request for Additional Information for Proposed Technical Specification Changes for the RWM and RSCS for Hatch," received June 23, 1986.

2. Letter, J. T. Beckham, Jr. (GPC) to R. DeYoung (NRC), " Response to Enforcement Action 83-86," January 25, 1984.,

GKM/lc c: Georc ia Power Company U. S. Nuclear Regulatory Commission Mr. s . P. O'Reilly Dr. J. N. Grace, Regional Administrator Mr. J. T. Beckham, Jr. Senior Resident Inspector Mr. H. C. Nix, Jr.

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