ML20148K126

Application for Amend to License NPF-68,revising Tech Spec 3.7.6 to Add Footnote Stating That Differential Pressure Requirement of Spec 4.7.6.e.3 May Be Waived During Emergency HVAC Testing.Fee Paid

ML20148K126
Person / Time
Site:	Vogtle
Issue date:	03/23/1988
From:	Head G GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20148K129	List: ML20148K126 ML20148K140
References
SL-4398, NUDOCS 8803310019
Download: ML20148K126 (9)

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,o = . , Georg<a Power Company 333 Piedmont Avenue .

At:anta. Georgia 30300 Treephone 404 5266526 Maeng Address:

Post OMce Box 4545 Atianta. Georg.a 30302 Georgia Power Nuclear Operations Department N' ' W N" M '"

SL-4398 0846m X7GJ17-V600 March 23, 1988 U. S. Nuclear Regulatory Commission ATTM: Document Control Desk Hashington, D.C. 20555 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 REQUEST TO REVISE TECHNICAL SPECIFICATION 3.7.6 CONTROL ROOH EMERGENCY FILTRATION SYSTEM Gentlemen:

In accordance with the provisions of 10 CFR 50.90 and 10 CFR 50.59, Georgia Power Company (GPC) hereby proposes to amend the Vogtle Electric Generating Plant Unit 1 Technical Specifications, Appendix A to Operating License NPF-68.

The Control Room Emergency Filtration System (CREFS) is required by Technical Specification 4.7.6.e.3 to be capable of maintaining the control room at a positive pressure of greater than or equal to 1/8 inch water gauge relative to adjacent areas at less than or equal to a pressurization flow of 850 cfm during system operation. During pre-operational testing of Unit 2 HVAC systems, an adjacent area (the Unit 2 control room) will intermittently have positive pressures which in certain cases can affect the ability to establish and maintain the specified Unit I control room differential pressure; however, the intent of Specification 4.7.6.e.3 can still be met given certain operator actions. If Unit 1 CREFS operation were required in the emergency n co (pressurization) mode while a positive pressure existed in the Unit 2 88 control room, the basis of Specification 4.7.6.e.3 would be met if the g operating Unit 2 Emergency HVAC system (s) were manually shut down. GPC 3 .- proposes to add a footnote to Specification 3.7.6 stating that the 88 differential pressure require.1ent of Specification 4.7.6.e.3 as it

'g applies to the Unit 2 control room may be waived during Unit 2 Emergency HVAC testing provided the capability exists to take the required operator 88 action within the necessary time constraint.

oo e88 GPC's schedule for Unit 2 Emergency HVAC testing will produce

@f A intermittent periods of positive pressures in the Unit 2 control room beginning March 28, 1988. Failure to meet this schedule will potentially

. i or likely result in a delay in the startup of Unit i following its first refueling outage. On. this basis, GPC requests approval of the proposed amendment on an "exigent" basis pursuant to 10 CFR 50.91(a)(6). In the 1 event tha the proposed amendment can not be ed by March 28, 1988, l

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Georgia Power A U. S. Nuclear Regulatory Commission March 23, 1988 Page Two GPC requests interim relief from compliance with the differential pressure requirement of Specification 4.7.6.e.3 with respect to the Unit 2 control room during Unit 2 Emergency HVAC testing until such time as the NRC can complete its approval process. If a waiver of compliance is necessary, GPC will implement the same administrative controls associated with the requested amendment.

Enclosure 1 provides a detailed description of the proposed change and the circumstances necessitating the change request.

Enclosure 2 provides the basis for our determination that the proposed change does not involve significant hazards considerations.

a Enclosure 3 provides instructions for incorporating the proposed change into the Technical Specifications. The proposed revised page follows Enclosure 3. -

Payment of the required filing fee is enclosed.

In accordance with 10 CFR 50.91, Hr. J. L. Ledbetter of the Environmental Protection Division of the Georgia Department of Natural Resources will be sent a copy of this letter and all applicable enclosures.

Mr. G. F. Head 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 POWER COMPANY By: 2 & /ke- '

G. F. Head Sworn to and subscribed before me this 23rd day of March 1988.

Y11 Notary Public JH/Im

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1 U. S. Nuclear Regulatory Commission 1 March 23, 1988  !

.Page Three

) i 4 J Enclosures

1. Basis for Proposed Change

2. 10 CFR 50.92 Evaluation

3. Instructions for Incorporation

4. Check for $150.00 Filing Fee c: Georgia Power Comoany .

Mr. P. D. Rice '

Mr. G. Bockhold, Jr.  !

GO-NORMS U. S. Nuclear Regi,atory Commission i Dr. J. N. Grace. >.egional Administrator Mr. J. B. Hopkir . Licensing Project Manager, NRR (2 copies) '

Mr. J. F. Rogge, Senior Resident Inspector-0perations, Vogtle i

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ENCLOSURE 1  !

PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 NRC OPERATING LICENSE NPF-68 REQUEST TO REVISE TECHNICAL SPECIFICATION 3.7.6 BASIS FOR PROPOSED CHANGE l

PROPOSED CHANGE Add the following footnote to Technical Specification 3.7.6, which l concerns operability requirements for the Control Room Emergency Filtration System (CREFS):

• The verification activity specified by Paragraph 4.7.6.e.3 is l waived with respect to the Unit 1 Control Room / Unit 2 Control  ;

Room differential pressure during periods of operation of the '

Unit 2 Emergency HVAC System while conducting pre-operational testing of that system. The waiver is contingent upon the capability to shut down the applicable Unit 2 HVAC systems within 4.5 minutes after receipt of a Unit 1 Control Room Isolation signal.

BACKGROUM i Unit 1 is protected from Unit 2 construction and testing activities l by physical barriers and administrative controls. In particular, the l

Unit 1 and Unit 2 control room areas are separated by a temporary wall  :

and the HVAC systems are separated by a series of dampers, removed duct '

sections, and caps on open ducts. I

In order to complete the integrated control room, the temporary wall l must be dismantled, duct caps removed, and duct sections reinstalled.  :

l Testing and flow balancing of the Unit 2 normal HVAC system will be l performed prior to removing the barriers between the Unit 1 and Unit 2 i control room areas. Testing of the Unit 2 Emergency HVAC systems will be 1 l

performed in stages with pre-operational testing (except for the control room pressurization test required by Technical Specification 4.7.6.e.3) l completed prior to removing the barriers. The control room pressurization test will be performed after the barriers have been removed.

BASIS FOR TECHNICAL SPECIFICATION CHANGE l GPC plans to remove the temporary wall separating the Unit 1 and Unit 2 control room areas during the first Unit I refueling outage, in order to minimize the negative impact of the wall removal on the l operation of Unit 1. This schedule requires that pre-operational testing 1

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_w GeorgiaPower A ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATION 3.7.6 BASIS FOR PROPOSED CHANGE l

l of the Unit 2 HVAC systems begin prior to the Unit 1 refueling outage.

The Unit 2 testing activities will result in occasional positive pressures in the Unit 2 control room, which could affect the capability to pressurize the Unit I control room with respect to adjacent areas if the need arose. Technical Specification 4.7.6.e.3 requires that the Control Room Emergency Filtration System (CREFS) be capable of maintaining the control room at a positive pressure of greater than or equal to 1/8 inch water gauge relative to adjacent areas at less than or i equal to a pressurization flow of 850 cfm during system operation. This requirement is based on maintaining control room radiation doses within I

GDC 19 limits in the event of a loss-of-coolant accident. With a positive pressure in the Unit 2 control room, the basis for Specification 4.7.6.e 3 could still be met, however, given certain compensatory operator action. If a LOCA occurred, requiring Unit 1 CREFS operation in the emergency (pressurization) mode while a positive pressure existed in the Unit 2 control room, GDC 19 limits would not be exceeded provided the

' operating Unit 2 Emergency HVAC system (s) were manually shut down within 4.5 minutes of receipt of the Unit 1 Control Room Isolation signal.

Manual shut down of the Unit 2 normal HVAC units would not be necessary because these units are part of a system shared with Unit I which would trip when the Unit 1 Emergency units started.

The 4.5 minute time limit is based on a calculation which was I

I performed assuming that (1) the maximum total outside air (0SA) flowrate through the Unit 2 control room emergency HVAC units being tested is 1500 cfm, (2) all other areas adjacent to the control room are maintained and tested in such a manner that the 1/8 inch water gauge differential l

pressure requirement is still met, and (3) credit is taken for a delay of 80.9 seconds from accident initiation until radioactivity reaches the control room OSA intake. The first assumption is consistent with the

, current FSAR analysis for the combined Unit 1 and Unit 2 control room.

l Compliance with the second assumption will be assured by normal on-going i administrative controls. With respect to the third assumption, the l current FSAR analysis takes credit for only 20 seconds between accident l initiation and radioactivity reaching the control room OSA intake. This l is based on a wind speed of 1 meter /second and a distance of 70 feet from the OSA intake to the nearest point on the containment, which actually support a delay time of 21.3 seconds. If the core release is not assumed to occur at time zero but at the point in time at which the first rod burst is calculated to occur, at least 59.6 seconds would be added to the i

time delay before activity due to the core release could enter the control room OSA intake. This is still very conservative as this is the 0846m El-2 03/23/88 SL-4398 mm

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ENCLOSURE 1 (Continued)

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1 REQUEST TO REVISE TECHNICAL SPECIFICATION 3.7.6 I BASIS FOR PROPOSED CHANGE )

l earliest time for any fuel rod to fail and the assumption is that the entire core fails at this time. T"e combined delay time of 80.9 seconds, l while less conservative than the present analysis, is reasonable and '

justified and contains adequate safety margin, 1

The results of the calculation show that control room doses would not  !

increase above those previously analyzed if the Unit 2 Emergency HVAC  ;

systems were shut down within 4.5 minutes after receipt of the Unit 1 l Control Room Isolation signal. In order to ensure that this time limit l would be met, GPC will station dedicated operators in the Unit 1 and l Unit 2 control rooms during operation of the Unit 2 Emergency HVAC l systems. If a Unit 1 Control Room Isolation Signal is received, the Unit 1 operator will make immediate contact with the Unit 2 operator to order shutdown of the Unit 2 Emergency HVAC systems.

JUSTIFICATION FOR EXIGENT REOUEST To minimize the impact on Unit 1 operation, GPC plans to remove the temporary wall separating the Unit 1 and Unit 2 control room areas during the first Unit I refueling outage which will begin in September,1988.

The required Unit 2 Emergency HVAC testing activities will produce positive pressures in the Unit 2 control room beginning Marc.h 28, 1988.

GPC initially believed that the required pre-operational testing of the Unit 2 Emergency HVAC systems could be performed during full power operation of Unit I without the need for a Technical Specification amendment. This belief was based on the temporary nature of the Unit 2 I pressurization testing and the continued compliance with the Technical l Specification Bases through compensatory operator action. The NRC staff informed GPC on March 17, 1988 of their position that a Technical Specification amendment was necessary.

Approval of the proposed amendment by March 28, 1988 is necessary to avoid a potential extension of the planned Unit I refueling outage or a separate outage for removal of the temporary wall. Since approval of the proposed amendment has a direct effect on the operation of Unit 1, GPC requests approval on an "exigent" basis in accordance with 10 CFR 50.91(a)(6). In the event the NRC can not approve the proposed amendment by March 28, 1988, GPC requests interim relief from compliance with the differential pressure requirement of Specification 4.7.6.e.3 as it applies to the Unit 2 control room until the NRC can complete its approva' process. If interim relief is necessary, GPC will implement the same administrative controls associated with the proposed amendment.

These control: will ensure that the basis of Specification 4.7.6.e.3 would be met.

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Georgia Power A ENCLOSURE 2 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 REQUEST TO REVISE TECHNICAL SPECIFICATION 3.7.6 10 CFR 50.92 EVALUATION In accordance with 10 CFR 50.92, GPC has reviewed the enclosed proposed amendment and has determined that not it does involve significant hazards considerations. The basis for this conclusion is provided in the following analysis:

ANALYSIS

1. The proposed change does not significantly increase the probability or consequences of previously evaluated accidents. The Unit 1 CREFS will respond to a Safety Injection, Intake Radiogas, or Manual Initiation signal in the same manner as before the change. The change involves no physical alteration or setpoint change to the Unit 1 CREFS. Radiation doses to control room operators in the event of a LOCA would not increase above those previously evaluated provided manual action is taken to shut down Unit 2 Emergency HVAC systems.

Strict administrative controls will ensure that this action is accomplished within the required time limit. Ocdicated operators, who would have no other duties in the event of an accident, will be stationed to shut down the Unit 2 Emergency HVAC systems within 4.5 minutes after receipt of a Control Room Isolation signal. During the time period that the amendment would be in C'fect, chlorine gas will not be stored on site in a quantity exceeding 20 lbs. The Technice Specifications do not require chlorine protection in t' a circumstances; therefore, toxic gas consequences need not .ce considered.

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

Since the change does not involve any physical alteration of tha plant, a failure mode which could lead to a new or different type of accident is not introduced.

3. The proposed change does not significantly reduce a margin of safety. The Technical Specification for the Unit 1 CREFS is based on limiting radiation doses to control room operators to GDC 19 limits in a loss-of-coolant accident. The proposed change maintains dose consequences below those limits; tnerefore, the safety margin inherent in the GDC 19 limits is maintained. Furthermore, the calculation of control room dose consequences using the revised assumption of radioactivity transport time contains adequate conservatism to assure sufficient safety margin.

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.. H GeorgiaPower A ENCLOSURE 2 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATION 3.7.6

! 10 CFR 50.92 EVALUATION CONCLUSION i Based on the preceding analysis, GPC has determined that the proposed l

! change to the Technical Specifications will not significantly increase the 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 '

margin of safety. GPC therefore concludes that the change meets the requirements of 10 CFR 50.92(c) and does not involve significant hazards I considerations. '

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ENCLOSURE 3 PLANT V0GTLE - UNIT l-NRC DOCKET 50-424  !

OPERATING LICENSE NPF-68 i REQUEST TO REVISE TECHNICAL SPECIFICATION 3.7.6  !

INSTRUCTIONS FOR INCORPORATION I The proposed amendment to the Technical Specifications (Appendix A to Operating License NPF-68) would be incorporated as follows: )

Remove Page Insert Paae 3/4 7-14 3/4 7-14 1 3/4 7-16 3/4 7-16 '

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