ML20155A719

Application for Amends to Licenses DPR-57 & NPF-5,modifying Reactor Protection Sys Instrumentation Surveillance Requirements.Proprietary GE Repts MDE-75-0485 & MDE-76-0485 Withheld.Fee Paid

ML20155A719
Person / Time
Site:	Hatch
Issue date:	03/27/1986
From:	James O'Reilly GEORGIA POWER CO.
To:	Muller D Office of Nuclear Reactor Regulation
Shared Package
ML19298D834	List: ML20155A719
References
0372C, 372C, SL-420, NUDOCS 8604090256
Download: ML20155A719 (9)

Text

._. - .. -. . . _ -

Georga Puer Company 333 Pie $90nt Avenue A*!anta, Georga 30308 Telephone 404 526-6526 c ox 4545 kla,ta Geoga 30302 James P. O'ReiHy (M southe n electre spt vn Semor Vee Presdent nacsar opere.ons SL-420 0372C Harch 27, 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 REQUEST TO REVISE REACTOR PROTECTION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS Gentlemen:

In accordance with the provisions of 10 CFR 50.90 as required by 10 CFR 50.59(c)(1), Georgia Power Company hereby proposes changes to the Technical Specifications, Appendix A to Operating Licenses DPR-57 and NPF-5.

The proposed changes would modify Reactor Protection System (RPS) instrumentation surveillance requirements for both Hatch Units. The requested changes fall into two areas: 1) Changes to the Hatch Unit 1 RPS (and Control Rod Block) furveillance Requirements to provide for consistency with the Hatch Unit 2 Tednical Specifications, and 2) Changes to RPS surveillance frequencies and outage times for both units resulting from GE Topical Report NEDC-30851P, which provides a probabilistic basis for RPS surveillance frequencies and allowed equipment outage times. We understand that an NRC Safety Evaluation Report (SER) approving NEDC-30851P will be issued in the near future.

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

Attachment 1 provides a detailed description of the proposed changes and bases for the changes.

Attachments 2 and 3 are Hatch plant specific analyses documenting that the Hatch plants are enveloped by the Generic Analysis of NEDC-30851P. These attachments are proprietary to General Electric company and are requested to be exempt from public disclosure.

Attachment 4 details the basis for our determination that the proposed changes do not involve a significant hazards consideration.

l 8604090256 DR 860327 ADOCK 05000321 1 PDR 4 j )c4pc44 e

gn49 $ p.C@

l

d Georgialbwer d Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 Director of Nuclear Reactor Regulation March 27,1986 Page Two Attachment 5 provides page change instructions for incorporating the proposed changes for Plant Hatch Unit 1.

Attachment 6 provides page change instructions for incorporating the '

proposed changet. for Plant Hatch Unit 2, ,

The proposed changed Technical Specification pages for Hatch Units 1 and 2 follcw Attachments 5 and 6, respectively, Payment of filing fee 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 approve (i 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 reqitirements of 10 CFR 50.91, Mr. 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 attachments.

J. P. O'Reilly, Jr. states that he is Vice President of Georgia Power Company and is etathorized to execute this oath on behalf of Georgia Power Company, and that to the best o' his knowledge and belief the facts set forth in the letter and attachment are true.

GEORGIA POWER COMPANY By: wd@

. P. O'Reilly Sworn to and subscribed before me this 27thJa of March,1986 V"'

< k0 Notary Public

% Public, Clayton Coun REB /lf C mm'ssi n Expires Dec i .Nhh Attachments c: Mr. H. C. Nix, Jr.

Senior Resident Inspector, Plant Hatch Dr. J. N. Grace Mr. J. L. Ledbetter GO-NORMS

. . ., O

GeorgiaPowerku ATTAQlMENT 1 NRC DOCKETS 50-321, 50*366 OPERATING LICENSES DPH 7 57, NPF-5 EDWIN 1. HATQi NUCLEAR FIANT UNITS 1, 2 REQUEST TO REVISE TEGINICAL SPECIFICATIONS:

DESCRIPTION OF O!ANGE AND TAST5' FOR OTANGE RE(UEST Proposed Change 1:

Change Unit 1 RPS and Control Rod Block instrumentatio'n siirveillance requirements to provide for consistency with Hatch Unit 2 Technical Specifications. All chanaes listed below affect Unit 1 Technical +

Specifications only. Proposed changes are as follows:

a. IRM High High Flux (Table 4.1 -1) -

01ange instrument calibration frequency from OnceNeek to once/ Operating Cycle. Delete reference to "during ref6eling", since applicable operational conditions are provided in Table 3.1-1 dnd note c. to Table 4 1-1. hbve requirement for testing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of startup froia Table 4,1-1 to note 1.

b. IRM Inoperative (Table 4.1-1) - 01ange instrument calibratibn ,

frequency from OnceNeek to not applicable (NA). Delete reference to "during refueling", since applicable operational conditions are provided in Table 3.1-1 and note c. to Table 4.1-1. Moye requirement for testing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of startup from Table 4.1-1 to note 1.

c. APRM Fixed Ifigh High Flux (Table 4.1-1) - Change instrtment calibraticn frequency froa WiceNeek to OnceNeck and Semi Annually (SA) and ndd note explaining two calibrations.

d. APRM Inoperable (Table 4.1-1) - Change instrument calibration frequency from Wice Neek to not applicable (NA):

e. APfdf Downscale (Table 4.1-1) e Change instrument calibration frequency from TwiceNe~ e k to not applicable (NA).

f. APRM Flow Referenced Simulated Thermal Power Monitor (Table 4.1-1) -

Change instrue:ent calibration frequency frem ,

TwiceNeek to onceNeek and Semi-Annually (SA) and add note explaining two calibrations.

Page 1

-=k - - -

+.. --.-s- --

w- -_ --

Georgia Potter sh s ATTACINENT 1 (Continued) l <

g. APRM 15% Flux (Table 4.1-1) - Oiange instrument functional test frequency from "within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of startup" to "OnceNeek during refueling" and add clarifying notes. Also -

add note requiring APRM, IRM, SRM overlap testing. Add statement that instrument calibration minimum frequency applies during refueling and add clarifying notes. 1 l

I

h. Move LIMf (Table 4.1-1) from item 12 to item 8.

j. There are currently no channel check requirements on Unit 1.

Adopt Hatch Unit 2 channel check requirements and minimum frequencies for all Unit 1 RPS instrumentation (Table 4.1-1).

J. Replace Unit 1 Table 4.2-7, " Check, Functional Test, and Calibration Minimum Frequency for Neutron Monitoring Instrumentation Which Initiates Control Rod Blocks," with a new- table based on Hatch Unit 2 and Standard Technical Specification requirements and formats.

Basis for Proposed Change 1:

Plant Hatch Units 1 and 2 contain essentially identical Reactor Protection System designs. Ibwever, Technical Specification format and requirements for RPS surveillance testing vary considerably between the units. These differences result primarily from the custom format of the Hatch Unit 1 Technical Specifications versus the Standard Technical Specification (STS) format for Hatch Unit 2. It is appropriate that - the RPS (ar.d Control Rod Block) instrumentation testing requirements for each unit be made as similar as possible.

This vill reduce confusion and allow for better maintenance and surveillance practice. Plant procedures are already in place to ensure that the littch Unit 2 RPS testing requirements, which are more thorough ths.n the Unit I requirements, hre applied to Unit I wherever {

'possible without creating a co:flict with the Unit 1 Technical l Specifications. In order to fully resolve this situation, changes to j the Unit 1 Technical Specifications are propoced which will I essentially adopt the current Unit 2 requirements. 'lhese changes, as identified in items a. through j. above, are justified as follous:

a. The requested once/ Cycle interval is consistent with Hatch j Unit 2 Technical Specifications and D'R S1S. Calibration on '

a OnceNeck basis, due to the time required for calibration and the r. umber of IRM channels, involves almcst constant ,

1

)

Page 2 l

1 j

~ . . . -

_ ___ _l_ _ _

Georgia Power A AITAONENT 1 (Continued) calibration and declaration of inoperable channels. Having less than the optimum number of channels operable at most times could result in some degradation of as-designed RPS reliability. Herefore, approval of this change should increase the margin of safety.

b. He requested change to NA is consistent with Hatch Unit 2 Technical Specifications and BWR STS. According to General ,

Electric, this equipment is not intended to be calibrated.

c. He requested change is consistent with Hatch Unit of2 Technical Specifications and BWR STS. Two types calibrations are required. One is perfomed on a weekly basis and one on a semi-annual basis. We requested change explicitly provides these requirements.

d. The requested change to NA is consistent with the Hatch Unit 2 Technical Specifications and BWR STS. According to General Electric, this equipment is not intended to be calibrated.

e. He requested change to NA is consistent with the Hatch Unit 2 Technical Specifications. Latest versions of BWR STS no longer contain requirements for the APRM downscale trip. t According to General Electric, this equipment is not intended to be calibrated.

f. He requested change is consistent with Hat'c h Unit 2 Technical Specifications and BWR STS. 1Vo types of i calibrations are required. One is performed on a weekly basis and one on a semi-annual basis. He requested change explicitly provides these requirements.

g. According to Hatch Unit 2 Technical Specifications and BWR STS, a functional test and channel calibration is required:

1) Weekly while in the refueling mode; 2) Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of startup, if not perfomed within the previous seven days; and 3) When changing from the Run to thetoStart and Hot Table 4.1-1, Standby mode. Addition of notes 1. and m.

and addition of "during refueling" to the weekly surveillance requirements, explicitly provide the correct require!4ents.

Additionally, note n. is added to require performance of

- overlap testing during each startup.

h. His change is for clarification only. No requirements are affected.

l Page 3 l

t

GeorgiaPower d ATTAONENT 1 (Continued)

1. His change adopts Hatch Unit 2 Gannel meck Requirements to Hatch Unit 1, which currently contains none. His is clearly a conservative change, and again, is provided for consistency.

j. he Hatch Unit 2 Control Rod Block Instrumentation surveillance requirements are adopted to the Unit 1 Technical Specifications. Hatch Unit 2 and BWR S15 do not contain requirements for channel checks for Control . Rod Block instrumentation. In general,. the affected instruments display no information which would provide a useful channel check. Herefore, it is appropriate to delete the current channel check requirements for this instrumentation.

We proposed changes are in some cases more conservative, and in other cases less conservative, than the present Unit 1 RPS surveillance requirements. However, overall, testing requirements for Unit I will be made more stringent under the proposed change. In all cases the proposed changes are consistent with the NRC approved requirements for Hatch Unit 2. Additionally, the requested changes are generally consistent (given format differences) with BWR STS and are consistent with General Electric technical instructions for the affected instrumentation.

Approval of the proposed changes will result in consistent and correct RPS and Control Rod Block instrumentation surveillance requirements for both Hatch Units, identified in similar format.

Adaptation of correct and equivalent surveillance requirements for

, essentially identical equipment will improve overall plant safety.

Proposed Gange 2:

he proposed changes for both Hatch Units result from General Electric Topical Report NEDC-30851P, and corresponding plant specific

analyses for Plant Hatch Unit 1 (MDE-75-0485) and Unit 2 (MDE-76-0485). Rese plant specific analyses are included as Attachments 5 and 6, respectively, to this letter, and identify the

' differences between the parts of the RPS that perform the trip functions in the Hatch Plants and those of the base case plant analyzed in NEDC-30851P. These reports provide a probabilistic basis for extending RPS surveillance and (in the case of Hatch Unit 2) allowed equipment outage times. He methodology shows that the requested interval extensions can be enacted without negatively Page 4 l

l .

GeorgiaPower A ATTACHMENT 1 (Continued)

An NRC affecting the functional capability or reliability of the RPS.

Safety Evaluation Report (SER) generically endorsing the methodology and changes provided by the above reports is expected to be issued imminently. Following issuance of this SER, we request that the following changes, as described in the above rep) orts, be approved for Plant Hatch Units 1 and 2 (Changes a. through c. and Plant Hatch Unit 2 (Changes d. and e.):

a. Change instrument functional test frequency (Table 4.1-1 for Unit 1, Table 4.3.1-1 for Unit 2) for Manual Scram from quarterly to weekly. (This change is necessary to ensure that the K-14 scram contactors continue to be tested at a frequency which will not degrade RPS reliability.)

b. Change the following RPS instrumentation functional test frequencies (Table 4.1-1 for- Unit 1, Table 4.3.1-1 for Unit

2) from monthly to quarterly:

1. Reactor vessel steam dome high pressure scram

2. High drywell pressure scram

3. Reactor vessel water low level scram

4. Scram discharge volume high level scram

5. Main steam isolation valve closure scram

6. Turbine control valve closure scram

7. Turbine stop valve closure scram

c. Change the following RPS instrumentation functional test frequencies (Table 4.1-1 for Unit 1, Table 4.3.1-1 for Unit

2) from weekly to quarterly:

1. APRM high high flux scram

2. APRM inoperable scram

3. APRM flow referenced simulated thermal power monitor scram

4. Main steam line high radiation scram

d. For Hatch Unit 2 only, change Action Statement 3.3.1.a. to allow twelve hours (instead of one hour) to place an inoperable channel in the tripped condition when the requirements for the minimum number of Operable channels cannot be met.

Page 5

i l

l Georgia Potver A i

l ATTAONENT 1 (Continued)

e. For Hatch Unit 2 only, change note a. to Table 3.3.1-1,

" Reactor Protection System Instrumentation", to allow a channel to be made inoperable for su.veillance - purposes without placing the channel in the tripped condition for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (instead of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />).

Appropriate detailed justifications for each of the above changes are contained in NEDC-30851P and will be approved by a generic NRC SER. Therefore, no further justification is necessary. A determination of no significant hazards is included under Attachment 2.

i Page 6 m .Ap a

l l

GeorgiaPower A ATTACINENT 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2 REQUEST TO PJVISE TECHNICAL SPECIFICATIONS:

GENERAL ELECTRIC REPORT MDE-75-0485 TECHNICAL SPECIFICATION IMPROVEMENT ANALYSIS FOR THE REALTOR PROTECTION SYSTE! FOR EDWIN. I HATCH NUCLEAR PLANT, UNIT 1 NOTICE: This information is proprietary to General Electric Company and should be withheld from public disclosure.

i l

I O

. . . . . 1 ,