ML20154B555

Application for Amends to Licenses DPR-57 & NPF-5,revising Stroke Time Operability Requirements for MSIVs by Extending Required Second Closing Time Interval to 2 to 8 S.Rept EAS-05-0188 Encl.Rept Withheld (Ref 10CFR2.790).Fee Paid

ML20154B555
Person / Time
Site:	Hatch
Issue date:	05/13/1988
From:	Mcdonald R GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML19302D606	List: ML20154B555 ML20154B561
References
SL-4109C, NUDOCS 8805170232
Download: ML20154B555 (10)

Text

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j SL-4109c 0252I X7GJ17-H600 May 13, 1988 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D. C. 20555 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPT-5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

MSIY CLOSURE TIME REOUIREMENTS 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 Plant Hatch Units 1 and 2 Technical Specifintions, Appendix A to Operating Licenses DPR-57 and NPF-5.

These proposed changes would revise the stroke time operability requirements for the Main Steam Line Isolation Valves (MSIVs),

i Specifically, the currently required 3 to 5 second closing time interval '

would be extended to 2 to 8 secends. Associated with this change, the I Unit 2 Technical Specifications (TS) would be modified to be consi3 tent with the Boiling Hater Reactor Standard Technical Specifications (NUREG-0123, Revision 3). To improve consistency between the Unit I and the Unit 2 TS, a specification specifically addressing MSIV requirements will be added to the Unit 1 TS. Also, for consistency, modifications will be made to the Definitions, Containment Systems, and Bases sections of the Unit 1 TS. GPC has determined that the implementation of these proposed changes will have an insignificant impact on existing plant safety analyses and, therefore, will not have an adverse impact on plant safety. These proposed changes, when approved, will provide increased flexibility during surveillance testing and will result in increased {

operability of the MSIVs without a reduction in safety.

Enclosure 1 provides detailed descriptions of these proposed changes and the circumstances necessitating the change request.

changes Enclosure do not 2involvedetailssignificant the bases for ourconsiderations.

hazards determination that the proposed go (

i 8805170232 880513 PDR ADOCK 05000321 i u,/ l C b 'C @

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GeorgiaPower A U. S. Nuclear Regulatory Co uission May 13, 1988 Page Two 4 Enclosure 3 provides page change instructions for incorporating the proposed changes. The proposed changed TS pages for Unit I and Unit 2 follow Enclosure 3.

To support the proposed changes, Enclosure 4 provides documentation that has not previously been submitted to the Nuclear Regulhtory Commission (NRC). Please note that some of the information contained in Enclosure 4 has been marked "Proprietary" to protect the commercial interest of the vendor. In accordance with 10 CFR 2.790, an affidavit requesting that certain information be withheld from the public domain is included herein.

Payment of the filing fee in the amount of one hundred fifty dollars is enclosed.

To allow time for procedure revi Alons and orderly incorporation into copies of the TS, GPC requests that the proposed amendments, once approved by the NRC, be issued with an effective date to be no later than 60 days from the date of issuance of the amendments.

In accordance with 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. R. P. Mcdonald states he is Executive 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 are true.

.i GEORGIA POWER y PANY By: > f')b

/

R. P. Mcdonald /

/

Swor to an subscribed before me this 13th day of May 1988.

//

Notary Public d[I P_ -[d$Yi,%

GDP/lc

Enclosures:

(See next page.)

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Georgia Power k z.

U. S. Nuclear Regulatory Commission May 13, 1988 Page Three

Enclosures:

1. Basis for Change Request.

2. 10 CFR 50.92 Evaluation.

3. Pag) Change Instructions.

4. "Safety Evaluation for Extension of HSIV Stroke Time Requirements for Plant Hatch Units 1 and 2," EAS-05-0188.

5. Filing Fee - $150.00.

c: Georaia Power Comoany Mr. J. T. Beckham, Jr., Vice President - Plant Hatch Mr. L. T. Gucwa, Manager Nuclear Safety and Licensing GO-NORMS U. S. Nuclear _Rftgulatory Commission. Hashington. D. C.

Hr. L. P. Crocker, Licensing Project Manager - Hatch U. S. Nuclear Regulatory Commission. Region II Dr. J. N. Grace, Regional Administrator Hr. P. Holmes-Ray, Senior Resident Inspector - Hatch State of Georgia Mr. J. L. Ledbetter, Commissioner - Department cif Natural Resources s

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GeorgialbwerA l

ENCLOSURE 1 l

PLANT HATCH - UNITS 1, 2 l NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS: l HSIV CLOSURE TIME REQUIREMENTS i BASIS FOR CHANGE REOUEST 130EOSED CHANGE 1:

This change revises the Plant Hatch Units 1 and 2 Technical j Specifications (TS) pertaining to the Main Steam Line Isolation Valve '

(MSIV) stroke time interval to reflect the evaluation results presented in "Safety Evaluation for Extension of MSIV Stroke Time Requirements for Plant Hatch Units 1 and 2," EAS-05-0188, January 1988 (Enclosure 4). ,

Specifically, the current 3 to 5 second closing time interval requirement j is being extended to 2 to 8 seconds. This new closure time interval is reflected in Specification 3/4.4.7 of the Unit 2 TS and in a new Speci fication, 3/4.6.H, of the Unit 1 TS.

i Basis for ProDosed Change _1:

The closure time interval required for the HSIVs is established to limit

' the release of reactor coolant or radio?ctive materials in the event of a design basis accident and to prevent violating pressurization or thermal limits during transient events. The Safety Evaluation documented in Enclosure 4 provides the results of evaluations regarding the impact of both a more rapid MSIV closure time and a slower closure time on safety analyses.

The shorter stroke time (2 seconds) primarily impacts transient analyses l related to inadvertent MSIV closure. The transient analyses include l overpressure protection and fuel thermal limits, and an analysis to l verify the integrity of the main steam lines. The shorter stroke time also has an indirect impact on the Loss-of-Coolant Accident (LOCA) and containment response. The evaluations presented in Enclosure 4 demonstrate that reducing the minimum MSIV closure time from 3 to 2 seconds does not have a significant impact on the areas described above.

The longer HSIV stroke time (8 seconds) mainly affects reactor inventory loss and radiological release during accident events. Extending the closure time could potentially affect postulated transient events which result in reactor depressurization and the bases for establishing environn ntal qualification of electrical equipment. All these areas i were evaluated in Enclosure 4, and it was determined that an 8 second maximum MSIV closure time has an insigni ficar.t impact on these i evaluations.

0252I El-1 5/13/88 SL-4109C nom

GeorgiaPower d ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

MSIV CLOSURE TIME REQUIREMENTS BASIS FOR CHANGE REOUEST Basis for Procosed Change 1: (Continued)

The Enclosure 4 evaluation demonstrates that extending the required MSIV closure interval to 2 to 8 seconds will not significantly impact plant safety.

PROPOSED CHANGE 2:

Proposed Change 2 clarifies sections of the Unit 2 TS to ensure consistency with the Boiling Hater Reactor Standard Technical Specifications (BHRSTS), while additionally revising the Unit 1 TS to provide consistency with those of Unit 2. In part, this change deletes reference to the HSIVs from Primary Containment Isolation Valve (PCIV)

Tables 3.6.3-1 of the Unit 2 TS and 3.7-1 of the Unit 1 TS, and adds a new specification, 3/4.6.H. to the Unit 1 TS. In addition, notes indicating the HSIVs are Group 1 isolation valves have been added to Tables 3.6.3-1 (Unit 1 TS) and 3.7-1 (Unit 1 TS). This note indicating the HSIVs are Group 1 isolation valves has also been added to Unit 1 Specification 3/4.6.H and Unit 2 Specification 3/4.4.7. Proposed Change 2 also modifies a footnote related to valve opening requirements in Unit 2 Table 3.6.3-1 and Unit 1 Table 3.7-1, while clarifying the Definitions, Primary Containment Integrity, and Primary Containment Isolation Valves sections of the Unit 1 TS (Sections 1.0.T. 3.7.A.2, and 3/4.7.0, respectively). In addition, Bases sections 1.2 and 3/4.6.H in the Unit 1 TS are new modified to3/4.6.H.

Specification reflect the extended MSIV stroke time interval and the Basis for ProDosed Change 2:

The Unit 2 TS have the same format as the Nuclear Regulatory Commission (NRC)-issued BWRSTS. The BWRSTS contain a separate Reactor Coolant System Specification (3/4.4.7) that specifically addresses the operability and surveillance requirements of the HSIVs. In addition to listing the required closing interval for the HSIVs, this specification allows 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for an inoperable HSIV to be restored to operable status prior to isolating the affected steam line. Also included in the BHRSTS is a Containment Systems specification (3/4.6.3) which provides the requirements for the PCIVs listed in Table 3.6.3-1. Specification 3/4.6.3 allows only 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to restore operation of an inoperable PCIV or to isolate the affected penetration before shutdown proceedings are initiated. The HSIVs are not specifically referenced in the BHRSTS Table 0252I El-2 5/13/88 SL-4109C rwm

u GeorgiaPower d ENCLOSURE I (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

MSIV CLOSURE TIME REQUIREMENTS BASIS FOR CHANGE RE00EST Basis for Proposed Change 2: (Continued) 3.6.3-1. Clearly, the requirements of 3/4.4.7 are intenaed for the MSIVs. The Unit 2 TS, in addition to containing Specification 3/4.4.7, also lists the HSIVs in PCIV Table 3.6.3-1, creating a discrepancy between the requirements of 3/4.4.7 and 3/4.6.3. To clarify the TS and to provide consistency with the NRC-issued BWRSTS, GPC proposes that reference to the HSIVs in Unit 2 TS Table 3.6.3-1 be deleted. Similarly, reference to the HSIVs will be deleted from Unit 1 TS Table 3.7-1 (and from the associated Surveillance Requirements of 4.7.D.1), and a new Specification, 3/4.6.H, reflecting the requirements of the Unit 2 HSIV Specification 3/4.4.7 will be added. Removing the HSIVs from Tables 3.6.3-1 and 3.7-1 deletes reference to the HSIVs as Group 1 PCIVs. For clarity, notes are added to Unit 2 Table 3.6.3-1 and Unit 1 Table 3.7-1, and Specifications 3/4.6.H and 3/4.4.7 of the Units 1 and 2 TS, respectively, to indicate the MSIVs are Group 1 isolation valves.

BHRSTS Table 3.6.3-1 contains a generic footnote that allows PCIVs to be opened (when normally required to be closed) under administrative control on an intermittent basis. The basis for this footnote is to allow PCIVs to be opened (with proper controls) during accident conditions to facilitate safety-related functions. Therefore, any PCIV that is not locked closed can be intermittently opened if sufficient administrative controls exist. This requirement is clarified in the Plant Hatch TS by revising the footnotes to Table 3.6.3-1 of the Unit 2 TS and Table 3.7-1 of the Unit 1 TS.

Additionally, for uniformity between the TS of both units, the Unit I definition of Primary Containment Integrity (Section 1.0.T), Primary Containment Integrity Spacification 3.7.A.2, and Primary Containment Isolation Valves Specification 3/4.7.0 are proposed to ba revised to be consistent with the corresponding sections in the Unit 2 Specifications.

This includes removing the surveillance requirement on lines with an inoperable PCIV (Unit 1 Specification 4.T.D.2), since it is not a requirement in the BHRSTS.

In addition to changes reflecting the extended MSIV stroke time interval, Bases section 1.2 has also been modified to delete discussion and reference to an outdated overpressure transient analysis that assumes a direct reactor scram on valve position. Since the worst overpressure transient (MSIV closure neglecting direct scram) is already discussed in this Bases section, a discussion of a less severe transient is not required.

0252I El-3 5/13/88 SL-4109C

GeorgiaPower A ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

MSIV CLOSURE TIME REQUIREMENTS BASIS FOR CHANGE RE0UEST Basis for Prooosed Change 2: (Continued) 3.6.3-1. Clearly, the requirements of 3/4.4.7 are intended for the MSIVs. The Unit 2 TS, in addition to containing Specification 3/4.4.7, also lists the HSIVs in PCIV Table 3.6.3-1, creating a discrepancy between the requirements of 3/4.4.7 and 3/4.6.3. To clarify the TS and to provide consistency with the NRC-issued BWRSTS, GPC proposes that reference to the MSIVs in Unit 2 TS Table 3.6.3-1 be deleted. Similarly, reference to the MSIVs will be deleted from Unit 1 TS Table 3.7-1 (and from the associated Surveillance Requirements of 4.7,0.1), and a new Specification, 3/4.6.M. reflecting the requirements of the Unit 2 MSIV Specification 3/4.4.7 will be added. Removing the MSIVs from Tables 3.6.3-1 and 3.7-I deletes reference to the MSIVs as Group 1 PCIVs. For clarity, notes are added to Unit 2 Table 3.6.3-1 and Unit 1 Table 3.7-1, and Specifications 3/4.6.M and 3/4.4.7 of the Units 1 and 2 TS, respectively, to indicate the MSIVs are Group 1 isolation valves.

BHRSTS Table 3.6.3-1 contains a generic footnote that allows PCIVs to be opened (when normally required to be closed) under administrative control on an intermittent basis. The basis for this footnote is to allow PCIVs to be opened (with proper controls) during accident conditions to facilitate safety-related functions. Therefore, any PCIV that is not locked closed can be intermittently opened if sufficient administrative controls exist. This requirement is clarified in the Plant Hatch TS by revising the footnotes to Table 3.6.3-1 of the Unit 2 TS and Table 3.7-1 of the Unit 1 TS.

Additionally, for uniformity between the TS of both units, the Unit I definition of Primary Containment Integrity (Section 1.0.T). Primary Containment Integrity Specification 3.7.A.2, and Primary Containment Isolation Valves Specification 3/4.7.0 are proposed to be revised to be consistent with the corresponding sections in the Unit 2 Specifications.

This includes removing the surveillance requirement on lines with an inoperable PCIV (Unit 1 Specification 4.T.D.2), since it is not a requirement in the BWRSTS.

In addition to changes reflecting the extended MSIV stroke time interval, Bases section 1.2 has also been modi fied to delete discussion and reference to an outdated overpressure transient analysis that assumes a direct reactor scram on valve position. Since the worst overpressure transient (MSIV closure neglecting direct scram) is already discussed in this Bases section, a discussion of a less severe transient is not required.

0252I El-3 5/13/88 SL-4109C mm ._ _ - _ _ _

GeorgiaPower A ENCLOSURE 1 (Continued)

• REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

MSIV CLOSURE TIME REQUIREMENTS BASIS FOR CHANGE RE0 VEST B3 sis for ProDosed Change 2: (Continued)

All TS modifications discussed under Proposed Change 2 are basically administrative changes to clarify the TS and improve consistency between the units. These revisions are also consistent with the requirements of the NRC-issued BHRSTS and, therefore, will not adversely affect plant equipment or system operation.

0252I El-4 SL-4109C 5/13/88 rw m

Georgia Power b ENCLOSURE 2 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES OPR-57, NPF-5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

MSIV CLOSURE TIME REQUIREMENTS 10 CFR 50.92 EVALUATION

) PROPOSED CHANGE 1_:

This change revises the Plant Hatch Units 1 and 2 TS pertaining to the HSIV stroke time interval to reflect the evaluation results presented in "Safety Evaluation for Extension of MSIV Stroke Time Requirements for Plant Hatch Units 1 and 2," EAS-05-0188, January 1988 (Enclosure 4).

Specifically, the current 3 to 5 second closing time interval requirement it being extended to 2 to 8 seconds. This new closure time interval is 4 reflected in Specification 3/4.4.7 of the Unit 2 TS and in a new '

Specification, 3/4.6.H, of the Unit 1 TS.

p.c is for No Sianificant Hazards Consideration Determination:

The proposed change does not involve a significant hazards consideration for the following reasons:

1.

It does not involve a significant increase in the probability or consequences of an accident previcusly evaluated, because the  ;

evaluation presented in Enclosure 4 concludes that the results '

of evaluations dependent on the HSIV closure interval will not  !

be significantly impacted by the extension of the interval to 2 to P seconds, l j

2. It does not create the possibility of a new or different kind of accident from any previously evaluated, because no change in r,lant design or operation will occur as a result of this change.

3. The proposed change does not involve a significant reduction in the margin of safety, because the evaluation presented i r.

Enclosure 4 demonstrates that extending the MSIV closury interval does not have a significant impact on plant safety analyses.

0252I E2-1 5/13/88 SL-4109C mm

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l GeorgiaPower A ENCLOSURE 2 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

MSIV CLOSURE TIME REQUIREHENTS 10 CFR 50.92 EVALUATION PROPOSED CHA%LZ:

As discussed in Enclosure 1, Proposed Change 2 clarifies sections of the Plant Hatch TS related to HSIVs, Primary Containment Integrity, and PCIVs to improve consistency between the Unit 1 and Unit 2 'S and to reflect the requirements of the BHRSTS.

Basis for No Significant Haitards Consideration Determination:

The proposed change does not involve a significant hazards consideration for the following reasons:

1. It does not involve a significant increase in the probability or consequences of an accident previously evaluated, because no change in plant operation will occur as a result of this change. This change provides consistency and reflects the requirements of the NRC-issued BHRSTS.

2 It does not create the possibility of a new or different kind of accident from any previously analyzed, because the change is basically administrative in nature, clarifies the TS, and does not introduce any new modes of plant equipment operation or failure.

3. It does not involve a significant reduction in the margin of safety, because plant operation is not affected and analyzed margins of safety are unchanged.

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a o i Georgia Power A f ENCLOSURE 3 PLANT HATCH - UNITS 1, 2  !

NRC DOCKETS 50-321, 50-366 OPERATING LICENSES OPR-57, NPF-5 t REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

MSIV CLOSURE TIME REQUIREMENTS PAGE CHANGE INSTRUCTIONS The proposed changes to the Unit I and Unit 2 Technical Specifications (Appendix A to Operating Licenses OPR-57 and NPF-5) would ba incorporated as follows: '

UNIT 1 Remove Pagg Insert Pagt 1.0-4 1.0-4 1.2-3 1.2-3 1.2-5 1.2-5 3.6-10e 3.6-10f .

3.6-32 3.6-32 '

3.7-2 3.7-2 3.7-3 3.7-3  !

3.7-14 3.7-14 3.7-16 3.7-16 3.7-16a 3.7-16a 3.7-17 3.7-17 .

3.7-18 3.7-18 3.7-18a 3.7-18a  !

3.7-18b 3.7-18b  !

3.7-19 3.7-19 j 3.7-19a 3.7-19a UNIT 2 Remove Page Insert Pagg 3/4 4-19 3/4 4-19 3/4 6-17 3/4 6-17 3/4 6-18 3/4 6-18 3/4 6-19 3/4 6-19  !

3/4 6-20 3/4 6-20 +

3/4 6-21 3/4 6-21 3/4 6-22 3/4 6-22 3/4 6-23 3/4 6-23 3/4 6-24 3/4 6-24 a 3/4 6-25 3/4 6-25 3/4 6-26 3/4 6-26 3/4 6-27 3/4 6-27 I'

3/4 6-28 3/4 6-28 3/4 6-29 3/4 6-29

3/4 6-30 3/4 6-30 3/4 6-31 3/4 6-31 3/4 6-32 3/4 6-32 i

02521 E3-1 5/13/88 SL-4109C 7C0775