ML20196B923

Application for Amend to License NPF-68,revising Level Limits for Spray Additive Tank to Be Consistent W/Specified Vols & Deleting Control Bldg Sump Effluent Line Radiation Monitor Based on Piping Mod.Fee Paid

ML20196B923
Person / Time
Site:	Vogtle
Issue date:	02/04/1988
From:	James O'Reilly GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20196B926	List: ML20196B923 ML20196B955
References
SL-3777, NUDOCS 8802120187
Download: ML20196B923 (12)

Text

y_K '. i-

?! ' h. - Geomia Power Company

• J' ' ' 333 Piedmont Avenue

'E- Atlanta Georgia 30308 0" Skphone 404 526-7851

," Mail:ng Address:

Post Office Box 4545

, Atlanta, Georgia 30302 James P. O'Reitly the southern etmtrc sph.sn '

Senor Vice Presdent Nuclear Operations SL-3777 0679m X7GJ17-V600 February 4, 1988 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C. 20555 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 REOUEST TO REVISE TECHNICAL SPECIFICATIONS Gentlemen:

In accordance with 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. Two changes are proposed.

The first proposed change revises the level limits for the spray additive tank to be consistent with the specified volumes.

The second proposed change deletec the control building sump effluent line radiation monitor based on a piping modification which provides for monitoring by other instrumentation.

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

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

, Enclosure 3 provides instructions for incorporating the proposed ll amendment into the Technical Specifications. The proposed revised Technical Specification pages follow Enclosure 3.

l Payment of the required filing fee is enclosed.

In accordance with 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 enclosures.

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e U. S. Nuclear Regulatory Commission February 4, 1988 Page Two Mr. James P. O'Reilly 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: m .@

James P. O'Reilly b

Sworn to and subscribed before me th th 4 of February 1988.

YLuw ?)./? W Notary Public Notary Pubrio. Oeyton Commer, Os.

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Enclosures:

1. Basis for Proposed Changes

2. 10 CFR 50.92 Evaluation

-3. Instructions for Incorporation

4. Check _No. 181267 for Filing Fee c: (see next page) l

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U. S.-Nuclear Regulatory Commission February 4, 1988 Page Three c: Georaia Power Comoany Mr. P. D. Rice Mr. G. Bockhold,~Jr.

- Mr. J. E. Swartzwelder Hr. C. H. Hayes GO-NORMS Southern Comoany Services Mr. R. A. Thomas Mr. J. A. Bailey Shaw. Pittman. Potts & Trowbridae Hr. B. H.-Churchill, Attorney-at-Law Troutman. Sanders. Lockerman & Ashmore Mr. A. H. Domby, Attorney-at-Law U. S. Nuclear Reaulatory Commission Dr. J. N. Grace,' Regional Administrator Mr. J. B. Hopkins, Licensing Project Manager, NRR (2 copies)

Mr. J. F. Rogge, Senior Resident Inspector-0perations Vogtle State of Georgia Mr. J. L. -Ledbetter, Commissioner - Department of Natural Resources 0679m

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ENCLOSURE 1 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

BASIS FOR PROPOSED CHANGES PROPOSED CHANGE 1 Technical Specification 3.6.2.2 specifies upper and lower volume limits for the sodium hydroxide solution in the spray additive tank (SAT). These limits are given both as gallons and as percentages of level span. The proposed change revises the lower percentage of level span from 87.7% to 89.9% and the upper percentage from 97.4% to 97.2%. A revision to the Bases for Specification 3.6.2.2 is proposed to state that the specified volumes are deliverable rather than contained volumes.

BASIS FOR PROPOSED CHANGE A review of the percentages of level span currently contained in the Technical Specifications has revealed that they are not consistent with the volumes specified in gallons. The proposed change revises the percentages of level span to be consistent with the lower and upper volume -limits of 3700 and 4000 gallons, respectively. An evaluation has been performed to determine if operation at the currently specified lower percentage of level span would decrease the capability of the spray additive system to perform its intended function. The evaluation shows that the equilibrium containment sump pH following a loss of coolant accident (LOCA) would still be above the minimum design criterion of 8.5, although the amount of margin would be reduced. The slight inconsistency in the Technical Specifications, therefore, has no safety consequences.

The proposed revision to the Bases for Specification 3.6.2.2 clarifies that the volume limits for the SAT are the volumes assumed to be discharged and, thus, do not include the unusable portion of the tank contents.

PROPOSED CHANGE 2 Technical Specifications 3.3.3.9 and 4.3.3.9 provide limiting conditions for operation and surveillance requirements for radioactive liquid effluent monitoring instrumentation. The proposed change deletes the control building sump effluent line monitor (RE-17646) from these specifications.

0679m El-1 2/4/88 SL-3717

1 f 1, , ,

ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

BASIS FOR PROPOSED-CHANGES BASIS FOR' PROPOSED CHANGE Monitor RE-17646 is provided to minimize the release of radioactive liquid from the control building sump. As a result of a recent pipir.g modi fication, this function can now be performed by another existing radiation monitor, RE-0848.

In the original piping configuration, the control building sump effluent, after being monitored by RE-17646, was piped into the turbine

, building drain header downstream of RE-0848. The modification' has l relocated the tie-in to a point upstream of RE-0848. Monitor RE-0848 l

automatically diverts effluent flow to a radioactive drain tank when high radiation is sensed.

Monitor RE-17646 is not required to mitigate the consequences of any accident analyzed for Plant Vogtle. Since RE-0848 provides automatic diversion of radioactive sump effluent, RE-17646 can be deleted without adverse safety consequences.

l 0679m El-2 2/4/88 SL-3777

i ENCLOSURE 2' PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-68 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

10 CFR 50.92 EVALUATION In accordance with 10 CFR 50.92, Georgia Power Company has evaluated the attached proposed amendment to the VEGP Unit 1 Technical Specifications and has determined that operation of the facility in accordance with the proposed amendment would not involve significant hazards considerations. The basis for this determination is as follows:

PROPOSED CHANGE 1 Revise Technical Specification 3.6.2.2 by changing the lower SAT volume limit from 87.7% to 89.9% and the upper limit from 97.4% to 97.2%. Revise the Bases of Specification 3.6.2.2 to state that the specified volumes are deliverable rather than contained volumes.

BACKGROUND The limits on SAT volume and concentration ensure a pH value of 8.5 to 10.5 for the solution recirculated within containment after a LOCA.

This pH bGnd minimizes the evolution of iodine and minimizes the effect of chloride and caustic stress corrosion on mechanical systems and components. Review of the limits currently contained in the VEGP Technical Specifications has revealed that the values for percentages of level span are not consistent with the volumes specified in gallons. It is also noted that the volume limits are stated to be "contained volumes", while the intent is that they be deliverable volumes.

l Assuming that the plant has been operating with the level in the SAT l at the currently specified minimum percentage of level span, the deliverable volume of sodium hydroxide solution would be 3600 gallons instead of the minimum volume of 3700 gallons specified in the Technical Specifications and the FSAR. Operation with this reduced volume of spray additive has impact only on the equilibrium post-UXA sump pH for the scenario in which the total contents of the SAT are delivered to containment. The specification of 3700 gallons as the minimum SAT volume is consistent with assuring that the equilibrium sump solution pH would be 8.5 or greater when the total spray additive volume is delivered to the containment. If only 3600 gallons of spray additive are available, 0679m E2-1 2/4/88 SL-3777

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I ENCLOSURE 2-(Continued)

REQUEST.T0 REVISE TECHNICAL SPECIFICATIONS:

10 CFR 50.92 EVALUATION

.the deliverable volum is still adequate to assure that the equilibrium sump pH is 8.5 or greater; however, the amount of margin is reduced. The margin of safety for iodine retention in the sump solution, however, is inherent in the selection of a minimum pH of 8.5. The minimum value of 8.5 is also well above the pH limit of 7.0 specified in NRC Branch Technical Position HTEB 6-1 for prevention of chloride-induced stress corrosion cracking of sensitized stainless steel. Operation with 100 gallons less than the specified volume of 3700 gallons would, therefore, not alter the intended function of tiie spray additive system.

ANALYSIS GPC has reviewed the proposed change to the SAT volume limits and associated Bases and has determined that the change does not involve significant hazards considerations. In support of this conclusion the following analysis is provided:

1. The proposed change to the SAT volume limits does not significantly increase the probability or consequences of an accident previously evaluated. The change modi fies the

. percentages of level span to be consistent with the volumes specified in gallons and with the analysis limits for loss of coolant accidents. The change provides added margin above the minimum sump solution pH, ensuring that the consequences of a LOCA would be consi:, tent with previous analyses. The probability of a LOCA is not affected because the change does not affect any failure mode which could lead to a LOCA. The probability or consequences of previously analyzed accidents are therefore not increased. The proposed change to the Bases is an administrative change to achieve consistency within the Technical Specifications and has no effect on the probability or consequences of previously evaluated accidents.

2. The proposed change to the SAT volume limits does not create the possibility of a new or different kind of accident than any accident previously evaluated. The change does not alter the design, operation, maintenance, or testing of the spray additive system in a manner which could create a new failure mode. A new or different kind of accident could, therefore, not result. The proposed change to the Bases is an administrative change having no effect on plant design or operation and does not create the possibility of a new or different kind of accident.

0679m E2-2 2/4/88 SL-3777

ENCLOSURE 2 (Continued) <

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

10 CFR 50.92 EVALUATION

3. _The proposed change to the SAT volume ~ limits does not significantly reduce a margin of safety. The minimum sump solution pH of 8.5 contains adequate margins of safety for minimizing the evolution of iodine and for minimizing the effects of chloride and caustic- stress corrosion on mechanical equipment. The change provides additional .'nargi n above the minimum pH of 8.5 for the case where the SAT is completely discharged. A reduction in a safety margin would, therefore, not result from the change. The proposed administrative change to the Bases has no effect on safety margins.

CONCLUSION Based on the preceding analysis, GPC has determined that the proposed 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 significantly reduce a margin of safety. GPC, therefore, concludes that the proposed change meets the requirements of 10 CFR 50.92(c) and does not involve significant hazards considerations.

PROPOSED CHANGE 2 Revise Technical Specifications 3.3.3.9 and 4.3.3.9 by deleting the control building sump effluent line monitor (RE-17646) from Tables 3.3-9 and 4.3-5.

l BACKGROUND Radiation monitor RE-17646 is a part of the Process and E'ffluent Radiation Monitoring System (PERMS) and functions to minimize the release of radioactive liquid effluent from the control building sump. As a result of a recent piping modi fication, this function can now be performed by another PERMS monitor.

i 0679m E2-3 2/4/88 SL-3777

-ENCLOSURE 2 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

10 CFR 50.92 EVALUATION In the original piping configuration, the normally non-radioactive discharge from the control building sump was ronitored by RE-17646 then tied in to the turbine building drain header at a point downstream of radiation monitor RE-0848. A high radiation signal from RE-17646 would cause isolation of control building sump discharge flow into the turbine building drain header.

The piping has been modified so that the control building ' sump l discharge now ties in to the turbine building drain header upstream of RE-0848. Detection of high radiation by RE-0848 causes automatic diversion of drain header flow from its normal flow path (to the oily l waste separator, then the waste water retention basin, and then the blowdown sump) to the "dirty" turbine building drain tank. The attached figure provides a simplified illustration of the modification.

Honitor RE-17646 is not necessary for the mitigation of any accident analyzed for Plant Vogtle. Since RE-0848 now provides for minimizing radioactive discharge from the control building sump, RE-17646 can be deleted with no safety consequences. GPC is proposing to delete RE-17646 to reduce the manpower commitment and expense required for maintenance and surveillance.

ANALYSIS GPC has reviewed the proposed deletion of radiation monitor RE-17646 and has determined that the change does not involve significant hazards considerations. In support of this conclusion the following analysis is provided:

1. The proposed change does not significantly increase the probability or consequences of an accident previously evaluated. Neither the piping modification nor the deletion of RE-17646 have any effect on the failure modes which lead to analyzed accidents. Furthermore, monitor RE-17646 is not required to mitigate the consequences of any analyzed accidents. The probability or consequences of previously evaluated accidents are therefore not increased.

0679m E2-4 2/4/88 SL-3777 L.

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Turbine (h Control dI"9 Plant Cooling

-From Other Sumps From Unit 2 Nuclear Oily Service Cooling Water Waste

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Separator From Unit 2 Turbine Plant Cocling Tower i Weste Water Liquid Retention Waste Basin "9

sy From Unit 2 Waste

" " "o o Water Retention Basin From Unit 2 6 Blowdown  : Coo Mng Tower M eup Liquid Waste , Sump Bypass Line 7

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Construction of Luit 2)

Uv Radioactivity Monitors:

RE0020 RE0021 REW48 RE17646 RE0018

• The Blowdown Sump is ccmmon to both units.

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voGTts ELECTRH: GENERATING PLANT LIQVID DISCHARGE PATHWAYS COrgia NWer UNIT 1 AND UNIT 2 eaa o E2-5 i

(i ENCLOSURE 2 (Continued)  !

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

10 CFR 50.92 EVALUATION

2. The proposed change does not create the possibility of a new or different kind of- accident- than any accident previously evaluated. The change does not ' alter operation of the drain system or the PERMS system in a manner which could cause an unanalyzed accident. Since no new failure mode is created, a new or different kind of accident could not occur.

, 3. The proposed change does not significantly reduce a margin of I safety. Liquid discharged from the control building sump has low potential for contamination. Nonetheless, this effluent will be monitored by RE-0848 which is required by Technical Specifications to be operable at all times. Monitor RE-0848 has range and sensitivity similar to those of RE-17646 and will cause automatic diversion of effluent flow on sensing high radiation. The setpoint of RE-0848 will be determined in accordance with the Off-Site Dose Calculation Manual and will be as -low as possible without being subject to spurious actuations. As mentioned previously, control building sump effluent is discharged to the waste water retention basin.

( Discharge from the waste water retention basin is sampled and

analyzed as required by the Technical Specifications to ensure that releases to unrestricted areas do not exceed prescribed limits. It is, therefore, extremely unlikely that radioactive effluent from the control building sump would be released in an uncontrolled manner, and ample safety margin is maintained.

l CONCLUSION Based on the preceding analyses, GPC has determined that the proposed 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 significantly reduce a margin of safety. GPC therefore concludes that the proposed change meets the requirements of 10 CFR 50.92(c) and does not involve significant hazards considerations.

0679m E2-6 2/4/88 SL-3777 L

s ENCLOSURE 3 PLANT V0GTLE - UNIT l' NRC DOCKET 50-424 OPERATING LICENSE NPF-68 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

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

Remove Page Insert Pa 3/4 3-66 3/4 3-66 3/4 3-68 3/4 3-68 3/4 6-14 3/4 6-14 B 3/4 6-3 B 3/4 6-3 4

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