ML20207J597

Application for Amend to License NPF-5,changing Tech Specs to Allow Use of Rosemount Transmitters for Analog Transmitter Trip Sys Instruments & Changing Limits for High Drywell Pressure Instruments.Fee Paid

ML20207J597
Person / Time
Site:	Hatch
Issue date:	07/18/1986
From:	Beckham J GEORGIA POWER CO.
To:	Muller D Office of Nuclear Reactor Regulation
Shared Package
ML20207J601	List: ML20207J597 ML20207J604 ML20207J614
References
SL-978, TAC-62029, NUDOCS 8607290184
Download: ML20207J597 (8)

Text

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Georgsa Power Company 333 Predmont henue A!!anta Georg<a 30308 Telephone 404 S26-7020 s Of e B5x 4545 Atlanta Georg>a 30302 Georgia Power J. T. Beckham, Jr.

vice prescer4 ano cenerai vanager SL-978 nuecar cenera en 0622C July 18',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 DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 REQUEST TO REVISE SETPOINTS FOR CERTAIN ANALOG TRANSMIIIt.R TRIP SYSTEM INSTRUMENTS 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 Technical Specifications, Appendix A to Operating License NPF-5.

Four areas of. changes are proposed: Proposed change one would revise Technical Specifications allowable values to provide for the use of Rosemount, as well as Barton, transmitters for certain Analog Transmitter Trip System (ATTS) instruments. Proposed change two would provide certain administrative clarifications. Proposed change three would revise the analytical limits and the corresponding allowable values for instruments which actuate on high drywell pressure. Proposed change four would lower the core spray (CS) and residual heat removal low pressure coolant injection (RHR-LPCI)' low reactor pressure injection permissive setpoints to allow for increased flexibility in the use of Rosemount transmitters for this trip function.

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

We request NRC approval of this change within 90 days of the submittal date in order to support orderly startup from the upcoming refueling outage scheduled to commence in September 1986.

Enclosure 1 provides detailed descriptions of the proposed changes and the bases for the changes.

Enclosure 2 details the basis for our detennination that the proposed changes do not involve a significant hazards consideration.

I 8607290184 860718 PDR ADOCK 05000366 P PDR p ,

E GeorgiaPowerkh Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 Director of Nuclear Reactor Regulation July 18, 1986 Page Two Enclosure 3 provides page change instructions for incorporating the proposed changes into the Technical Specifications.

The proposed changed Technical Specifications pages follow Enclosure 3.

Payment of the filing fee in the amount of one hundred and fif ty dollars 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 approved 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 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. J. T. Beckham, Jr. states that he is Vice President of Georgia Power Company and is authorized to execute this oath on behalf of Georgia Power Company, and that to the be.t of his knowledge and belief, the facts set forth in the letter and enclosures are true.

GEORGIA POWER COMPANY By: Sv y J. T. Beckham, Jr.

Sworn to and subscribed before me this 18th day of July 1986.

LL f rJ2 Notary Public

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• R NN Enclosures c: Georria Power Company U.S. Nuclear Regulatory Commission Mr.t. P. O'Reilly Dr. J. N. Grace, Regional Administrator Mr. H. C. Nix, Jr. Senior Resident Inspector GO-NORMS State of Georgia Mr. J. L. Ledbetter 0622C 700775

Georgia Powerkh ENCLOSURE 1 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 REQUEST TO REVISE SETPOINTS FOR CERTAIN ANALOG TRANSMIIIER TRIP SYSTEM INSTRUMENTS BASIS FOR CHANGE REQUEST Proposed Change 1: This proposed change would revise Technical Specifications allowable values (and trip setpoints, which are the same as the allowable values) for the reactor vessel water levels 1, 2, and 3; the shroud water level; the HPCI and RCIC steam line high flow; and the reactor steam dome low-pressure instruments.

Present Proposed Trip Function Allowable Value Allowable Value Reactor Yessel Water Level 1 -121.5 inches -113 inches Reactor Vessel Water Level 2 -55 inches -47 inches Reactor Vessel Water Level 3 8.5 inches 10 inches Reactor Shroud Water Level 0 -207 inches -202 inches Reactor Yessel Steam Dome 325 psig 335 psig Pressure Low HPCI Steam Line High Flow 307% 303%

RCIC Steam Line High Flow 307% 31 2%

The original design of the Analog Transmitter Trip System (ATTS) provided for the use of Barton Models 763 and 764 transmitters. Georgia Power has now decided to replace the Barton transmitters, through attrition, with Rosemount Models 1153 and 1154 transmitters, because the Rosemount transmitters offer increased operational and maintenance flexibility. It is expected that certain of the Barton transmitters will be replaced with Rosemount transmitters in the upcoming refueling outage scheduled for September 1986. Because the accuracy characteristics of the Barton and Rosemount transmitters differ, it is necessary to calculate new Technical Specifications allowable values, using the established analytical limits, to El-1 0622C 7/18/86 rwirL _ _ -. ._ . _ _ _ _ _ ----= - ----- . - - -

E Georgia Power d ENCLOSURE 1 (Continued)

NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 REQUEST TO REVISE SETPOINTS FOR CERTAIN ANALOG TRANSMIITER TRIP SYSTEM INSTRUMENTS BASIS FOR CHANGE REQUEST acconnodate the new transmitter types. The proposed allowable values would bound both transmitter types and allow the installation of either type transmitter without requiring further Technical Specifications changes. The proposed allowable values were calculated using the criteria of Regulatory Guide 1.105 and the specifications of the Barton and the Rosemount transmitters. The methodology used to determine the septoints was previously approved by the NRC in the safety evaluation included with Amendment 39 to the Hatch Unit 2 Technical Specifications. In all cases, the proposed allowable values are conservative with respect to the existing allowable values. The actual (in-plant) trip setpoint will take into account instrument drift.

Since the proposed allowable values were calculated using an approved methodology and are more conservative than the present values with respect to the analytical limits, the probOilities or consequences of analyzed accidents will not be increased by the proposed change. The proposed change does not involve new modes of operation; therefore, no new types of accidents are created. The proposed change does not decrease margins of safety, since all proposed limits are conservative with respect to the analytical limits.

Proposed Change 2: This proposed change would provide administrative i

clarifications to the Technical Specifications as follows:

f A. Correct the parts number for the ATTS recirculation pump trip l

instruments appearing in Table 3.3.1-1. Correct parts numbers 2821-N024 A, B and 2821-N025 A, B would replace the presently listed 2821-N681 A, B, C, D.

B. The reactor shroud water level trip (2821-N685 A, B), as listed in

, Table 3.3.3-1, is not a high-level trip. Thus, the word "High" is deleted from the table.

{ C. The suppression chamber water level high trip function (2E41-N662 A, I B) used an arbitrary zero point to derive the allowable value. The I

new allowable value (154.2 inches versus 33.2 inches) is derived from the torus invert. The actual level is unchanged.

El-2 0622C 07/18/86 L =m

GeorgiaPower A ENCLOSURE 1 (Continued)

NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 REQUEST TO REVISE SETPOINTS FOR CERTAIN ANALOG TRANSMIlitR TRIP SYSTEM INSTRUMENTS BASIS FOR CHANGE REQUEST D. The suppression pool area differential temperature high system (2E51-N665 A, B, C, D; 2E51-N663 A, B, C, D; and 2E51-N664 A, B, C,

, D) allowable value is proposed to be changed from 42.50F to 420F for simplicity. Adequate margin is provided in the setpoint calculation such that.either allowable value is appropriate.

l These proposed changes represent administrative clarifications or corrections to the Technical Specifications. No changes to plant operation would result from these administrative changes. Thus, the probabilities and consequences of analyzed accidents will not be increased by the proposed change. No new accident types are created by the proposed change. Margins of safety are not reduced by the proposed change.

Proposed Change 3: During the upcoming refueling outage scheduled to commence in September 1986, the presently installed Barton model 746 transmitters, which provide the high drywell pressure trip function, would be replaced with Rosemount model 1154 transmitters. This modification will necessitate the establishment of a new Technical Specifications allowable value for the high drywell pressure trip function. The proposed allowable value takes into account the improved accuracy of the Rosemount transmitter types which would be installed. The proposed value of 1.92 psig would replace the current value of 1.85 psig. Approval of this change is required to support unit startup from the upcoming outage.

Installation of the ATTS replaced the original drywell pressure instruments with Barton model 764 transmitters. It was proposed to revise the allowable values to bound the use of either Barton or Rosemount transmitters.

However, the values calculated (using the analytical limit of 2.0 psig) were unacceptably low from an operations standpoint. If the calculated allowable value of 1.70 psig (resulting in an actual instrument setting of 1.45 psig) were implemented, spurious trips during drywell inerting would likely occur. To solve this problem, a new allowable value was calculated using a smaller range Rosemount 1154 transmitter. The proposed allowable value for this transmitter type (1.92 psig) was developed using the 2.0 psig analytical limit and the criteria of Regulatory Guide 1.105. The methodology El-3 0622C 07/18/86

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! GeorgiaPower d

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ENCLOSURE 1 (Continued) 3 NRC DOCKET 50-366

. OPERATING LICENSE NPF-5

! EDWIN I. HATCH NUCLEAR PLANT UNIT 2 REQUEST TO REVISE SETPOINTS FOR CERTAIN 4

ANALOG TRANSMIIItR TRIP SYsitM INSTRUMENTS BASIS FOR CHANGE REQUEST used to determine the septoints was previously approved by the NRC in the

. safety evaluation included with Amendment 39 to the Hatch Unit 2 Technical

Specifications. The proposed allowable value is only applicable for Rosemount 1154DP4RJ and 1154GP4RJ model transmitters installed in the 4

drywell pressure transmitters' current locations.

3 The probabilities or consequences of analyzed accidents are not increased above those analyzed in the FSAR by this change, because the proposed j setpoint was calculated using NRC-approved methodology which preserves an appropriate margin to the analytical limit. No new modes of plant operation

will result from the proposed change. Thus, no new types of accidents are created. The proposed change does not reduce margins of safety, because appropriate methodology is used to preserve the required margins.

Proposed Change 4: This change proposes to lower the allowable value for the RHR-LPCI and core spray low reactor pressure permissives which open the l injection valves from 422 psig to 390 psig. This change is required to allow for increased flexibility in the use of Rosemount transmitters for this function.

l The subject instruments provide RHR-LPCI and core spray injection valve i permissives on decreasing reactor pressure. An upper limit of 500 psig is also provided for this injection setpoint. This upper limit is established ,

, to prevent possible overpressurization of these low-pressure ECCS systems. "

With the present low pressure injection allowable value of 422 psig, it is necessary to calibrate these instruments at 12-month intervals to ensure that instrument drift does not compromise the 500-psig upper bound. (Normal

ATTS calibration frequency is 18 months.) In order to allow the use of the normal 18-month calibration interval, as well as the use of either Barton or Rosemount transmitters for this function, it is necessary to lower the low-pressure permissive allowable value from 422 psig to 390 psig. In order to justify this change, it is necessary to provide equivalent relaxation to the corresponding analytical limit. In a report entitled " Evaluation of LPCI and Core Spray System Pressure Permissive - Plant Hatch Units 1 and 2" (Appendix to this enclosure), General Electric provided justification for relaxing the analytical limit for the RHR-LPCI and core spray injection

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GeorgiaPower d '

ENCLOSURE 1 (Continued)

NRC DOCKET 50-366 OPERATING LICENSE NPF-5 '

EDWIN I. HATCH NUCLEAR PLANT UNIT 2

. REQUEST TO REVISE SETPOINTS FOR CERTAIN ANALOG TRANSMITTER TRIP SYSTEM INSTR 0R NTS 4 BASIS FOR CHANGE REQUEST valve permissives from 425 psig to 365 psig. General Electric analyzed the proposed analytical limit for its effects on fuel thermal limits and LOCA limits and determined that the proposed ifmit is acceptable. This report is l provided as the Appendix to this enclosure.

In regard to the fuel thermal limits, the transients governing thcse limits occur at relatively high pressure. Since the LPCI and core spray cannot inject water into the reactor vessel until the reactor is depressurized, the fuel thermal limits are not impacted by the performance of the low-pressure ECCS systems. This conclusion is documented in the Appendix to this l 1 enclosure.

l l In regard to the LOCA limits, the core MAPLHGR limits are determined by l analyzing the postulated LOCAs to ensure compliance with 10 CFR 50. The i limiting scenarios for these analyses involve the operation of the low i l pressure ECCS. General Electric's evaluation shows that the lowering of the pressure permissive analytical limit to the proposed value is within the l plant design basis and safety analysis assumptions. This conclusion is documented in the Appendix to this enclosure.

The proposed allowable value of 390 psig, based upon the new analytical limit, was developed using the criteria of Regulatory Guide 1.105. The methodology used to determine the septoints was previously approved by the NRC in the safety avaluation included with Amendment 39 to the Hatch Unit 2 Technical Specifications.

The probabilities and consequences of analyzed accidents are not increased by the proposed change, because the lower pressure setpoint has been shown to be within the plant design basis and safety analysis assumptions. The proposed change does not result in the possibility of new accident types, because the design function of the equipment is preserved. Margins of safety are not reduced, because the lower limit has been shown to maintain compliance with the plant design basis and safety analysis assumptions.

El-5 06-22C 07/18/86 700;75

Georgialbwer d APPENDIX TO ENCLOSURE 1 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 REQUEST TO REVISE SETPOINTS FOR CERTAIN ANALOG TRANSMIIItR TRIP SYsItM INSTRUMENTS GENERAL ELECTRIC REPORT NUMBER MDE-263-1185 EVALUATION OF LPCI AND CORE SPRAY SYSTEM PRESSURE PERMISSIVE PLANT HATCH UNITf 1 AND 2 Note: This report is non-proprietary.

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