ML20135G510

Application for Amends to Licenses DPR-57 & NPF-5,adding 60 Scram Discharge Vol Vent & Drain Valve Closure Time Requirement to Tech Specs.Fee Paid

ML20135G510
Person / Time
Site:	Hatch
Issue date:	09/13/1985
From:	Beckham J GEORGIA POWER CO.
To:	Stolz J Office of Nuclear Reactor Regulation
Shared Package
ML20135G511	List: ML20135G510 ML20135G519
References
1659N, NED-85-370, TAC-53327, TAC-53328, NUDOCS 8509190328
Download: ML20135G510 (9)

Text

-

r 1 Georgia Power Company

. ,, 333 Ptedmont Avenue At ania, Georg a 30303 TekFene 404 526 7020 Ma !:rg Address' Post Ottce Fes 4545 Atyt3 Gec*g a 30302 b Georgia Power J. T. Beckham, Jr. tv wuvn awtsc setem V,ce Preset and Ge eral Manger Nuciear Operat.ons NED-85-370 1659N September 13, 1985 Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 Division of 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 TECHNICAL SPECIFICATIONS:

ADD SCRAM DISCHARGE VOLUME VENT AND DRAIN VALVE CLOSURE TIME REQUIREMENT 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.

Technical Specification amendments numbers 97 and 34 for Plant Hatch Units 1 and 2, respectively, added operability and surveillance requirements for the scram dischar system in accordance with NRC's Generic Safety Evaluation Report (SER)geon the BWR scram discharge system, dated December 1, 1980, which specified a 30 second closure time limit for the scram discharge volume (SDV) vent and drain valves. Prior to issuance of the above amendments, it was determined that the 30 second closure time could not be met for the Hatch Units without significant plant modifications. Af ter a commitment by Georgia Power to make the necessary plant modifications to meet the 30 second closure time, the above amendments were issued with a closure time requirement "to be provided in a subsequent amendment." These plant modifications have since been made. Concurrently, a more extensive

- analysis has been performed justifying a 60 second closure time limit.

J$

gga.

Accordingly, this submittal proposes incorporation of a 60 second closure time requirement, and provides supporting justification for this deviation o from the December 1,1980 SER. Additionall;, a typographical error in the g$

t same Technical Specification is corrected.

Nd Attachment 1 provides a detailed description of the proposed changes and f8 circumstances necessitating the change request.

f<

o-Attachment 2 details the basis for our determination that the pro, nosed

$$ changes do not constitute an unreviewed safety question.

a)a.a.

N " ^

_1 -

m ..o no

GeorgiaPowerd Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 September 13, 1985 Page Two Attachment 3 details the basis for our determination that the proposed changes do not involve significant hazards considerations.

Attachment 4 provides page change instructions for incorporating the proposed changes.

The proposed changed Technical Specification pages follow Attachment 4.

Payment of filing fee is enclosed.

Pursuant to the requirements 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.

In order to allow time for procedure revision and orderly incorporation '

into copies of the Technical Specifications, we request that the proposed amendments, once approved by the NRC, be issued with an effective date to be no later than 30 days from the date of issuance of the amendment.

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 best of his knowledge and belief the facts set forth in this letter are true.

GEORGIA POWER CO W ANY By: - =

. T. Beckham, Jr. '

Sworn to a.d subscribed be ore me his 13th day of September,1985.

Notary Pubhc. Georgia, SMe at large

( , ,j p My Commission bpires Sept 18,1967

/ hotary Public RES/mb Enclosures 4

xc: Mr. H. C. Nix, Jr.

Dr. J. N. Gt sce, (NRC-Region II)

Senior Resideni. Inspector, Plant Hatch Mr. J. L. Ledbetter nons

GeorgiaPower A ATTACHMENT 1 TO GPC LETTER NED-85-370 DISCUSSION OF PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS Georgia Power Company's (GPC) submittal of September 19, 1983, proposed Technical Specification changes to incorporate operability and surveillance requirements for the scram discharge volume (SDV) vent and drain valves, in accordance with NRC's SER dated December 1,1980. The changes proposed in that submittal included a 30 second closure time requirement for demonstrating operability of the subject valves. By letter of December 14, 1983, GPC stated that the 30 second closure time value was inappropriate for the Hatch units and proposed a 60 second closure time, along with supporting justification for this deviation from the subject SER. Attachment I to GPC's letter of December 22, 1983 provided a more extensive qualitative analysis of the effects of a 60 second closure time. This analysis was performed by our Architect / Engineer, and concluded that the longer closure time was acceptable. At NRC request, this analysis was provided to General .

Electric (GE), who had developed the 30 second closure time limit, for '

review. Our letter of April 23, 1984 provided the results of the GE

• review. GE provided qualitative bases addressing three areas: 1) hydrodynamic loads, 2) CRD leakage flow, and 3) high temperatures. GE further stated that more extensive analyses would be required to support GE concurrence with the 60 second closure time. Since full GE concurrence was not obtained, NRC requested from GPC, and was provided by letter of June 14, 1984, a schedule for implementation of modifications to meet the 30 second closure time requirement. NRC proceeded to issue, as amendments 94 and 31 respectively, changes to the Plant Hatch Units 1 and 2 Technical Specifications, reflecting the submittal of September 19, 1983, but without a specified closure time value. The Technical Specifications amended pages were issued with a statement that this value would be provided later.

The extent of plant modifications required to meet the 30 second closure time was unclear in June of 1984. For this reason, GE was asked by GPC to '

perform a more extensive analysis, addressing quantitatively the conclusions of the qualitative analyses- provided to NRC in GPC's letter of December 22, 1983. This GE report was provided as MDE 1184, Rev 1, " Relaxation of Scram Discharge Volume Vent and Drain Valve Closure Times", dated December 1984.

The GE report concludes that " extending the valve closure times from 30 seconds to 60 seconds meets applicable criteria under normal scram -

conditions for: filling the scram discharge volume; thermal effects; radiation; and hydrodynamic loads. This proposed change does not decrease the margin of safety in the SDV design, as defined in the new bases for the plant technical specification." i roons

GeorgiaIbwer d ATTACMENT 1 (Continued)

Accordingly, this letter proposes a closure time value of 60 seconds for both Hatch Units. It should be noted that subsequent plant modifications have resulted in the ability to meet the 30 second closure time for both units. However, there is very .little margin (as little as 0.05 seconds) between as-measured closure times and the 30 second limit. In order to allow a realistic margin and ensure consistent compliance with the closure time Technical Specification, the 60 second value is proposed, on the basis of the analysis noted above.

Additionally, correction of a typographical error is proposed. The word

": cram" was duplicated in Technical Specification 4.3.I.2.b.2 for Unit 1.

The proposed change removes the duplicatica.

I

'd 700TTS

T Georgia Power 1 ATTACHMENT 2 TO GPC LETTER NED-85-370 10 CFR 50.59 EVALUATION GPC's submittal dated December 22, 1983 provided a qualitative analysis supporting closure times of 60 seconds for the inboard valves and 120 9 seconds for the outboard valves. This submittal requests a closure time l hit of 60 seconds for both inboard and outboard valves, which is conservative with respect to the values analyzed in the above referenced submittal. Therefore, the information and conclusions of the previous qualitative analysis remain valid for this submittal. As explained in GPC's letter of April 23, 1984, GE was unable at the time to concur without more extensive anilysis. Since that time, GE has performed the necessary analysis which supports the 60 second closure time. This analysis, provided under GE report MDE 103 1184 Rev. 1 dated December 1984, considers the impacts on plant safety due to radioactive releases, increased temperatures, and hydrodynamic loads. Mass inventory calculations were performed to demonstrate that the SDV would not overfill. No additional radiological concerns are generated with the longer closure time since overfilling will not occur. Temperature increases in the SDV were evaluated. This evaluation showed that, with the 60 second closure time, temperature and pressure in the SDV were sufficiently low to preclude flashing and associated concerns of steam collapse and chugging. The GE report supports the conclusion of our previous analysis, that extending the valve closure time will not adversely effect hydrodynamic loads. The report further states that, per GE's evaluation, the proposed 60 second closure time satisfies all 10 CFR 50.59 criteria.

Based on the above conclusions and additional arguments provided in previous submittals as referenced, the Plant Review Board and Safety Review Board have reviewed the attached proposed amendments to the Plant Hatch Unit I and Unit 2 Technical Specifications and have determined that implementation of the proposed amendments do not constitute an unreviewed safety question. No increases in the consequences or probabilities of analyzed accidents will result. The plant was designed and has operated since startup with no closure time limitation for the subject valves. The 60 second closure limit represents an additional constraint in the Technical Specifications. No new types of accidents are created since no new modes of operation are involved. The margin of safety as defined in the basis of the Technical Specifications is not reduced by this change since no closure time limits were previously enforced.

mm

Georgia Power d ATTACHMENT 2 (Continued)

Additionally, this submittal proposes to correct a typographical error contained in Unit 1 Technical Specification 4.3.1.2.b.2. The superfluous word " scram" would be deleted.

The Plant Review Board and Safety Review Board have reviewed this additional proposed change and have determined that it does not involve an unreviewed safety question. Accident probabilities and consequences are not affected. No new accident types are created. Margins of safety are unaffected. This is a purely editorial change.

700775

C Georgia Power A ATTACHMENT 3 TO GPC LETTER NED-85-370 10 CFR 50.92 EVALUATION Pursuant to 10 CFR 50.92, Georgia Power Company has evaluated the attached proposed amendments for Plant Hatch Units 1 and 2 and has determined that their adoption would not involve a significant hazard.

- The basis for this determination is as follows:

Proposed Change 1 Provide a 60 second closure time limit for demonstrating operability of the SDV vent and drain valves.

Basis The proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated since the proposed change is an additional requirement not presently included in the Technical Specifications.

The proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated. since no new modes of plant operation are involved.

The proposed change will not involve a significant reduction in a margin of safety. The proposed change is an additional requirement which should increase the margin of safety.

The proposed change is an additional requirement not presently contained in the Technical Specifications. Therefore, the proposed change is consistent with example (ii) of " Amendments that are considered not likely to involve significant hazards considerations" as described in the Federal Register, Vol. 48, No. 67, Page 14870.

.-l M2n$

E 1 GeorgiaPower d ATTACHMENT 3 (Continued)

Proposed Change 2 Correct a typographical _ error in Unit 1 Technical Specification 4.3.I.2.b.2 by removing the word " scram" which appears twice.

Basis The proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated since the proposed change is a purely editorial correction.

The proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated since plant operation is unaffected by this editorial change.

The proposed change will not involve a significant reduction in a margin of safety. The proposed change is strictly editorial in nature.

The proposed change is an editorial correction of an error in the Technical Specifications. Therefore, the proposed change is consistent with example (1) of " Amendments that are considered not likely to involve significant hazards considerations" as described in the Federal Register, Vol. 48, No. 67, Page 14870.' ,

4

'* .. g i

GeorgiaPowerI ATTACFMENT~4 i TO GPC LETTER NED-85-370 -

INCORPORATION INSTRUCTIONS ,

The proposed change to Technical Specifications (Appendix A to Operating i Licenses DPR-57 and NPF-5 would be incorporated as follows:

Remove Page Insert Page-(Plant Hatch Unit 1) 3.3-7a 3.3-7a i*

(Plant Hatch Unit 2) 3/4 1-21 3/4 1-21 <

s F

n i

[

3 i

f e

1 i

}

i-i

.f i

4 b

700?75 4