HL-3048, Application for Amend to License DPR-57,revising TS Re Removal of Primary Containment Isolation Valves E11-F022 & E11-F023

Application for Amend to License DPR-57,revising TS Re Removal of Primary Containment Isolation Valves E11-F022 & E11-F023

ML20126E425
Person / Time
Site:	Hatch
Issue date:	12/21/1992
From:	Beckham J GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20126E428	List: HL-3048, Application for Amend to License DPR-57,revising TS Re Removal of Primary Containment Isolation Valves E11-F022 & E11-F023 ML20126E437
References
HL-3048, NUDOCS 9212290136
Download: ML20126E425 (12)

Text

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HL-3048 004466 ,

i December 21, 1992 U.S. Nuclear Regulatory Commission AllN: Document Control Desk Washington, D.C. 20555 PLANT HATCH - UNIT 1 liRC DOCKET 50-321 OPERATING LICENSE DPR-57 REQUEST TO REVISE TECHNICAL SPEClflCATIONS REMOVAL OF PRIMARY CONTAINMLNT ISOLATION VALVES

[11-f022 AND Ell-F023 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 Unit 1 Technical Specifications (TS), Appendix A to Operating License DPR-57.

The proposed amendment deletes the Primary Containment Isolation Valves (PCIVs) associated with the Residual Heat Removal (RHR) Head Spray Mode, Ell-f022 and Ell-f023, from Table 3.7-), " Primary Containment Isolation Valves Which Receive a Primary Containment isolation Signal"; Table 4.2-1,

" Check, Functional Test, and Calibration Minimum frequency for Instrumentation Which Initiates Reactor Vessel and Primary Containment isolation"; and Table 3.7-4, " Primary Containment Testable Isolation Valves". In addition, Table 3.7-3, " Testable Penetrations with Testable Bellows", will be revised to identify Penetration X-17 as a spare. The testable bellows for Penetration X-17 will not be removed and surveillance testing of the bellows will continue.

Enclosure i provides a detailed description of the proposed change and the reasons for the change request.

Enclosere 2 details the bases for GPC's determination that the proposed changes do not involve a significant hazards consideration.

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Georgialbwer d U.S. Nuclear Regulatory Commission December 21, 1992 Page Two l

Enclosure 3 provides page change instructions for incorporating the proposed changes. The proposed changed TS pages for Unit 1 follow Enclosure 3. The markup of the proposed changes is also included.

GPC requests that the proposed TS change be approved by the NRC no later than April 1, 1993 to facilitate removal of pCIVs Ell-f022 and 1 Ell-f023 during the Spring 1993 refueling outage currently scheduled to begin March 10, 1993.

in accordance with the requirements of 10 CfR 50.91, a copy of this letter and all applicable enclosures will be sent to the designated State official of the Environmental Protection Division of the _ Georgia Department of Natural Resources.

Mr. J. T. Beckham, Jr. states he is duly authorized to execute this oath on behalf of Georgia Power Company, and to the best of his knowledge and belief, the facts set forth in this letter are true.

GEORGIA POWER COMPANY i BY: Cc2 E T~ BE klam, Jr.

Sworn to and subscribed before me this qf[ day of M M 1992.

G2f&D?tod%J 7/ N6Iary PublTc

(/. m taw.srsumssunuo,nm SRM/cr ,

004466

Enclosures:

1. Basis for Change Request '

2. 10 CFR SO.92 Evaluation

3. Page Change Instructions cc: (See next page.)'

Geoigialbwer d U.S. Nuclear Regulatory Commission December 21, 1992 Page Three cc: Georaia P.qwer Company Mr. H. L. Sumner, General Manager - Nuclear P1 Ant NORMS V.S. Nucjgar Requlatory Commission. Washinoton. D.C.

Mr. K.-Jabbour, Licensing Project Manager - tlatch LLS. Nuclear lagitla1ory Commission. Reaion 11 Mr. S. D. Ebneter Regional Administrator Mr. L. D. Wert, Senior Resident inspector - Hatch State of Gentgla Mr. J. D. Tanner, Commissioner - Department of Natural- Resources

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uniu unuma ii l'.NCLOSURE1 PLANT llATCil- UNIT I NRC DOCKET 50 321 OPERATING LICENSE DPR-57 Rl! QUEST TO REVISE TECllNICAL SPECIFICATIONS REMOVAL, OF PRIMARY CONTAINMENT ISOLATION VALVES IILt-E0222NDJi1LB122 1)ASJS_EDEfilANDIUUiqwiSI

ENCLOSUREI PLANTliATCli UNIT 1 NRC DOCKET 50 321 OPERATING LICENSE DPR 57 REQUEST TO REVISE TECilNICAL SPECIFICATIONS REMOVAL OF PRIMARY CONTAINMENT ISOLATION VALVES IHLE022 AND El1 F022 DASl_S FOR CUANGE REOUESI ERDEOSEDIUANCdi This proposed amendment deletes the Primary Containment Isolation Valves (PCIVs)  ;

associated with the Residual lleat Removal (RilR) llead Spray Mode, El1.F022 and '

El1.F023, from Table 3.71, " Primary Containment Isolation Valves Which Receive a Primary Containment Isolation Signal;" Table 4.21, " Check, Functional Test, and Calibration Minimum Frequency for Instrumentation Which initiates Reactor Vessel and  :

Primary Containment isolation;" and Table 3.7-4, " Primary Containment Testable isolation Valves." In addition, Table 3.7-3, " Testable Penetrations with Testable llellows," will be revised to identify Penetration X 17 as a spare. The testable bellows for i Penetration X 17 will not be removed and surveillance testing of the bellows will-continue.

f IIASIS10REROE0hfiD_C11ANGE The purpose.of this change is to support physical removal of PCIVs El1 F022 and El1 F023 associated with the RIIR Head Spray Mode of operation. The function of the head spray mode of RilR is to spray water in the reactor vessel head area, while in the process of reactor shutdown, to provide a rapid reactor head cooldown. It is a low flow, low pressure system designed to supply water to the vessel' steam dome, through the_ head spray nozzle. Hatch Unit I was designed with this capability when it was anticipated that =

reactor vessel head conditions would be critical path for beginning a refueling outage.

However, operating experience has shown that the RHR licad Spray Mode is unnecessary for cooldown of the vessel head. The RHR Head Spray Mode does not perform any -

safetyirelated functions nor is it addressed in the Emergency Operating Procedures. :In1 >

addition, use of the head spray mode of RHR is not practical given the restrictive-cooldown' rates established in Technical Specification 3.6. - Additionally, removal.of the : '

RilR Head Spray piping spool piece delayed removal of the reactor head for refueling .

which resulted in unnecessary personnel exposure. Accordingly, the RHR Head Spray Mode was de-activated and the spool piece from the flanged coanection on the reactor -

vessel head to the flanged connection just downstream of valve El1 F019'was removed-on llatch Unit I during 1986,in accordance with 10 CFR 50.59.

IIL-3048 El-1 l-

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ENCLOSURE I (CONTINUED)

REQUEST TO REVISE TECilNICAL SPECIFICATIONS j REMOVAL OF PRihtARY CONTAINh1ENT ISOLATION VALVES l El1 F022 AND E11.F021 I! ASIS FOR CHANGE RiiQWi,SI ,

Although the RilR llead Spray Mode of operation was de activated and a spool piece removed, the associated PCIVs, El1.F022 and El1 F023, were not removed. .!

Accordingly, testing in accordance with 10 CFR 50, Appendix J has continued on the  :

PCIVs, resulting in unnecessary personnel exposure. Georgia Power Company currently ,

plans to physically remove PCIVs El1.F022 and El1 F023 during the upcoming Unit 1,

• Spring 1993 refueling outage. Following removal of the PCIVs, Penetration X 17.will be_ >

capped, thus preserving containment integrity.

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-Table 4.2.1 of the Technical Specifications lists the minimum frequency for checks,_-

ftmetional tests, and calibration for instrumentation that initiates a reactor vessel and primary containment isolation; PCIVs Ell F022 and Ell F023 receive isolation signals l from some of these instruments. The RilR licad Spray Mode it included at the end of ->

-Table 4.2.1 in the list of systems requiring a logic system functional test and simulated automatic actuation once per operating cycle in order to verify the ability to secure containment. It is proposed that this listing be deleted. i Technical Specification 4.7.A.2.f requires that the PCIVs listed in Table 3.71 and 3.7-4, which include PCIVs El1-F022 and El1 F023 associated with the R11R IIcad Spray .

Mode, be Type C tested in accordance with 10 CFR 50, Appendix J, during each major l tefueling outage or at intervals not to exceed two (2) years. It is proposed that these PCIVs be deleted from these tables.

As stated above, the RilR llead Spray Mode is no longer used on llatch Unit I and has been de-activated. Therefore, PCIVs Ell F022 and Ell F023 are not required. Since the valves are being physically removed, the surveillance requirements on the valves must be deleted. I L ,

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ENCLOSURE 2 PLANT liATCII- UNIT I l NRC DOCKET 50 321 OPERATING LICENSE DPR-57 REQUEST TO REVISE TECIINICAL SPECIFICATIONS REMOVAL OF PRIMARY CONTAINMENT ISOLATION VALVES ILil-F02: AND El1-F021 10 CFR 50.92 EVALUATION >

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1 ENCLOSURE 2 PLANT liATCll - UNIT 1  ;

NRC DOCKET 50-321  ;

OPERATINO LICENSE DPR-57  !

REQUEST TO REVISE TECIINICAL SPECIFICATIONS -

REMOVAL OF PRIMARY CONTAINMENT ISOLATION VALVES l El1.F022 AND El1 F021 ,

1p_Eg 50 92 EVA1.UATION ,

5 The Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license  ;

does not involve a significant hazards consideration if operation of the facility in .

accordance with the proposed amendment would not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or i (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or l

l (3) Involve a significant reduction in a margin of safety.

i Georgia Power Company has reviewed the proposed amendment and has determined its  ;

adoption would not involve a significant hazards consideration. The basis for this ,

determination is given below. ,

llasilf01hoposed No Significant llazards Consideration Determittalipm This change does not involve a significant hazards consideration for the following reasons:

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L 1. The proposed change to the TS does not involve a significant .mcrease m the-probability or consequences of an accident previously evaluated. The process lines associated with PCIVs El1-F022 and El1-F023 have been removed and therefore, the . 1 PCIVs are no longer needed. Accordingly, FCIVs El1-F022 and El1-F023 will be ~

1 removed and replaced by a welded cap which will serve as :he containment pressure boundary, subject to testing in accordance with 10 CFR 50, Appendix .T. Therefore,  !

containment integrity;will be presened in a. manner equal to, or better than,L that :

provided by PCIVs El1-F022 and El1-F023.

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ENCLOSURE 2 (CONTINUED)

REQUEST TO REVISE TECilNICAL SPECIFICATIONS RiihiOVAL OF PRIMARY CONTAINMENT ISOLATION VALVES Edi-E0222ND_E11 E023 liLCElL1032_l!VALUALLQN

2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated, incorporation of the proposed change does not create any new interfaces with safety related equipment, systems, or structures or any new system subject to failure or malfunction. 'Ihe proposed change does not c cate any new operating modes or accident initiating mechanisms.

3. The proposed change does not involve a significant reduction in a margin of safety because removal of PCIVs El1-F022 and El1 F023 does not affect any system that is required for normal operation, accident mitigation, or shutdown of Plant llatch.

Removal of PCIVs El1.F022 and El1-F023, and the installation of a welded cap on the penetration will provide an equivalent or better containment pressure boundary, without relying on the PCIVs to close on a containment isolation signal. Therefore, the proposed change will not involve a significant reduction in a margin of safety, i

llL-3048 E2-2

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-i ENCLOSURE 3 -1 PLANT liATCil- UNIT 1 NRC DOCKET 50 321-OPERATING LICENSE DPR-57 REQUEST TO REVISE TECIINICAL SPECIFICATIONS

. REMOVAL OF PRIMARY CONTAINMENT ISOLATION VALVES .

1111.F022 AND El1 F02] . l JMOR ClIANGE INSTRUCTIONS k

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ENCLOSURE 3 PLANTliATCli UNIT 1 NRC DOCKET 50 321 OPERATING LICENSE DPR 57 REQUEST TO REVISE TECIINICAL SPECIFICATIONS RiiMOVAL OF PRIMARY CONTAINMENT ISOLATION VALVES Pd).F022 AND El1 F021 i

PAGE CllANGE INST. RUCTIONS -

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