L-99-013, Application for Amends to Licenses NPF-2 & NPF-8.Amends Would Increase Dei Limit from 0.15 to 0.3 Uci/Gram IAW 10CFR50.90.Marked-up & Revised Current TS Encl

Application for Amends to Licenses NPF-2 & NPF-8.Amends Would Increase Dei Limit from 0.15 to 0.3 Uci/Gram IAW 10CFR50.90.Marked-up & Revised Current TS Encl

ML20205G846
Person / Time
Site:	Farley
Issue date:	04/02/1999
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20205G852	List: L-99-013, Application for Amends to Licenses NPF-2 & NPF-8.Amends Would Increase Dei Limit from 0.15 to 0.3 Uci/Gram IAW 10CFR50.90.Marked-up & Revised Current TS Encl ML20205G857
References
NEL-99-0131, NEL-99-131, NUDOCS 9904070393
Download: ML20205G846 (11)

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Dave Moray Southtrn Nuclear E 5

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^pril 2.1999 SOUTHERN k L COMPANY

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Drop to Wriv hur GM Docket Nos.: 50-348 _ NEL-99-0131 "5E364 1 e

U. S. Nuclear Regulatory Commission  !

ATTN: Document Control Desk -

Washington, D. C. 20555-0001 Joseph M. Failey Nuclear Plant Reactor Coolant Svstgmjpecific Activity Technical Specifications Change Recmesi Ladies and Gentlemen:

!!y NRC letter dated October 29,1997, Amendment Nos.132 and 124 were issued for Farley Nuclear Plant Units I and 2, respectively. These amendments reduced the dose equivalent iodine (DEI) limits from 0.3 pCune/ gram to 0.15 pCurie/ gram. That adjustment in the DEI limit was needed due to the calculated steam line break (SLB) steam generator tube leakage being in excess of tlE leak rate assumption imposed as a result of using steam generator alternate repair criteria (ARC). The increased tube leakage was calculated using the results of Unit I test data from the spring 1997 outage and adjusting for temperature considerations. Additional detail may be found in the Southern Nuclear Operating Company (SNC) transmittal letter (Woodard to NRC) for the DEI amendment request dated September 17,1997. The projected EOC leakage in the event of a steamline break is significantly less than the current 23.8 gpm limit. Consequently, margin exists ,

that would allow raising the DEI limits. Therefore, SNC is submitting this amendment request to increase the DEI limit from 0.15 to 0.3 pCurie/ gram in accordance with 10 CFR 50 90.

Enclosure i provides the basis of the proposed Technical Specifications change. Enclosure 2 provides the required significant hazards evaluation, wherein SNC detennined that the proposed change does not invoive a significant hazards consideration as dermed by 10 CFR 50.92. Enclosure 3 provides the revised Current Technical Specification pages. Enclosure 4 provides the revised improved Technical Specification pages.

SNC has performed an assessment of the impact of the proposed revision to the Technical Specifications on the environment and has determined that there is no impact on the environment.

The proposed revision does not affect the types of any radiological or non-radiological ellluents that may be released ofTsite. Plant releases during nonnal operation may increase slightly. Ilowever, releases will continue to be maintained within regulatory limits. In addition, ofTsite dose from accident conditions also will remain within regulatory limits. No significant increase in individual or cumulative occupational radiation exposures will result from this revision. Finally, the revision does not involve the use of any resources not previously considered in the Final Environmental Statement related to the operation of Farley Nuclear Plant.

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Page 2 U. S. Nuclear Regulatory Conunission

. A copy of these proposed changes is being sent to Dr. D. E. Williamson, the Alabama State

~ Designee, in accordance with 10 CFR 50 91(b)(l)

Unit i DEI has increased due to fuel pin leakage. Since additional fuel leakage could cause the current DEI limit to be exceeded later in this cycle, approval of this Technical Specification change is requested on an expedited basis. For consistency, the Unit 2 limit is proposed to be changed to match Unit I The current calculated projected end of cycle SLil steam generator tube leakage value -

has sufficient margin to accept this proposed change. The DEI limits will change to 0.5 pCurie/ gram upon implementation of the Tecimical Specifications amendment request associated with the upcoming steam generators replacements. If you have any questions, please advise.

'l Respectfully submitted, ]

SOUTilERN NUCLEAR OPERATING COMPANY i

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Dave Morey b to and subscribed before me Il 's _A. day of _k Nlt 999 f

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My Commission Expires: HY COMMtS$10N EXP!RES M.E 10. 2Xe EWC/maf:1-SDEl. DOC

Enclosures:

1. - Basis for Proposed Technical Specifications Change  !

2. Significant IIazards Evaluation j

3. Current Technical Specifications Pages

4. Improved Technical Specifications Pages L

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.U. S1 Nuclear Regulatory Commission j 1

cc Southern Nuclear Operatinn Compaiiv Mr. L: M. Stinson, General Manager - Farley i U - S. Nuclear Reculatory Commission: Washincton. D C.

Mr.1; 1.; Zinunerman, Licensing Project Manager - Farley U. S.' Nuclear Regulatory Commission. Recion 11.

Mr. L. A. Reyes, Regional Administrator -

Mr. T. P. Johnson, Senior Resident inspector - Farley 1

Alabama Department of Public Health j

. Dr. D. E Williamson, State Health Omccr i I

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. Enclosure 1 Farley Nuclear Plant Reactor Coolant System Specific Activity Limit Basis for Proposed Technical Specifications Change l

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Farley Nuclear Plant Reactor Coolant System Specific Activity Limit Basis for Proposed Technical Specifications Change l l

Introduction l Implementation of the voltage-based repair criteria for Westinghouse steam generators affected by outside diameter stress corrosion cracking requires the implementation of a primary-to-secondary leakage limit in i the event of a steam line break outside containment. By limiting the primary-to-secondary leakage, the radiological consequences of a postulated accident will not exceed the guideline values of 10 CFR 100.

He quantity of primary-to-secondary leakage that is acceptable in the event of a postulated accident is dependent on the allowable activity in the primary coolant. )

Description of the Amendment Reauest ,

l The proposed amendment will modify Technical Specification 3/4.4.9, " Specific Activity," and the '

associated Bases to increase the limit associated with dose equivalent iodine-131. The steady-state dose equivalent iodine-131 limit will increase to 0.3 pCuric/ gram. The transient limit for 80% to 100% power  ;

provided by Technical Specification Figure 3.4-1 will increase to 18 pCurie/ gram with a corresponding l increase in the 0% to 80% power limits.

l Basis By letter dated June 4,1992, Southern Nuclear submitted an assessment of the radiological dose consequences of a main steam line break. That calculation, based on a dose equivalent iodine-131 limit of 1.0 Curie / gram for steady-state with a corresponding transient limit, concluded that the leak rate in the faulted steam generator should be limited to 5.7 gpm.

By letter dated April 5,1994, the NRC Staffissued Amendment No.106 to the Farley Unit 1 Technical Specifications. His amendment reduced the dose equivalent iodine-131 limit to 0.25 Curie / gram for steady-state with a corresponding reduction in the transient limit. This change resulted in a leakage limit of 4 x 5.7 gpm or 22.8 gpm.

I By letter dated September 28,1995, the NRC Staffissued Amendment No. I17 for the Farley Unit 1 Technical Specifications. This amendment increased the dose equivalent iodine-131 limit to 0.5 Curie / gram for steady-state with a corresponding increase in the transient limit. This change resulted in a leakage limit of 2 x 5.7 gpm or 11.4 gpm. The NRC Safety Evaluation included a description of ,

confirmatory calculations performed by the NRC Staff that " concluded that a leak rate of 11.4 gpm is an acceptable limit of the maxunum primary to secondary leakage initiated by the steam line break accident."

By letter dated May 19,1997, the NRC Staffissued Amendment No.128 for the Farley Unit 1 Tecimical Specifications. His amendment reduced the dose equivalent iodine-131 limit to 0.3 Curie / gram for steady-state with a corresponding decrease in the transient limit. His change resulted in a leakage limit of 3.333 x 5.7 gpm or 19 gpm. Subsequent to this amendment, it was discovered that the steam line break leakage limit and steam line break leakage projections had not consistently accounted for the density of water at various temperatures. This finding resulted in a reduction of the steam line break leakage limit to I a value that is 71% of the 19 gpm value calculated above, or 13.5 gpm.

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9 Enclosure i . _ _

Page 2 Basis for Proposed Technical Specification Change Reduction in Dose Equivalent Iodine-131 Limits -

By letter dated October 29,1997, the NRC Staffissued Amendment No.132 for the Farley Unit i Technical Specifications. This amendment reduced the dose equivalent iodine-131 limit to 0.15 Curie / gram for steady-state with a corresponding reduction in the transient limit of 9 Curie / gram.. This change resulted in a leakage limit of 23.8 gpm.

Similar Technical' Specifications changes have been approved for Farley Unit 2.

Unit i DO his increased due to fuel pin leakage, requiring recovery of operating margin for DEI. For .

mancnm rae Unit 2 DEI limit is being changed to match Unit 1. 'Ihe current projected end of cycle SLB ,

wakAp is 8.2 gpm for Unit I and 2.0 gpm for Unit 2. These values are well below the limit of 23.8 gpm and demonstrate that existing margin can be recovered without impacting offsite dose analysis. 'This proposed change will increase DEI to a value of 0.3 Curie / gram and reduce the ARC SG SLB leakage limit to 11.8 gpm. Calculated offsite dose will remain within regulatory limits at 29.56 Rem at the low

_ population zone boundary as a result of this proposed change. The DEI limits will change to 0.5 pCurie/ gram upon implementation of the Technical Specifications amendment request associated with the upcoming steam generators replacements.

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. Enclosure 2 Faricy Nuclear Plant Reactor Coolant System Specific Activity thnit Technical Specifications Change Significant Hazards Evaluation i

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Farley Nuclear Plant Reactor Coolant System Specific Activity Limit

. Technical Specifications Change Significant flazards Evaluation Introduction

' Implementation of the voltage-based repair criteria for Westinghouse steam generators affected by outside diameter stress corrosion cracking requires the implementation of a primary-to-secondary leakage limit in the event of a steam line break outside containment. . By limiting the primary-to-secondary leakage, the radiological consequences of a postulated ' accident will not exceed the guideline value of 10 CFR 100.

The quantity of primary-to-secondary leakage that is acceptable in the event of a postuinted accident is dependent on the allowable activity in the primary coolant.

- i Description of the Amendment Reauest l il

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~ As required _by 10 CFR 50.91(a)(1), this analysis is provided to demonstrate that a proposed amendment to increase the dose equivalent iodine limits for Farley Units I and 2 represents no significant hazards. In ~  !

accordance with 10_CFR 50.92(c), implementation of the proposed license amendment was analyzed using the following standards and found not to: 1) involve a significant increase in the probability or consequences for an accident previously evaluated; 2) create the possibility of a new or different kind of j accident from any accident previously evaluated; or 3) involve a significant reduction in a margin of safety. ,

- He proposed amendment will modify Technical Specification 3/4.4.9, " Specific Activity," and the l associated Bases to increase the limit associated with dose equivalent iodine-131. The steady-state dose .

equivalent iodine-131 limit will be increased to 0.3 Curie / gram. The transient limit for 80% to 100%

power provided by Technical Specification Figure 3.4 1 will be increased to 18 Curie / gram. Forless than 80% power, the transient limits will be increased by 9 Curic/ gram for each power level. This change will result in a density compensated leakage limit of i 1.8 gpm for the affected SG. Both units end of cycle MSLB event estimated leakage rate is below this limit.. The calculation of these limits is consistent with that submitted originally by Southem Nuclear Operating Company letter dated June 4,1992 and subsequently discussed in safety evaluations issued by the NRC Staffin letters dated April 5,1994, September 28,1995, May 19,1997, and October 29,1997.

He following evaluation applies to the Improved Technical Specifications (ITS) submittal as wHl as Current Technical Specifications. In addition to the changes associated with the DEI change some editorial j

. changes have been made to the ITS pages.

Evaluation i ne proposed Technical Specifications change will result in a dose equivalent iodine-131 limit of 0.3

Curie / gram for steady-state and a corresponding increase in the transient limit. The transient limit will be 18 Curie / gram above 80% power with limits as shown on Figure 3.4 1 below 80% power.

Analysis Conformance of the proposed amendment to the standards for detennining that it involves no significant

hazards as defined in 10 CFR 50.92 is shown by the following.

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- Reducti'on in Dose Equivalent Iodine-131 Limits

l. Operation of Farley Units I and 2 in accordance with the proposed license amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The increase in the dose equivalent iodine limits, both steady-state and transient, will not increase the probability of any accident evaluated since no physical changes to the plant are being 'made. The  ;

consequences of any accident previously evaluated will not be significantly increased since the doses remain a small fraction of the regulatory limit.

2. The proposed license amendment does not create the possibility of a new or different kind of 4 accident from any accident previously evaluated. -

The increase in the dose equivalent iodine limits, both steady-state and transient, will not create the possibility of a new or different kind of accident from any accident previously evaluated since no physical j changes to the plant are being made. He accidents of concem continue to be those that have previously been analyzed. ,

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3. ~ The proposed license amendment does not involve a significant reduction in a margin of safety.

He calculated potential radiological consequences from the main steam line break accident (the bounding event) remain within the regulatory exposure guidelines and have not changed significantly. Increase of the dose equivalent iodine limit along with a corresponding decrease of allowable steam line break pnmary-to- )

secondary steam generator leakage provides a compensating offsite dose effect. Although the calculated dose increases slightly, the dose remains within a small fraction of the regulatory limit (30.0 REM at the LPZ boundary). Consequently, there is no significant reduction in any margin of safety.

Conclusion Based on the preceding analysis, it is concluded that operation of Farley Units I and 2 following the increase in the dose equivalent iodine-131 limits in accordance with the proposed amendment does not involve a significant increase in the probability or consequence of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or significantly reduce any margins of safety. Therefore, the license amendment does not involve any i significant hazards as defined in 10 CFR 50.92.

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Enclosure 3 Farley Nuclear Plant Reactor Coolant System Specific Activity Technical Specifications Change Request Current Technical Specification Pages l

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1 Pen and Ink Mark-ups For Current Technical Specifications

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