ML020520163

Request to Revise Technical Specifications Regarding Post Accident Sampling

ML020520163
Person / Time
Site:	Farley
Issue date:	01/24/2002
From:	Dennis Morey Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NEL-02-0022
Download: ML020520163 (11)

Text

Dave Morey Southern Nuclear Vice President Operating Company, Inc.

Farley Project Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.5131 SOUTHERN January 24, 2002 COMPANY Energy to Serve Your World" Docket Nos.

50-348 10 CFR 50.90 50-364 NEL-02-0022 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Joseph M. Farley Nuclear Plant Request to Revise Technical Specifications Post Accident Sampling Ladies and Gentlemen:

In accordance with the requirements of 10 CFR 50.90, Southern Nuclear Operating Company (SNC) proposes to revise the Farley Nuclear Plant (FNP) Unit 1 and Unit 2 Technical Specifications (TS). The proposed amendment would delete TS 5.5.3, "Post Accident Sampling," to eliminate the requirements for a post accident sampling system. The proposed changes are consistent with the NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-366, "Elimination of Requirements for a Post Accident Sampling System (PASS)." The availability of this TS improvement was announced in the Federal Register on October 31, 2000, as part of the Consolidated Line Item Improvement Process (CLIIP). provides the basis for the proposed changes. This includes a description of the proposed changes, the requested confirmation of applicability, plant-specific verifications and the no significant hazards determination. Enclosure 2 provides the existing TS and Bases pages marked-up to show the proposed changes, and Enclosure 3 provides clean-typed copies of the affected TS and Bases pages.

SNC requests approval of the proposed changes by July 1, 2002 with the amendment being implemented by December 31, 2002. The requested approval date was administratively selected to allow for NRC review, and the implementation date was selected to allow for revision of the necessary procedures to reflect elimination of the PASS.

This letter contains three commitments as discussed in Enclosure 1. These commitments are 1) establishment of contingency plans, 2) ensuring the capability for classifying fuel damage events, and 3) ensuring the capability to monitor radioactive iodines.

oý 0 0

U. S. Nuclear Regulatory Commission Page 2 A copy of the proposed changes has been sent to Dr. D. E. Williamson, the Alabama State Designee, in accordance with 10 CFR 50.91 (b)(1).

Mr. D. N. Morey states that he is a Vice President of Southern Nuclear Operating Company and is authorized to execute this oath on behalf of Southern Nuclear Operating Company and that, to the best of his knowledge and belief, the facts set forth in this letter are true.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY Dave Morey Sworn to and subscribed before me this 24 day of 2002 Notary Public My Commission Expires:

/ I

&S kah/was: PASS NRC letter.doc : Basis for Proposed Change : Marked-up TS and Bases Pages : Clean-typed TS and Bases Pages

U. S. Nuclear Regulatory Commission Page 3 cc:

Southern Nuclear Operating Company Mr. L. M. Stinson, General Manager - Farley U. S. Nuclear Regulatory Commission. Washington. D. C.

Mr. F. Rinaldi, Licensing Project Manager - Farley U. S. Nuclear Regulatory Commission, Region II Mr. L. A. Reyes, Regional Administrator Mr. T. P. Johnson, Senior Resident Inspector - Farley Alabama Department of Public Health Dr. D. E. Williamson, State Health Officer Joseph M. Farley Nuclear Plant Request to Revise Technical Specifications Post Accident Sampling Basis for Proposed Change Proposed Change The proposed License amendment deletes the program requirements of the Joseph M. Farley Nuclear Plant (FNP) Units 1 and 2 Technical Specifications (TS) 5.5.3, "Post Accident Sampling." In addition, for the sake of completeness, the Bases for LCO 3.3.3, Post Accident Monitoring Instrumentation, Required Action D. 1 are revised to remove a reference to the Post Accident Sampling System (PASS).

The proposed changes are consistent with NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-366. The availability of this TS improvement was announced in the Federal Register, Vol. 65, No. 211, on October 31, 2000, (Pages 65018-65024) as part of the consolidated line item improvement process (CLIIP).

Applicability of Published Safety Evaluation Southern Nuclear Operating Company (SNC) has reviewed the safety evaluation published on October 31, 2000 as part of the CLI1P. This verification included a review of the NRC staff's evaluation as well as the information provided to support TSTF-366 (i.e., WCAP-14986-A, Revision 2, "Post Accident Sampling System Requirements: A Technical Basis," submitted October 26, 1998, as supplemented by letters dated April 28, 1999, April 10, 2000 and May 22, 2000). SNC has concluded that the justifications presented in TSTF-366 and the safety evaluation prepared by the NRC staff are applicable to FNP Units 1 and 2 and justify this amendment for the incorporation of the changes to the FNP TS.

Optional Changes and Variations SNC is not proposing any variations or deviations from the TS changes described in TSTF-366 or the NRC staff's model safety evaluation published on October 31, 2000.

The elimination of the PASS results in changes to the discussion in the Bases section for TS 3.3.3, "Post Accident Monitoring (PAM) Instrumentation." The current Bases mention the capability of the PASS as a backup for monitoring hydrogen concentration within containment in the event that two hydrogen monitor channels are inoperable. Proposed changes to the Bases for TS 3.3.3 are contained in Enclosure

2.

No Sianificant Hazards Determination SNC has reviewed the no significant hazards consideration (NSHC) determination published on October 31, 2000 as part of the CLIIP. SNC has concluded that the NSHC determination presented in the Federal Register, on October 31, 2000 (65 FR 65018) is applicable to FNP Units 1 and 2 and the NSHC determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.9 1(a).

Verification and Commitments As discussed in the notice of availability published in the Federal Register, Vol. 65, No. 211 on October 31, 2000 for this TS improvement, the following plant-specific verifications were performed:

El-1 Joseph M. Farley Nuclear Plant Request to Revise Technical Specifications Post Accident Sampling Basis for Proposed Change

1. SNC will develop contingency plans for obtaining and analyzing highly radioactive samples of reactor coolant, containment sump, and containment atmosphere. The contingency plans will be contained in plant procedures and implemented with the implementation of the license amendment.

Establishment of contingency plans is considered a regulatory commitment.

2. The capability for classifying fuel damage events at the Alert level threshold has been established for FNP at radioactivity levels of 300 RCi/gram dose equivalent iodine. This capability will be described in plant procedures and implemented with the implementation of the license amendment. The capability for classifying fuel damage events is considered a regulatory commitment.

3.

SNC has established the capability to monitor radioactive iodines that have been released to offsite environs. This capability is described in our emergency plan implementing procedures. The capability to monitor radioactive iodines is considered a regulatory commitment.

Environmental Evaluation SNC has reviewed the environmental evaluation included in the model safety evaluation published on October 31, 2000 as part of the CLIIP. SNC has concluded that the staff's findings presented in that evaluation are applicable to FNP Units 1 and 2 and the evaluation is hereby incorporated by reference for this application.

El-2 Joseph M. Farley Nuclear Plant Request to Revise Technical Specifications Post Accident Sampling Marked-up TS and Bases Pares

Programs and Manuals 5.5 5.5 Programs and Manuals Primary Coolant Sources Outside Containment This program provides controls to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to levels as low as practicable. The systems include recirculation portions of the Containment Spray, Safety Injection, and Chemical and Volume Control Systems, the Waste Gas System, the Reactor Coolant Sampling System, the Residual Heat Removal System, and the Containment Atmosphere Sampling System. The program shall include the following:

a.

Preventive maintenance and periodic visual inspection requirements; and

b.

Integrated leak test requirements for each system with the exception of the waste gas system and the containment atmosphere sampling system which are "snoop" tested at refueling cycle intervals or less.

P st Accie ent Sa ing This p gram p vides ntrols th ensure t capabili to obtai and anal e

reac r coola, radioa ive gase and parti lates in ant gase us efflue s, an contain ent atm sphere s pies un r accide conditio s. The pr gram s

11 inclu the foidwing:

a.

T ining of ersonne

b.

Proced es for sa piing an analysis; nd

c.

Prov ions for aintenan of sam ng and a alysis eq pment.

Radioactive Effluent Controls Program This program conforms to 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable. The program shall be contained in the ODCM, shall be implemented by procedures, and shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:

a.

Limitations on the functional capability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM; (continued)

Farley Units 1 and 2 5.5-2 Amendment No. 146 (Unit 1)

Amendment No. 137 (Unit 2) 5.5.2 5.5.3 Not Used 5.5.4

PAM Instrumentation B 3.3.3 BASES ACTIONS (continued) other core damage assessment capabilities available B._1 Condition B applies when the Required Action and associated Completion Time for Condition A are not met. This Required Action specifies initiation of actions in Specification 5.6.8, which requires a written report to be submitted to the NRC. This report discusses the results of the root cause evaluation of the inoperability, if performed, and identifies proposed restorative actions. This action is appropriate in lieu of a shutdown requirement since alternative actions are identified before loss of functional capability, and given the likelihood of unit conditions that would require information provided by this instrumentation.

C.1 Condition C applies when one or more Functions have two inoperable required channels (i.e., two channels inoperable in the same Function). Required Action C.1 requires restoring one channel in the Function(s) to OPERABLE status within 7 days. The Completion Time of 7 days is based on the relatively low probability of an event requiring PAM instrument operation and the availability of alternate means to obtain the required information. Continuous operation with two required channels inoperable in a Function is not acceptable because the alternate indications may not fully meet all performance qualification requirements applied to the PAM instrumentation.

Therefore, requiring restoration of one inoperable channel of the Function limits the risk that the PAM Function will be in a degraded condition should an accident occur.

Condition C is modified by a Note that excludes hydrogen monitor channels.

D.. 1 Condition D applies when two hydrogen monitor channels are inoperable. Required Action D.1 requires restoring one hydrogen monitor channel to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable based on the bakp rapability of tho Poetccdt Sampling Systemn to-m.onito-r. tho hydro@Go cnc,---ntrntion fr o.... uatio* of cors d.a.ago and to provide information for operator decisions. Also, it is unlikely that a LOCA (which would cause core damage) would occur during this time.

(continued)

Farley Units I and 2 Revision 0 B 3.3.3-13 Joseph M. Farley Nuclear Plant Request to Revise Technical Specifications Post Accident Sampling Clean-typed TS and Bases Paees

Programs and Manuals 5.5 5.5 Programs and Manuals Primary Coolant Sources Outside Containment This program provides controls to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to levels as low as practicable. The systems include recirculation portions of the Containment Spray, Safety Injection, and Chemical and Volume Control Systems, the Waste Gas System, the Reactor Coolant Sampling System, the Residual Heat Removal System, and the Containment Atmosphere Sampling System. The program shall include the following:

a.

Preventive maintenance and periodic visual inspection requirements; and

b.

Integrated leak test requirements for each system with the exception of the waste gas system and the containment atmosphere sampling system which are "snoop" tested at refueling cycle intervals or less.

Not Used Radioactive Effluent Controls Program This program conforms to 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable. The program shall be contained in the ODCM, shall be implemented by procedures, and shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:

a.

Limitations on the functional capability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM; (continued)

Farley Units 1 and 2 5.5-2 Amendment No.

Amendment No.

5.5.2 5.5.3 5.5.4 (Unit 1)

(Unit 2)

PAM Instrumentation B 3.3.3 BASES ACTIONS B.1 (continued)

Condition B applies when the Required Action and associated Completion Time for Condition A are not met. This Required Action specifies initiation of actions in Specification 5.6.8, which requires a written report to be submitted to the NRC. This report discusses the results of the root cause evaluation of the inoperability, if performed, and identifies proposed restorative actions. This action is appropriate in lieu of a shutdown requirement since alternative actions are identified before loss of functional capability, and given the likelihood of unit conditions that would require information provided by this instrumentation.

C.1 Condition C applies when one or more Functions have two inoperable required channels (i.e., two channels inoperable in the same Function). Required Action C.1 requires restoring one channel in the Function(s) to OPERABLE status within 7 days. The Completion Time of 7 days is based on the relatively low probability of an event requiring PAM instrument operation and the availability of alternate means to obtain the required information. Continuous operation with two required channels inoperable in a Function is not acceptable because the alternate indications may not fully meet all performance qualification requirements applied to the PAM instrumentation.

Therefore, requiring restoration of one inoperable channel of the Function limits the risk that the PAM Function will be in a degraded condition should an accident occur.

Condition C is modified by a Note that excludes hydrogen monitor channels.

D.A Condition D applies when two hydrogen monitor channels are inoperable. Required Action D.1 requires restoring one hydrogen monitor channel to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable based on other core damage assessment capabilities available to provide information for operator decisions. Also, it is unlikely that a LOCA (which would cause core damage) would occur during this time.

(continued)

Farley Units 1 and 2 B 3.3.3-13 Revision