ML20082H486

Application for Amend to Licenses DPR-57 & NPF-5,changing Tech Specs Re Dose Equivalent Iodine in Reactor Coolant Sys. Original Amend Submitted on 830531.Class III License Amend Fee Encl

ML20082H486
Person / Time
Site:	Hatch
Issue date:	11/22/1983
From:	Head G GEORGIA POWER CO.
To:	Stolz J Office of Nuclear Reactor Regulation
Shared Package
ML20082H490	List: ML20082H486 ML20082H504
References
NED-83-571, TAC-53476, TAC-53477, NUDOCS 8312010179
Download: ML20082H486 (7)

Text

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@ ",7f n . November 22, 1983 NED-8b-571 p u . < 0. . vm Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operatirg Reactors Branch No. 4 Division of Licensirg U. S. Nuclear Regulatory Comnission Washington, D. C. 20555

!mC DOCKETS 50-321, 50-366 OPERATI!G LIGNSES DPR-57, NPF-5 EWIN I. HA'IQi NUCLEAR PLANP UNITS 1, 2 DOSE EQUIVALENT IODINE (DEI)

Gentlemen: 1 The purpose of this letter is to amend our subnittal of May 31, 1983 regarding proposed changes to the Plant Hatch Unit 1 Technical Specifications regarding Dose Equivalent Iodine (DEI) in reactor coolant.

In addition we are proposing a similar amendment to the reactor coolant I chemistry Specifications for Unit 2. For clarity, we are resubnitting the entire package of changes.

Plant Hatch Unit 1 was licensed with a DEI limit of 10 microcuries per gram of coolant on a site specific basis. The earlier submittal proposed to change this basis to a worst-case non-site specific limit of 0.2 microcuries per gram. %is change is clearly in the conservative direction. The change proposal also provided for minor administrative changes in the terminology in the specification and in the frequency of analyses. The intent of the submittal is to conform Unit 1 DEI Technical Specifications to the Standard Technical Specifications.

Subsequent review of the cubmittal by our staff has revealed that due to an oversight a paragraph was left out of our original submittal; an over-lapping of sampling requirements was included in our submittal; and, an inadvertant change of one of the analysis levels was also included. We are also revising the Unit 2 Technical Specifications by removing an overlap of existing sampling requirements to renove a source of potential confusion in determining which sampling frequency to use.

Attachment 1 to this letter is the justification required by 10 CFR 50.92 for the proposed changes to the Technical Specifications. Instructions for insertion (for Unit 1) and the proposed pages reflecting the amended Specifications are included in Attachment 2. Likewise, the instructions for insertion (for Unit 2) and the proposed changed pages are included in Attachment 3. Attachment 4 is the determination of amendment class.

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Georgial ower s_. k Director of Nuclear Reactor Regulation Operating Reactors Branch No. 4 U. S. Nuclear Regulatory Conmission Washington, D. C. 20555 November 22, 1983 Page 'Iwo The proposed changes have been reviewed and approved by the Plant Review Board and the Safety Review Board and have been determined not to constitute an unreviewed safety question. The probability of occurrence or the consequences of an accident or malfunction of equipnent important to safety would not be increased above those analyzed in the FSAR because the changes are in the conservative direction. No new modes of operation are involved or initiated by this proposal. The margin of safety will be increased due to the lower allowable levels of DEI in Unit 1 and the removal of a potential conflicting requirement in Unit 2.

Pursuant to the requirements of 10 CFR 50.92, J. L. Ledbetter of the Georgia Department of Natural Resources will be sent a copy of this letter and all applicable attachments.

G. F. Head states that he is Vice President of Georgia Power Conpany 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.

GEDIGIA POWER COMPANY By: 9./b -

G. F. Head Sworn to and subscribed before me this 22th day of November, 1983.

N -; 71m u.y NMary NW, hg3, g Notary Public My Commcica Exp:rcs Aug.26,1984 M3B -* v Enclosure xc: H. C. Nix, Jr.

Senior Resident Inspector J. P. O'Reilly, (NBC-Region II)

J. L. Ledbetter

ATTACINENT l' NBC DOCKETS 50-321, 50-366 OPERATI?G LICENSES DPR-57, NPF-5 EDf1N I. HA'ICH NUCLEAR PIRff UNITS 1, 2 DOSE EQUIVALENT IODINE (DEI) 10 CFR 50.92 JUSTIFICATION

1. Charge Unit 1 Technical Specifications from "10 microcuries per gram" to "0.2 microcuries per gram".

BASIS:

This change constitutes a more restrictive operational limitation to Unit 1. The resultant doses from a potential accident are less since the allowable initiating point for the transient is lower.

The change constitutes a major decrease in the effects of accidents previously analyzed, does not create any new accidents, and increases the margin of safety. Therefore, the results of this change are clearly within acceptance criteria, and this change is consistant with Itan (ii) of the " Examples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6,1983, issue of the Federal Register.

2. Change Unit 1 Technical Specifications from operation at " equilibrium values by a factor of more than 10" to "less than or egual to 4.0 microcuries per gram":

BASIS:

This change constitutes a more restrictive operational limitation to Unit 1. The resultant doses from a potential accident are less since the allowable initiating point for the transient is lower.

The change constitutes a major decrease in the effects of accidents previously analyzed, does not create any new accidents, and increases the margin of safety. Werefore, the results of this change are clearly within acceptance criteria, and this change is consistant with Item (ii) of the " Examples of Amerdments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6,1983, issue of the Federal Register.

3. Change Unit 1 Technical Specifications from "more than 5 percent of its yearly power operation" to "does not exceed 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in any consecutive 12 month period":

BASIS:

The change does not raise the probability or the consequences of an accident already evaluated. The cnange by itself may increase the allowable time in excess of the DEI limit. However, the lower level of allowable DEI offsets any increase in time exposure.

There are no new modes of operation. There is no significant reduction in the margin of safety. %erefore, the results of this change are clearly within acceptance criteria, and this change is consistant with Item (vi) of the " Examples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations"_ listed on page 14,870 of the April 6,1983, issue of the Federal Register. ,

This change is also administrative in that there is a change in nomenclature. We proposed change in nmenclature does not:

invo'.ve a significant increase in the probability or consequences of an accident previously evaluated; create the possibility of an accident of a type different from any evaluated previously; or involve a significant reduction in a margin of safety. Therefore, this change is consistant with Item (i) of the " Examples of Amendments that are Cor.aidered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6,1983, issue of the Federal Register.

4. Add to the Unit 1 Technical Specifications:

"Should the total operating time of a specific activity greater than 0.2 microcuries per gram dose equivalent I-131 exceed 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> in any consequtive 6 month period, the licensee shall report the number of hours of operation above this limit to the NRC within 30 days":

BASIS:

This change constitutes a more restrictive operational limitation to Unit 1. We resultant doses from a potential accident are less since the allowable initiating point for the transient is lower.

The change constitutes a major decrease in the effects of accidents previously analyzed, does not create any new accidents, and increases the margin of safety. %erefore, the results of this change are clearly within acceptance criteria, and this change is consistant with Item (ii) of the " Examples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6,1983, issue of the Federal Register.

5. Change Unit 1 Technical Specifications from " steam line isolation valves shall be closed inmediately" to " steam line isolation valves closed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />":

BASIS:

The change does not raise the probability or the consequences of an accident already evaluated. The change by itself may increase the allowable time in excess of the DEI limit. However, the lower level of allowable DEI offsets any increase in time exposure.

There are no new modes of operation. There is no significant reduction in the margin of safety. Werefore, the results of this change are clearly within acceptance criteria, and this change is consistant with Itm (vi) of the " Examples of Amendments that are Considered not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6,1983, issue of the Federal Register.

6. Change in Unit 1 Technical Specifications from " isotopic" to iodine":

BASIS:

This change is administrative in that there is a change in nomenclature. The change is a clarification of an existing practice. Without this change the Technical Specification could be construed to mean that the total isotopic inventory must be converted to an equivalence of. I-131. This is clearly not the intent of the specification. The intent is that all iodine

l isotopes must be converted to an equivalence of I-131. The proposed change does not: involve a significant increase in the probability or consequences of an accident previously evaluated; create the possibility of an accident of a type different from any evaluated previously; or involve a significant reduction in a margin of safety. Therefore, this change is consistant with Item (i) of the "Exanples of Amendnents that are Considered Not Likely to Involve Significant Haza rds Considerations" listed on page 14,870 of the April 6, 1983, i.; sue of the Federal Register.

7. Add to the Unit 1 'Nchnical Specifications: "(net change averaged for 1 Hour)":

BASIS:

This change is also administrative in that there is a change in nomenclature. The proposed change in nomenclature does not:

involve a significant increase in the probability or consequences of an accident previously evaluated; create the possibility of an acx:ident of a type different from any evaluated previously; or involve a significant reduction in a margin of safety. Therefore, this change is consistant w ' ith Item (i) of the "Exanples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6,1983, issue of the Federal Register.

8. Add to the Unit 1 Technical Specifications:

"3) ...at release rate less that 75,000 microcuries per second, or 4)

The off-gas levels at the SJAE, increases by more than 15% in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at release rate greater than 75,000 microcuries per second."

BASIS:

The change does not raise the probability or the consequences of an accident already evaluated. . The change by itself may increase the rate at which mI is allowed to increase. However, the lower level of allowable mI offsets any increase in consequences. There are no new modes of operation. There is no significant reduction in l the margin of safety. Werefore, the results of this change are l clearly within acceptance criteria, and this change is consistant with Item (vi) of the " Examples of Amendments that are Considered

, Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6, 1983, issue of the Federal Register.

9. Change the Unit 2 Technical Specifications from "80,000" to "75,000":

BASIS:

The change does not raise the probability or the consequences of an accident already evaluated. The change by itself may increase the rate at which mI is allowed to increase. However, the lower level

! of allowable DEI offsets any increase in consequences. There are no new modes of operation. There is no significant reduction in the margin of safety. %erefore, the results of this change are clearly within acceptance criteria, and this change is consistant with Item (vi) of the " Examples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6, 1983, issue of the Federal Register.

/

10. Delete from Unit 1 Technical Specifications:

"However, at least 3 consecutive samples shall be taken in all cases.":

BASIS:

This change is administrative in that there is a change in definition as to the number of required sanples. There is no change in the requirement to sanple until a stable value of DEI is reached. The proposed change in definition does not: involve a significant increase in the probability or consequences of an accident previously evaluated; create the possibility of an accident of a type different from any evaluated previously; or involve a significant reduction in a margin of safety. %erefore, this change is consistant with Item (1) of the "Exanples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6,19G3, issue of the Federal Register,

11. Add to the' Unit 1 Technical Specifications:

"The first additional coolant sample shall be taken between 2 and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following the change in thermal power of off-gas level.":

BASIS:

This change constitutes a more restrictive operational limitation to Unit 1. In that, it defines when the first sample must be taken. The resultant doses from a potential accident are less since the allowable iniciating point for the transient is lower.

The change constitutes a major decrease in the effects of accidents previously analyzed, does not create any new accidents, and increases the margin of safety. Therefore, the results of this change are clearly within acceptance criteria, and this change is consistant with Item (ii) of the " Examples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6,1983, issue of the Federal Register.

12. Charges to the bases to reflect the above changes:

BASIS:

These changes do not raise the probability or the consequences of an accident already evaluated. The change by itself may increase the allowable time in excess 'of the DEI limit. However, the lower level of allowable DEI offsets any increase in time exposure. % ere are no new modes of operation. There is no significant reduction in the margin of safety. Therefore, the results of these changes are clearly within acceptance criteria, and these changes are consistant with Items (1) , (ii) and (vi) of the " Examples of Amendments that are Considered Not .Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6,1983, issue of the Federal Register.

ATTACINENr 2 NIC DOCKET 50-321 OPERATING LICENSE DPR-57 EININ I. HA'ICH NUCLEAR PIANr UNIT 1 DOSE EQUIVALENT IODINE (IEI)

The proposed change to the Technical Specification (Appendix A to the Operating License) would be incorporated as follows:

Renove Page Insert Page 3.6-4 3.6.4 3.6-5 3.6-5 3.6-18 3.6-18

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