ML20084M040

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Safety Evaluation Supporting Amends 115 & 107 to Licenses NPF-2 & NPF-8, Respectively
ML20084M040
Person / Time
Site: Farley  
Issue date: 05/22/1995
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20084L982 List:
References
NUDOCS 9506070382
Download: ML20084M040 (5)


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k UNITED STATES NUCLEAR REGUI.ATORY. COMMISSION f

WASHINGTON, D.C. 20066-4001

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.115 TO FACILITY OPERATING LICENSE NO. NPF-2 AND_MENDMENT NO. 107 TO FACILITY OPERATING LICENSE NO. NPF-8

. SOUTHERN NUCLEAR OPERATING COMPANY. INC.

JOSEPH M. FARLEY NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-348'AND 50-364 s

1.0 INTRODUCTION

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By letter dated March 6,1995, Southern Nuclear Operating Company (the licensee), submitted a request for changes to the Joseph M. Farley Nuclear

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Plant (Farley), > Units 1 and 2, Technical Specifications (TS). The requested amendments would relocate all of the TS requirements related to the Seismic and Meteorological Monitoring Instrumentation from the TS (Sections 3/4.3.3.3 and 3/4.3.3.4) to the Final Safety Analysis Report (FSAR) with the exception of the Special Reports regarding inoperable instrumentation. The relocated requirements include the limiting conditions for operation (LCO) and related surveillance requirements. The licensee has stated that the next update of the FSAR will include the TS Bases discussion of the relocated requirements.

2.0 BACKGRALNR Section 182a of the Atomic Energy Act (the "Act") requires applicants for nuclear power plant operating licenses to include -TS as part of the license.

The Comission's regulatory requirements related to the content of TS are set forth in Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36.

That regulation requires that the TS include items in five specific categories, including (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrativa controls. However, the regulation does not specify the particular requirements to be included in a plant's TS.

The Comission has provided guidance for the contents of TS in its " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (" Final Policy Statement"), 58 FR 39132 (July 22,1993), in which the Comission indicated that compliance with the Final Policy Statement satisfies Section 182a of the Act.

In particular, the Comission indicated that certain items could be relocated from the TS to licensee-controlled 9506070382 950$22 PDR ADOCK 05000348 P

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. documents, consistent with the standard enunciated in Portland General Electric Co. (Trojan Nuclear Plant), ALAB-531, 9 NRC 263, 273 (1979).

In that case, the Atomic Safety and Licensing Appeal Board indicated that " technical specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety."

Consistent with this approach, the Final Policy Statement identified four criteria to be used in determining whether a particular matter is required to be included in the TS, as follows:

(1) installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; (2) a process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient analysis that eitner assumes the failure of or presents a challenge to the integrity of a fission product barrier; (3) a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a Design Basis Accident or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (4) a structure, system, or component which operatingexperienceorprobabilisticsa[etyassessmenthasshowntobe significant to public health and safety.

As a result, existing TS requirements which fall within or satisfy any of the criteria in the Final Policy Statement must be retained in the TS, while those TS requirements which do not fall within or satisfy these criteria may be relocated to other licensee-controlled documents.

3.0 EVALUATION 3/4.3.3.3 Seismic Monitoring Instrumentation The licensee has proposed to relocate the requirements of TS 3/4.3.3.3 Seismic Instrumentation, to the FSAR.

Section VI(a)(3) of Appendix A to 10 CFR Part 100, requires that seismic monitoring instrumentation be provided to i

promptly determine the response of those nuclear power plant features important to safety in the event of an earthquake. This capability is required to allow for a comparison of the measured response to that used in the design basis for the unit.

Comparison of such data is needed to (1) determine whether the plant can continue to be operated safely, and (2) permit such timely action as may be appropriate.

However, seismic instrumentation does not actuate any protective equipment or play any direct role in the mitigation of an accident.

The Consnission recently promulgated a proposed change to i 50.36, pursuant to which the rule would be amended to codify and incorporate these criteria (59 FR 48180). The Commission's Final Policy $tatement specified that only limiting conditions for Reactor Core Isolation Cooling, Isolation Condenser, Residual Heat Removal, Stan@y Liquid Control, and Recirculation Pwp Trip meet the guidance for inclusion in the TS tnder Criterion 4 (58 FR at 39137). The Commission has solicited public coments on the scope of Criterion 4, in the pending rutemaking.

The capability of the plant to withstand a seismic event or other design-basis accident is determined by the initial design aid construction of systems, structures, and components.

The instrumentation is used to alert operators to the seismic event and evaluate the plant response. The Final Policy Statement explained that instrumentation to detect precursors to reactor coolant pressure boundary leakage, such as seismic instrumentation, is not included in the first criterion. As discussed above, the seismic instrumentation does not serve as an active design feature or part of a primary success path for events which challenge fission product barriers by actuating protective equipment or play any direct role in the mitigation of an accident.

The licensee has proposed to relocate these provisions to the FSAR such that future changes to the cperation and surveillance of the seismic monitoring instrumentation could be changed under 10 CFR 50.59.

Accordingly, the staff concluded that the requirements for seismic monitoring instrumentation do not meet the TS criteria in the Final Policy Statement.

s The limiting conditions for operation and surveillance requirements for seismic monitoring instrumentation, including Special Reports, were removed from the standard technical specifications.

3/4.3.3.4 Meterologict.1 Monitoring Instrumentation The meteorological monitoring instrumentation is used to measure environmental parameters (wind direction, speed, and air temperature differences) that may affect the distribution of radioactive effluents following a release of radioactive material.

In 10 CFR 50.47, " Emergency Plans," and 10 CFR Part 50, Appendix E, " Emergency Planning and Preparedness for Production and Utilization Facilities," the Commission requires power plant licensees to provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. Timely access to accurate local meteorological data is important for estimating potential radiation doses to the public and for determining appropriate protective measures.

In 10 CFR 50.36a(a)(2), the Commission requires nuclear power plant licensees to submit annual reports specifying the quantity of each of the principal radionuclides released to unrestricted areas in liquid and airborne effluents and such other information as may be required by the NRC to estimate maximum potential annual radiation doses to the public. A knowledge of meteorological conditions in the vicinity of the reactor is important in providing a basis for estimating annual radiation doses resulting from radioactive materials released in airborne effluents. Accordingly, the meteorological monitoring instrumentation serves a useful function in estimating radiation doses to the public from either routine or accidental releases of radioactive materials to the atmosphere.

The licensee has proposed to relocate these provisions to the FSAR such that future changes to the operation and surveillance of the meteorological monitoring instrumentation could be changed under 10 CFR 50.59.

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. The meteorological monitoring instrumentation does not serve such a primary protective function as to warrant inclusion in the TS in accordance with the criteria of the Final Policy Statement. The instrumentation does not serve to i

ensure that the plant is operated within the bounds of initial conditions assumed in design basis accident and transient analyses or that the plant will be operated to preclude transients or accidents.

Likewise, the meteorological instrumentation does not serve as part of the primary success path of a safety sequence analysis.used to demonstrate that the consequences of these events are within the appropriate acceptance criteria. The licensee has proposed to i

relocate these provisions to the FSAR such that future changes to the operation and surveillance of the meteorological monitoring instrumentation could be changed under 10 CFR 50.59.

Currently, Special Reports must be made to the NRC if the seismic or meteorological instrumentation are out of service for extended periods. The licensee has proposed to remove this requirement from the remaining s

requirements being relocated to the FSAR. The staff finds that deleting special reporting requirements related to this instrumentation is acceptable.

1 The staff bases this conclusion on the existence of adequate reporting requirements in such regulations as 10 CFR 50.72 and 50.73.

i Accordingly, the staff concluded that the requirements for meteorological monitoring instrumentation do not meet the TS criteria in the Final Policy Statement.

The limiting conditions for operation and surveillance requirements for meteorological monitoring instrumentation, including Special Reports, were removed from the standard technical specifications.

In conclusion, the above relocated requirements relating to the relocation of the specific instrumentation requirements are not required to be in the TS under 10 CFR 50.36 or Section 182a of the Atomic Energy Act, and are not required to obviate the possibility of an abnormal situation or event giving 1

rise to an immediate threat to the public health and safety.

Further, they do i

not fall within any of the four criteria set forth in the Commission's Final Policy Statement, discussed above..In addition, the staff finds that sufficient regulatory controls exist under 10 CFR 50.59 to ensure continued protection of the public health and safety. Accordingly, the staff has concluded that these requirements may be relocated from the TS to the licensee's FSAR.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the State of Alabama official was notified of the proposed issuance of the amendments.

The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change the Surveillance Requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, I

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, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (60 FR 18628 dated April 12,1995). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, s

and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors:

W. Reckley B. Siegel Date:

May 22, 1995 i

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