ML20098B091

Application for Amends to Licenses NPF-2 & NPF-8,changing TS 4.6.1.3 to Incorporate Improvements to Containment Air Lock Testing Ref in Chapter 3.6,containment Sys of NUREG-1431, Sts,Westinghouse Plants

ML20098B091
Person / Time
Site:	Farley
Issue date:	09/26/1995
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20098B092	List: ML20098B091 ML20098B094
References
RTR-NUREG-1431 NUDOCS 9510020138
Download: ML20098B091 (4)

Text

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Southctn Nuct:ir Operating Company

• Post Offic9 Box 1295 Birmingham. Alibams 35201 -

Telephone (205) 868-5131

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. L o... mor.y Southern Nudear Operating Company "

Vice President Farley Project the Southem electnc System i

September 26,1995 Docket Nos. 50-348 10CFR50.90 50-364 1

- U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 i Joseph M. Farley Nuclear Plant Containment Air Lock Technical Soccification Channes l Ladies and Gentlemen:

In accordance with the provisions of 10 CFR 50.90, enclosed are proposed Technical Specifications changes requested by Southern Nuclear Operatmg Company (SNC) for the Farley Nuclear Plant, Unit 1 and Unit 2 to incorporate improvements to containment air lock testing referenced in Chapter 3.6, Containment Systems, of NUREG-1431, " Standard Technical Specifications, Westinghouse Plants." The proposed changes affect Technical Specificaten secten 4.6.1.3.

A safety assessment of the proposed technical specificaten changes is provided in Enclosure 1. The '

supporting significant hazards evaluaten pursuant to 10 CFR 50.91 is provided in Enclosure 2. The revised typed pages of the proposed technical specifications, including page change instructions, are included in Enclosure 3. The marked-up pages are provided in Enclosure 4.

SNC has determined that the proposed license amendment will not affect the ability of containment to limit ,

the leakage of fission product radioactivity to the environment. SNC has also reviewed the proposed j Ikense amendment against the criteria of 10 CFR 51.22 for environmental considerations. The proposed changes do not involve a significant hazards considerabon, nor increase the types and amounts of effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, SNC concludes that the proposed chan8e meets the criteria delineated in 10 CFR 51.22(c)(9) and will have no impact on the environment.

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U. S. Nuclear Regulatory Commission Page 2 SNC has determined that_ this submittal represents a Cost Beneficial Licensing Action (CBLA), in that the implementation of this request can result in a savings of greater than $100,000 over the life of the plant. SNC will implement the proposed license amendment within 30 days of NRC issuance.

A copy of these proposed changes is being sent to Dr. Donald E. Williamson, the Alabama State Designee, in accordance with 10 CFR 50.91(b)(1).-

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

Respectfully Submitted, SOUTHERN NUCLEAR OPERATING COMPANY YILgu Dave Morey SWORN TO AND SUBSCRIBED BEFORE ME Tills of[- DAY OF 1995 L L . - (gg Notary Public '/ My Commission Expireb JM /77'/ EFB: air _ loc 1. doc 0 i , Enclosures

1. Basis for Change Request 2.10 CFR 50.92 Evaluation

3. Page Change instructions and Revised Pages

4. Marked Up Pages cc: lll. Nuclear Regulatory Commission. Washington. D. C.

B. L. Siegel, Licensing Project Manager, NRR-U.S. Nuclear Regulatory Commission. Region 11  ; S. D. Ebneter, Regional Administrator T. M. Ross, Senior Resident inspector State of Alabama D. E. Williamson, State Public Ilealth Officer

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k Enclosure 1 l Joseph M. Farley Nuclear Plant 10 CFR 50, Appendix J Containment Leakage Testing Technical Suecification Changes t Safety Assessment It is a requirement of 10 CFR 50, Appendix J, section Ill(DXbXiv) to document the containment air lock acceptance criteria values in the plant technical specifications. The overall leakage rate of the air lock remains as less than or equal to 0.05L when tested at a pres <ure greater than or equal to P,. The door seal leakage rate is proposed to be changed to less than or equal to 0.0ll, when the gap between the door seals is pressurized to greater than or equal to 10 psig for a period of not less than 15 minutes. These details more closely reflect the format and presentation of the acceptance criteria in NUREG-1431,

                   " Standard Technical Specifications - Westinghouse Plants." The test pressure and duration (10 psig for at least 15 minutes) was approved by the NRC pei the original Safety Evaluation Report (SER),
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Supplement 4. The values representing the leakage rate acceptance criteria referenced in the proposed wording have been reviewed and have been found to be an improvement to Farley Nuclear Plant's current acceptance criteria while maintaining an acceptable level of safety. The current acceptance criteria. no detectable seal leakage by pressure decay when the volume between the door seals is pressurized to > 10 psig for at least 15 minutes," is an impractical criterion for evaluation of door seal performance. Tbe proposed acceptable leakage criterion facilitates performance of a reasonable test while assuring the door seals will perform at a high level of quality. Containment leakage is an assumption in the safety analysis of the loss of coolant accident and the rod ejection accident. Changes to the containment air lock door seal test acceptance criteria will have no impact on the radiological consequences of these accidents since the plant safety analysis is based on the more conservative assumption that the containment leaks at its design leak rate of 0.15 percent per day for the first 24 hours and 0.075 percent per day thereafter for each of these accidents. El-1

M i Enclosure 2 Joseph M. Farley Nuclear Plant Containment Air lock Testag Technical Soccification Channes 10 CFR 50.92 Evaluation ~ l

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.             SNC has reviewed the requirements of 10 CFR $0.92 as they relate to the proposed change and has made

the following detennmation

1. He proposed change does not involve a significant increase in the probability or consequences of an ,

accident previously evaluated. De proposed change does not involve any change to the configuration or method of operation of any plant equipment used to mitigate the consequences of an accident. Containment i leakage is an assumption in the safety analysis of the loss of coolant accident and the rod ejection accident. Changes to the containment air lock door seal test acceptance criteria will have no impact on the < radiological consequences of these accidents since the plant safety analysis is based on the assumption that the containment leaks at its design leak rate of 0.15 percent per day for the first 24 hours and 0.075 percent per day thereafter for each of these accidents. %c change to the surveillance requirement meets the intent of the guidance in NUREG-1431. Primary containment mtegrity casures that the releese of radioactive

materials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the accident analysis. De limitations on closure and leak rate for the containment air locks are required to meet these restrictions on containment integnty. %ese changes do not increase the probability that the 10 CFR 100 limits will be ne~dd %c change to the surveillance requirement does 3

not impose any new safety analyses limits or alter the plants ability to detect and mitigate events i %erefore, the proposed change does nM involve a significant increase in the probability or ma==_m of an accident previously evaluated.

2. De proposed change does not create the possibility of a new or different kind of accident from any

accident previously evaluated. De proposed change involves a revision to the Technical Specifications to l meet the intent of the guidance of NUREG-1431, and does not necessitate a physical alteration of the plant or change in parameters governing ramal plant operation. De change has no effect on tlw plant's compliance with the requirenwnts of Appendix J. %c revision of the acceptance criteria for the air lock j door seal test will improve the FNP current testing criteria while maintainmg an acceptable level of safety.

Therefore, the proposed change do:e not create the possibility of a new or different kind of accident from i any accident previously evaluated.

3. He proposed change does not involve a significant reduction in a margin of safety. Le revision of the acceptance criteria of the air lock door seal test will decrease the overall test burden without decreasing the margin of safcty. The overall leakage rate of the air lock continues as less than or equal to 0.051 and the plant safety analysis continues to be based on the assumption that the containment leaks at its design leak rate of 0.15 percent per day for the first 24 hours and 0.075 perecuit per day thereafter for each of these accidats. ncrefore, the proposed change does not involve a signinennt reduction in a margm of safety.

In conclusion, SNC has determmed the proposed changes meet the requirements of 10 CFR 50.92(c) and do not inmtw a significant hazards consideration E2-1

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