ML20126D238

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Safety Evaluation Supporting Amends 87 & 80 to Licenses DPR-19 & DPR-25,respectively
ML20126D238
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 05/30/1985
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20126D231 List:
References
NUDOCS 8506140685
Download: ML20126D238 (3)


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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 87 TO PROVISIONAL OPERATING LICENSE NO. DPR-19 AND AMENDMENT NO. 80 TO FACILITY OPERATING LICENSE NO. DPR-25 COMMONWEALTH EDISON COMPANY DRESDEN NUCLEAR POWER STATION, UNIT NOS. 2 AND 3 DOCKET NOS. 50-237/249

1.0 INTRODUCTION

The staff's original Safety Evaluation Report (SER) on this subject, for Dresden 2, was issued in NUREG-0823, " Integrated Plant Safety Assessment Dresden Nuclear Power Station, Unit 2." Section 4.21.4 required that the licensee provide a suitable Technical Specification (TS) for a Limiting Condition for Operation (LCO) with a battery system out of service.

In Sections 4.31 and 4.32, the staff concluded that the licensee should adopt the BWR Standard Technical Specifications (STS) limits for dose-equivalent iodine-131 in the primary coolant to minimize the radiological consequences of events involving a release of primary coolant outside the containment without significant core damage.

Further, the staff concluded that the licensee should develop appropriate plant-specific actions to be taken in the event that these limits are exceeded; the limits and actions should be incorporated into the LC0 in the plant TS. The licensee agreed.

In a letter dated February 10, 1984, the licensee provided revised TS for both Dresden 2 and Dresden 3, since the latter is identical to Unit 2, for i

each of the above staff concerns. These proposed TS were ref0 matted, revised and resubmitted by the licensee in a letter dated August 2, 1984.

A Notice of Consideration of Issuance of Amendments to License and Proposed No Significant Hazards Consideration Determination and Opportunity for Hearing related to the requested action was published in the Federal Register on December 31, 1984 (49 FR 50799). No public comments or requests for hearing were received.

i 2.0 REVIEW CRITERIA The review criteria that govern an LCO with a battery system out of service are identified in Section 8.3.2, Part II, Items 1 and 2 of the NRC Standard Review Plan. Those for primary coolant iodine are identified in the November 10,_1982 SER for Systematic Evaluation Program (SEP) Topic XV-16 and in the February 2, 1982 SER for SEP Topic XV-18.

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0 l 3.0 RELATED SAFETY TOPICS The related safety topics for primary coolant iodine are identified in the topic SERs, listed above. There were none for an LC0 with a battery system out of service.

4.0 REVIEW GUIDELINES

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For an LCO with a battery system out of service, the review was limited to considering the degree to which redundant equipment was protected from a loss of power as a result of a single failure while a battery was out of service.

l For primary coolant iodine, the review was limited to a comparison of the licensee's proposed TS to the STS to determine whether the licensee included the appropriate STS limits and action statement.

5.0 EVALUATION 5.1 LCO With a Battery System Out of Service In the February 10 and August 2,1984 submittals, the licensee submitted a proposed TS and basis that was prepared in response to the staff concerns expressed in Section 4.21.4 of NUREG-0823.

The proposed change limits operation to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> with a failed battery system. A cumulative exception (on a refueling cycle basis) is made for testing and maintenance. A second cumulative exception is made for cell replacement.

The 2-hour limit satisfies the requirement specified in Section 4.21.4 of NUREG-0823 and is, therefore, acceptable to the staff.

The exceptions have been considered and the staff believes that they are necessary to permit the operation of Units E and 3 while routine testing and maintenance is being conducted. TS page l

B 3/4.9-7 provides the licensee's basis for its LCO. The staff's basis for approval is a finding that the limited time for the I

exception satisfies the reouirements of IEEE Std. 279-1971 Section 4.11. " Channel Bypass or Removal from Operation."

t 5.2 Primary Coolant Iodine A comparison of the licensee's TS with the STS shows that the licensee has included the dose equivalent I-131 (DEI-131) and total activity limits in the LCO for the revised Dresden TS.

. The action statements in the STS include sampling and reporting requirements which are intended to provide plant-specific data that could be used to investigate iodine spiking behavior and isotopic distributions. The licensee has proposed to take a sample of l

reactor coolant and perform an isotopic analysis at least every 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />. Sampling frequencies would increase to at least three samples every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when readings are above 0.2 and less than 4.0 microcuries per gram DEI-131.

In the event that DEI-131 concentration exceeds the 0.2 equilibrium limit for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or exceeds a maximum of 4 microcuries per gram, the licensee would initiate a plant shutdown to investigate the cause of the high activity. When readings above 4 microcuries per gram are taken, the licensee must verify the reading within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and, if the second reading is above 4 microcuries per gram, then plant shutdown must be initiated. Although the proposed action requirements do not conform exactly with those in the STS, they accomplish the l

same objective: the proposed LCO will ensure that the potential for an accident involving a release of primary coolant with a DEI-131 concentration above the equilibrium limit is acceptably small. The proposed TS for primary coolant iodine are therefore acceptable.

6.0 ENVIRONMENTAL CONSIDERATION

These amendments involve a change in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes to the surveillance requirements. The staff has determined that the amendments involve no significant increase in the amounts, 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 these amendments involve no significant hazards consideration and there has been no public comment on such finding.

Accordingly, these 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 these amendments.

7.0 CONCLUSION

The staff has concluded, based on the considerations discussed above, that:

will not be endangered by operation in the proposed manner, and (2) public (1) there is reasonable assurance that the health and safety of the such activities will be conducted in compliance with the Commission's regulations and the issuance of these amendments will not be inimical to the common defense and security or to the health and safety of the public.

8.0 ACKNOWLEDGEMENT This Safety Evaluation has been prepared by R. Scholl and T. Michaels.

Dated: May 30, 1985.

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