ML20137H601

Application for Amend to License NPF-2,requesting Implementation of voltage-based Alternate Repair Criteria, Per GL 95-05

ML20137H601
Person / Time
Site:	Farley
Issue date:	03/25/1997
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20137H605	List: ML20137H601 ML20137H609
References
GL-95-05, GL-95-5, NUDOCS 9704020295
Download: ML20137H601 (9)

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b D:ve MIr:y Siuthern Nuclear

• Vice Prevdent ' Opn: ting Comp:ny i f arley Project PO. Box 1295 l

. Birmingham Alabama 35201 J Tel 205.932.5131 I March 25, 1997 COMPANY Energy toServe YourWorld" l

Docket No.: 50-348 10 CFR 50.90  !

U.S. Nuclear Regulatory Commission ATfN: Document Control Desk 4 Washington, DC 20555 l i

Joseph M. Farley Nuclear Plant - Unit 1 I Primary Coolant Specific Activity Technical Specification Amendment l

Ladies and Gentlemen: ,

By letter dated December 26,199ti, Southem Nuclear submitted a technical specification amendment  ;

request for Farley Unit I for implementation of a voltage-based alternate repair criteria in accordance with Generic Letter 95-05. As part of that amendment request, Southern Nuclear asked that the primary-to-secondary leakage limit for leakage in the event of a steam line break be increased from 11.4 gpm to 20 ,

gpm based on an analysis described in the submittal. Subsequent discussions with the NRC Staffindicated that the results of the analysis were not consistent with calculations performed by the NRC Staff.  ;

Consequently, the amendment was approved with an 11.4 gpm leakage limit. Southern Nuclear was to submit a resised leakage limit based on a reduction of the primary coolant specific activity of Technical Specification 3/4.4.9.

Consequently, a technical specification for a reduction in the specific activity limits of the Farley Unit 1 i tecimical specifications is submitted. Enclosure I provides the basis of the described amendment. l Enclosure 2 provides a significant hazards evaluation for the amendment. Enclosure 3 provides the resised technical specification pages. Enclosure 4 provides resised responses to Generic Letter 95-05 guidance, based on submittals dated December 26,1996 and February 6,1997. The only change made with this submittal is the rinision to section 2.b.4 which addresses the leakage limit.

Southern Nuclear has performed an assessment of the impact of the proposed resision to the technical specifications on the environment and has determined that there is no impact on the environment. The proposed revision does not affect the types or amounts of any radiological or non-radiological effluents that may be released offsite. No increase in individual or cumulative occupational radiation exposures will result from this revision. Additionally, the revision does not invcae the use of any resources not previously considered in the Final Emironmental Statement related to the operation of Farley Nuclear Plant.

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

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• a U. S. Nuclear Regulatory Commission Page 2 As stated earlier, Southern Nuclear and the NRC Staff have been unable to resolve the differences in a leak rate limit calculation which was submitted m December 1996. Discussions on the calculation are continuing. However, due to the unexpected disagreement over the leak rate calculation and the unknowns of the current steam generator inspection underway for Farley Unit 1, the NRC Staffis requested to review this amendment request as soon as practical.

If you have any questions, please advise.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY

$] ))y Dave Morey Swom to and subscribed before me thishy af 1997 Y'1tfQAfAn, bG.ub binar

'\ Notary Public ' (/

My Commission Expires: #24/>AIto /, /792 REM /maf:UNITIDEl. DOC

Enclosures:

1. Basis for Amendment

2. Significant Hazards Evaluation

3. Technical Specification Pages

4. Revised Responses to Generic Letter 95-05 Guidance cc: Mr. L. A. Reyes, Region 11 Administrator Mr. J. I. Zimmerman, NRR Project Manager I Mr. T. M. Ross, Plant Sr. Resident Inspector Dr. D. E. Williamson, State Department of Public Health 4 l

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Enclosure 1 Basis for Amendment 3

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Basis for Amendment Introduction Implementation of the voltage-based repair criteria for Westinghouse steam generators affected by outside diameter stress corrosion cracking requires the implementation of a primary-to-secondary leakage limit in the event of a steam line break outside containment. By limiting the primary-to-secondary leakage, the radiological consequences of a postulated accident will not exceed the guideline values of 10CFR100. He quantity of primary-to-secondary leakage that is acceptable in the event of a postulated accident is dependent on the allowable activity in the primary coolant.

Description of the Amendment Reauest he proposed amendment will modify Technical Specification 3/4.4.9, " Specific Activity," and the associated bases to reduce the limit associated with dose equivalent iodine-131. The steady-state dose equivalent iodine-131 limit will be reduced by 40% from .5 pCurie/ gram to .3 pCurie/ gram. He transient limit for 80% to 100% power provided by Technical Specification Figure 3.4-1 will also be reduced by 40% (12 pCi/ gram). For less than 80% power, the transient limits will also be appropriately reduced by 12 pCi/ gram.

EMil By letter dated June 4,1992, Southern Nuclear submitted an assessment of the radiological dose consequences of a main steam line break. That calculation, based on a dose equinient iodine-131 limit of 1.0 Curie / gram foi t.:edy state with a corresponding transient limit, concluded that the leak rate in the faulted steam generator should be limited to 5.7 gpm.

By letter dated April 5,1994, the NRC Staffissued amendment 106 to the Farley Unit I technical specifications. This amendment reduced the dose equivalent iodine-131 limit to .25 pCurie/ gram for steady state with a corresponding reduction in the transient limit. This resulted in a leakage limit of(4 x 5.7 gpm) or 22.8 gpm.

By letter dated September 28,1995, the NRC Staffissued amendment 117 for the Farley Unit I technical specifications. This amendment increased the dose equivalent iodine-131 limit to .5 pCurie/ gram for steady state with a corresponding increase in the transient limit. This resulted in a leakage limit of(2 x 5.7 gpm) or 11.4 gpm. His safety evaluation included a description of confirmatory calculations performed by the NRC Staff that " concluded that a leak rate of 11.4 gpm is an acceptable limit of the maximum prunary to secondary leakage initiated by the steam line break accident."

"Ois proposed amendment will result in a dose equivalent iodine-131 hmit of.3 pCurie/ gram for steady state and a corresponding reduction in the transient limit of 12 pCi/ gram. This will result in a leakage limit 1 of(3.333 x 5.7 gpm) or 19 gpm. The transient limit will be 18 pCurie/ gram above 80% power with limits as shown on Figure 3.4-1 below 80% power. The calculation of these limits is consistent with that .

submitted originally by Southern Nuclear letter dated June 4,1992 and subsequently discussed in safety l cvaluations issued by the NRC Staffin letters dated April 5,1994 and September 28,1995. ,

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Enclosure 2 1

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i Significant Hazards Evaluation .

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6 Dose Equivalent lodine Limit Reduction Farley Nuclear Plant - Unit 1 Significant Hazards Evaluation Introduction implementation of the voltage-based repair criteria for Westinghouse steam generators affected by outside diameter stress corrosion cracking requires the implementation of a pnmary-to-secondary leakage limit in the event of a steam line break outside containment. By limiting the prunary-to-secondary leakage, the radiological consequences of a postulated accident will not exceed the guideline values of 10CFR100. He quantity of pnmary-to-wandey leakage that is acceptable in the event of a postulated accident is dependent on the allowable activity in the primary coolant.

Description of the Amendment Reauest As required by 10CFR50.91(a)(1), this analysis is provided to demonstrate that a proposed amendment to reduce the dose equivalent iodine limits for Farley Unit I represents no significant hazards. In accordance with 10CFR50.92(c), implementation of the proposed license amendment was analyzed using the followmg standards and found not to: 1) involve a significant increase in the probability or consequences for an accident previously evaluated; 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or 3) involve a significant reduction in a margin of safety.

He proposed amendment will modify Technical Specification 3/4.4.9, " Specific Actisity," and the associated bases to reduce the limit associated with dose equivalent iodine-131. He steady-state dose equivalent iodine-131 limit will be reduced by 40% from .5 pCurie/ gram to .3 pCurie/ gram. The transient limit for 80% to 100% power provided by Technical Specification Figure 3.4-1 will also be reduced by 40% (12 pCi/ gram). He limits for power less than 80% will also be appropriately reduced by 12 pCi/ gram.

Evaluation By letter dated June 4,1992, Southem Nuclear submitted an assessment of the radiological dose consequences of a main steam line break. Hat calculation, based on a dose equivalent iodine-131 limit of 1.0 pCurie/ gram for steady state with a corresponding transient limit, concluded that the leak rate in the faulted steam generator should be limited to 5.7 gpm.

By letter dated April 5,1994, the NRC Staffissued amendment 106 to the Farley Unit I technical specifications. This amendment reduced the dose equivalent iodine-131 limit to .25 Curie / gram for steady state with a corresponding reduction in the transient limit. His resulted in a leakage limit of(4 x 5.7 gpm) or 22.8 gpm.

By letter dated September 28,1995, the NRC Staffissued amendment i17 for the Farley Unit I technical specifications. His amendment increased the dose equivalent iodine-131 limit to .5 pCurie/ gram for steady state with a corresponding increase in the transient limit. This resulted in a leakage limit of(2 x 5.7 gpm) or 11.4 gpm. His safety evaluation included a description of confirmatory calculations performed by the NRC Staff that " concluded that a leak rate of 11.4 gpm is an acceptable limit of the maximum primary to secondary leakage initiated by the steam line break accident."

His proposed amendment will result in a dose equivalent iodine-131 timit of.3 pCurie/ gram for steady state and a correspondmg transient limit. His will result in a leakage limit of(3.333 x 5.7 gpm) or 19 gpm. The transient limit will be 18 pCurie/ gram above 80% power with limits as shown on Figure 3 4 1

, . Sigmficant Hazards Evaluation Page 2 Reduction in Dose Equivalent lodine-131 Limits below 80% power, he calculation of these limits is consistent with that submitted originally by Southern Nuclear letter dated June 4.1992 and subsequently discussed in safety evaluations issued by the NRC Staff in letters dated April 5,1994 and September 28,1995.

AllalIlit Conformance of the proposed met to the standards for a determmation of no significant hazards as defined in 10CFR50.92 is shown in the following.

1. Operation of Farley Unit 1 in amece with the proposed license ==h=* does not involve a significant increase in the probability or consequences of an accident previously evaluated.

He reduction in the dose equivalent iodine limits, both steady-state and transient, will not increase the probabdity of any accident evaluated since no physical changes to the plant are being made. He 9==g= == of any acculent previously evaluated will not be increased since the activity of the primary coolantis being decreased

2. De proposed hcense anumdemit dose not create the possibility of a new or different kind of accident from any accident previously evaluated.

The re *-, in the dose equivalent iodine limits, both steady-state and transient, will not create the possibility of a new or different kind of accident from any accident previously evaluated since no physical changes to the plant are being made. He accidents of concern continue to be those that have previously been analyzed.

3. He proposed license amendment does not involve a significant reduction in a margin of safety.

The calculated potential radiological consequences from the main steam line break accident remain within the regulatory exposure guidelines. Consequently, there is no reduction in any margin of safety.

Conclusion Based on the precedag analysis, it is concluded that operation of Farley Unit I following the reduction in the dose equivalent iodine-131 limits in accordance with the proposed amendment does not increase the probability of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, nor reduce any margms of safety. Derefore, the license amendment does not involve any significant hazards as defined in 10CFR50.92.

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Enclosure 3 Technical Specification Pages 1

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