ML20137S521

Application for Amends to Licenses NPF-2 & NPF-8,eliminating Tech Spec Requirement to Shut Down Plant If Coolant Iodine Activity Above 1 Uci/G for Greater than 800 H Period in 12 Months,Per Generic Ltr 85-19.Fee Paid

ML20137S521
Person / Time
Site:	Farley
Issue date:	11/27/1985
From:	Mcdonald R ALABAMA POWER CO.
To:	Rubenstein L Office of Nuclear Reactor Regulation
Shared Package
ML20137S526	List: ML20137S521 ML20137S539
References
GL-85-19, TAC-60293, TAC-60294, NUDOCS 8512060254
Download: ML20137S521 (3)

Text

I e . Mailing Addr:ss

. Alabima Power Company 600 North 18th Street e Post Of fice Box 2641 Birmingham. Alabama 35291 Tciephone 205 783-6090 R. P. Mcdonald Senior Vice President Flintridge Building Mghggg gg November 27, 1985 Docket Nos. 50-348 50-364 Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. L. S. Rubenstein Joseph M. Farley Nuclear Plant - Units 1 and 2 Proposed Generic Letter 8S-19 and Dose Equivalent Iodine Definition Technical Specification Change Gentlemen:

NRC Generic Letter 85-19, " Reporting Requirements on Primary Coolant Iodine Spikes", indicated that reportable occurrences for iodine spiking and the requirement to shut down a plant if the coolant iodine activity is above 1.0 microcurie / gram for greater than 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12-month period can be eliminated. The reportability portion of Generic Letter 85-19 was incorporated into the Farley Nuclear Plant Technical Specification 6.9.1.13 by License Amendments 57 and 49 for Units 1 ard 2, respectively. The elimination of the requirement. to shut down the plant as described in Generic Letter 85-19 is hereby proposed by Alabama Power Company.

Additionally, the Farley Nuclear Plant FSAR environmental consequences analyses are based on the thyroid dose conversion factors (DCFs) listed in Table III of TID-14844, " Calculation of Distance Factors for Power and Test Reactor Sites" for calculating a thyroid inhalation dose. Consequently, the technical specification definition of Pose Equivalent I-131 is also based on the TID-14844 thyroid DCFs. Subsequent to tne performance of the FSAR analyses, the NRC issued Regulatory Guide 1.109 to provide methods acceptable to the NRC for calculating doses for the purpose of evaluating compliance with 10CFR50, Appendix I. For routine releases, Alabama Power Company adopted a methodology for the Offsite Dose Calculation Manual (0DCM) which is consistent with the methodology of Regulatory Guide 1.109. As a result, both the Unit 1 and Unit 2 Technical Specification bases for the

(

Bh* IS$$ SEbbhis [

ge sJ w(u n ris

. "yogw o

Mr. L. S. Rubenstein November 27, 1985 U. S. Nuclear Regulatory Commission Page 2 radiological effluent technical specifications were written to clearly identify the consistency between the ODCM and Regulatory Guide 1.109 methodologies for calculating doses due to actual releases. The definition of DEI-131, however, was not changed in either unit to make it consistent with the bases.

Alabama Power Company proposes changes to the Technical Specifications to make them consistent throughout and to reflect Generic Letter 85-19. The proposed changes are presented in Attachment 1.

These proposed changes are consistent with the NRC Generic Letter 85-19 and do not increase the DEI-131 numerical limit of 1.0 microcurie / gram in Specification 3.4.9 and 0.1 microcurie / gram in specification 3.7.1.4.

Although the Regulatory Guide 1.109 DCFs are less limiting than those of TID-14844, the offsite releases from a steam generator tube rupture or steam line break accident, with the new technical specification DEI-131 definition, remain bounded by the existing FSAR analyses. There remains within the Limiting Condition for Operation of Specifications 3.4.9 and 3.7.1.4 adequate margin to the FSAR accident environmental consequences analyses. This change incorporates methodology which the NRC has found acceptable and is consistent with draft Revision 3 of NUREG-0472, the NRC Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors (PWRs), and draft Revision 5 of NUREG-0452, the NRC Standard Technical Specifications for Westinghouse PWRs.

Since the proposed Technical Specification change includes no changes which would significantly increase the probability or consequences of an accident previously evaluated, no changes which create the possibility of a new or different kind of accident from any accidents previously evaluated and no changes which would involve a significant reduction in a margin of safety, it is considered by Alabama Power Company to not involve a significant hazards consideration as defined in 10CFR50.92. This conclusion is based upon the FSAR offsite doses for steam line break and steam generator tube rupture accidents remaining bounding and this change representing a comparatively minor change in an input parameter in the previously evaluated accidents. It should be noted that the margin to the 10CFR100 dose limits provided in the FSAR analyses remain unaffected by this proposed change. In addition, the elimination of the requirement to shut down the plant when the Dose Equivalent I-131 exceeds 1 microcurie / gram in the reactor coolant for over 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12-month period is consistent with NRC accepted practice as indicated by Generic Letter 85-19 and therefore does not constitute a significant hazards consideration.

Alabama Power Company's Plant Operations Review Committee has reviewed this proposed change and the Nuclear Operations Review Board will review this proposed change at a future meeting.

Mr. L. S. Rubenstein November 27, 1985 U. S. Nuclear Regulatory Commissian Page 3 Pursuant to 10CFR170.21, the required License Amendment Application Fee of $150.00 is enclosed. In accordance with 10CFR50.90, three signed originals and forty additional copies of this proposed change are enclosed.

A copy of this proposed change has also been sent to Mr. Dan Turner, the Alabama State Designee, in accordance with 10CFR50.91(b)(1).

If you have any questions, please advise.

Yours very truly, x 'hy /

R. P. Mcdonald RPM /CJS:ddb-D30 Attachments cc: Mr. L. B. Long SWORN TO AND SUBSCRIBED BEFORE ME Dr. J. N. Grace Mr. E. A. Reeves THIS r 7 rd DAY OF M g 1985 Mr. W. H. Bradford g Mr. Dan Turner LI / A., < N '

No~tary P'r611c  ;

My Commission Expires: /oI, 1