ML20151R773
| ML20151R773 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 01/27/1986 |
| From: | Beckham J GEORGIA POWER CO. |
| To: | Muller D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20151R778 | List: |
| References | |
| 2166N, SL-186, TAC-60728, TAC-60729, NUDOCS 8602060230 | |
| Download: ML20151R773 (11) | |
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Georgta Power Company 333 PiedrTiont Avenue Atlanta. Gectgta 30308
. Tetephone 404 52G 7020 Maing Address-Post Office Box 4545 Atlanta, Georqq 30302 b
Georgia Power J. T. Beckham, Jr.
U '**" 'W/'t s rsfem Vice President and Generat Manager Nucleat Opcar:cnt SL-186 2166N January 27, 1986 Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 Division of Boiling Water Reactor Licensing U. S. Nuclear Regulatory Commission Washington, D.C.
20555 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 REQUEST TO REVISE TECHNICAL SPECIFICATIONS Gentlemen:
In accordance with the provisions of 10 CFR 50.90 as required by 10 CFR CO.59(c)(1),
Georgia Pcwer Company hereby proposes changes to the Technical Specifications, Appendix A to Operating Licenses DPR-57 and NPF-5 The proposed revision consists of several changes to the Technical Specifications which require analysis and monitoring of radioactive effluents.
It is proposed to: allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before the flowrates of various radioactive gaseous effluent pathways must be estimated when less than the minimum number of required channels are operable; eliminate checking the tritium levels during startup and power level changes; add a time frame for performance of gaseous waste analyses; and only require additional monitoring of gaseous effluents if necessitated by changes in water chemistry. provides a detailed description of the proposed changes and circumstances necessitating the change request. details the basis for our determination that the proposed change does not involve significant hazards considerations. details the basis for our determination that the proposed change does not involve significant hazards considerations, e602060230 e60127 PDR ADOCK 0500 1
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k Georgia Power h U. S. Nuclear Regulatory Commission Washington, D.C.
January 27, 1986 Page 2 and Attachment 5 provide page change instructions for incorporating the proposed changes in the Technical Specifications of Unit 1 and Unit 2, respectively.
The proposed changed Unit 1 and Unit 2 Technical Specifications pages follow their respective attachments.
Payment of filing fee is enclosed.
In ort e to allow time for procedure revision and orderly incorporation f
into copies of the Technical Specifications, we request that the proposed amendment once approved by the NRC, be issued with an effective date to be no later than 30 days from the date of issuance of the amendment.
Pursuant to the requirements of 10 CFR 50.91, Mr. J. L. Ledbetter of the Environmental Protection Division of the Georgia Department of Natural Resources will be sent a copy of this letter and all applicable attachments.
J. T.
Beckham, J r.
states that he is Vice President of Georgia Power Company and is authorized to execute this oath on behalf of Georgia Power Company, and that to the best of his knowledge and belief the facts set forth in this letter and attachments are true.
GEORGIA POWER COMPANY By: h&
,* b y J. T. Beckham, Jr.'
Sworn to and subscribed before me this 27th day of January 1986
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Enclosures xc:
H. C. Nix, J r.
Senior Resident Inspector NRC Regional Administrator J. L. Ledbetter l
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GeorgiaPower d ATTACHMENT 1 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 REQUEST TO REVISE RADI0 ACTIVE EFFLUENT TECHNICAL SPECIFICATIONS Basis for Change The proposed revision consists of several changes to the Radiological Effluent Technical Specifications (RETS) which require analysis and monitoring of radioactive effluents.
The first change revises Action Statement 104 of Unit 1 Table 3.14.2-1 and Unit 2 Table 3.3.6.10-1.
The proposed change will require that the reactor buildings vent stack effluent and sampler flowrates, the recombiner building ventilation sampler flowrate, and the main stack effluent and sampler flowrates be estimated every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, rather than every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> in the current specification, when less than the minimum number of channels are operable.
At Plant Hatch, gaseous radioactive effluents are released via the main stack in a continuous mode during normal plant operation.
The plant does not have a
gaseous retention system; therefore, the flowrates and concentrations of radionuclides through that pathway are essentially constant for a given power level.
For the other pathways, under the worst case assumption, there would be no indication of a no-flow condition for a maximum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
There would not be releases through the pathway with no flow.
Given the maximum allowable building leakage rate from the building, the limits of 10 CFR 100 or 10 CFR 50 Appendix I would not' be exceeded.
The proposed change will allow daily verification as was required in the Plant Hatch Appendix
'B' Technical Specifications before implementation of Radiological Effluent Technical Specifications (RETS) in Appendix
'A'.
It will also provide consistency with surveillance requirements of similar tests.
The second change involves revising Unit 1 Table 4.15.2-1 and Unit 2 Table 4.11.2-1 to delete footnote 'c' from applying to tritium levels.
Footnote 'c' requires additional sampling following shutdown, startup, or power level changes greater.than 15% of rated thermal power.
The basis for the inclusion of this Technical Specification is the early detection of a Primary to Secondary leak in a PWR.
Hatch RETS were developed from PWR Standard RETS rather than BWR because the latest guidance had not been incorporated into the BWR Standard at that time.
The Plant Hatch Unit 2 FSAR section 11.1.3 identifies the primary source of tritium in a BWR as the activation of deuterium in the coolant.
Although the rate of tritium production due to activation is dependent upon power, it will not significantly change during the conditions described.
Tritium is also produced by tertiary fission.
Tritiun may transfer from the fuel to the primary coolant if cladding defects are present, from the fission of tramp Uranium on the outside surface of the cladding, or migration through the clad.
Stress on the fuel during severe power level changes could enhance any cladding defects present resulting in the possibility of increased fuel leakage.
However, the change in the level of gamma emitters will provided a quicker and more sensitive indication of increased fuel leakage than tritium, since more gamma emitters are produced by the fuel than tritium.
In addition, Regulatory Guide 1.21 only requires that the tritium concentration be determined monthly for continuous releases.
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k Georgia Power m ATTACHMENT 1 Basis for Change (Continued)
It is also proposed to revise footnotes 'c' and
'd' of Unit 1 Table 4.15.2-1 and Unit 2 Table 4.11.2-1 to be similar to the Standard RETS for BWRs, NUREG-0473 Revision 3.
Both footnotes 'c' and
'd' would be revised so that additional monitoring of gaseous waste streams will not be required following shutdown, startup or power level changes greater than 15% rated thermal power unless the Dose Equivalent Iodine (DEI) level has increased by more than a factor of three above the steady state value and greater than 0.02 uCi/g.
This addition to the specification will eliminate redundant surveillance of both DEI and gaseous plant effluents, since sampling and analysis of the primary coolant is required after pov.er level changes greater than 15% of rated thermal power.
The sampling is redundant because an increase in dose equivalent iodine would direct.ly imply an increase in principle gamma emitters and vice versa. At Plant Hatch DEI i:, required to be sampled every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> during operation.
It is normally sampled daily.
This change will maintain DEI testing at existing levels and require additional gaseous effluent monitoring only if indicated by changes in chemistry.
The DEI level is chosen to indicate a statistically significant increase above background while still being 10% of the Technical Specification limit.
If the level should increase to a factor of three beyond a starting point of 0.02 pCi/g the resultant level would still only be 30% of the allowable DEI and give sutficient time for remedial action.
This change is necessary due ta the current DEI levels being on the order of lE-4 C1/gm.
There could en tly be a change of a factor of three from this steady state value with no significant impact on radiological effluents from the facility.
Revising the footnotes to require additional testing after power level changes if the dose equivalent iodine increases by more that a factor of three and greater than 0.02 p Ci/g is similar to the Standard RETS for BWRs.
Plant Hatch was originally licensed with a site specific dose analysis limit for DEI.
This limit was 10 pCi/g.
Continuous discharges at just below this level would not exceed 10 CFR 100 or 10 CFR 20 limits.
Therefore, continuous discharge at a level 500 times smaller will not exceed those limits set forth in 10 CFR 50 Appendix I or 10 CFR 100.
Footnote 'c' would also be revised to add a time frame for performing the analysis, since one currently does not exist.
The standard RETS does not specify a sampling and analysis time limit.
The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit was proposed based on an examination of the various release paths (Reactor Building Vents, Main Stack and Recombiner Building) to assure scmples are taken consistent with the release of any radioactivity.
The Main Stack is the limiting (longest) pathway.
The offgas treatment system pros ides for a2 1/2 hour delay line followed by holdup in the offgas charcoal filters.
These filters provide for a 9 hour1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> delay in Krypton isotopes and 7 day holdup for Xenon isotopes.
Sampling of the main stack therefore is delayed by 2 1/2 hours if the charcoal filters are bypassed or 11 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with the filters in-line.
The change is made to prevent a possible misinterpretation that the sample should be taken at all points before the gaseous radioactive effluent in question could reasonably be expected to be available for sampling.
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GeorgiaPower d ATTACHMENT 2 NRC UULKtl5 60-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 REQUEST TO REVISE RADI0 ACTIVE EFFLUENT TECHNICAL SPECIFICATIONS 10 CFR 50.59 Evaluation Pursuant to 10 CFR 50.59, the Plant Review Board and Safety Review Board have reviewed the proposed amendment to the Plant Hatch Units 1 and 2 Technical Specifications and have determined that implementation of the proposed amendment does not constitute an unreviewed safety question.
A.
PROPOSED CHANGE It is proposed to revise Action Statement 104 of Unit 1 Table 3.14.2-1 and Unit 2 Table 3.3.6.10-1, so that, the flowrates must be estimated every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, rather than every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, to allow effluent releases to continue with less than a minimum number of channels of instrumentation operable.
BASIS The probability of occurrence or the consequences of an accident or malfunction of equipment important to safety are not increased above those analyzed in the FSAR due to this change because it does not affect the mode of operation or function of any safety system as described in the FSAR.
The possibility of an accident or malfunction of a different type than analyzed in the FSAR does not result from this change because this proposal does not change the mode of operation of any safety system, thus 1
the accident analyses is still valid.
The margin of safety as defined in the Technical Specifications is not reduced due to this change because the radioactive effluent release rates through the main stack are relatively constant.
For the other pathways, under the worst case assumption there would be no releases through the pathway with no flow; therefore, there is no degradation of the margin of safety.
B.
PROPOSED CHANGE It is proposed to revise Unit 1 Table 4.15.2-1 and Unit 2 Table 4.11.2-1 1
to delete footnote 'c' from applying to tritium levels.
Footnote 'c' requires additional sampling following shutdown, startup or power level changes greater than 15% of rated thermal power.
BASIS
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The probability of occurrence or the consequences of an accident or malfunction of equipment important to safety are not increased above those analyzed in the FSAR due to this change because it does rot affect the imode of operation or function of any safety system as described in the FSAR.
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ATTACHMENT 2 10 CFR 50.59 Evaluation (continued)
The possibility of an accident or malfunction of a different type than analyzed in the FSAR does not result from this change because it does not change the mode of operation or function of any safety system as described in the FSAR, thus the accident analyses is still valid.
The margin of safety as defined in the Technical Specifications is not reduced due to this change because tritium levels in BWRs are fairly low and do not significantly change during power level changes.
FSAR section 11.1.3 identifies the primary source of tritium in a BWR as the activation of deuterium.
Although the rate of tritium production due to activation is dependent upon power, it will not significantly change during the conditions described.
In addition, Regulatory Guide.1.21 only requires that the tritium concentration be determined monthly for continuous releases.
C.
PROPOSED CHANGE Footnotes 'c' and
'd' of Unit 1 Table 4.15.2-1 and Unit 2 Table 4.11.2-1 will be revised.
Both footnotes will be revised so that additional monitoring is not required unless the dose equivalent iodina level increases by more than a factor of three and greater than 0.02 fi/g.
BASIS The probability of occurrence or the consequences of an accident or malfunction of equipment important to safety are not increased above those analyzed in the FSAR due to this change because it does not change the mode of operation or function of any safety system as described in the FSAR.
The possibility of an accident or malfunction of a different type than analyzed in the FSAR does not result from this change because it does not change the mode of operation or function of any safety system as described in the FSAR.
The margin of safety as defined in the Technical Specifications is not reduced due to this change because the change will eliminate redundant testing. Revising the footnotes to require additional testing after power level changes if the dose equivalent iodine increases by more that a factor of three and greater than 0.02 pCi/g is similar to the Standard RETS for BWRs.
The DEI level is chosen to indicate a statistically significant increase above background while still being 10% of the Technical -Specification limit.
If the level should increase to a factor of three beyond a starting point of 0.02 pCi/g the resultant level would still only be 30% of the allowable DEI and give sufficient time for remedial action.
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GeorSlaPower d ATTACHMENT 2 i
10 CFR 50.59 Evaluation (Continueu)
D.
PROPOSED CHANGE Footnotes 'c' of Unit 1 Table 4.15.2-1 and Unit 2 Table 4.11.2-1 will be revised.
A time frame ' of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for performing the analysis will be added.
BASIS The probability of occurrence or the consequences of an accident or malfunction of equipment important to safety are not increased above those analyzed in the' FSAR due to this change because it does not change the mode of operation or function of any safety system as described in the FSAR.
The possibility of an accident or malfunction of a different type than analyzed in the FSAR does not result from this change because it does not change the mode of operation or function of any safety system as described in the FSAR.
The margin of safety as defined in the Technical Specifications is not reduced due to this change because the addition of a time limit for performing surveillance on footnote 'c' is more restrictive.
The change is made to prevent a possible misinterpretation that the sample should be taken at all points before the gaseous radioactive effluent in question could reasonably be expected to be available for sampling.
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1 GeorgiaPower d ATTACHMENT 3 NRC DGCKETS 50-321, 3 -30G OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 REQUEST TO REVISE RADI0 ACTIVE EFFLUENT TECHNICAL SPECIFICATIONS 10 CFR 50.92 Evaluation Pursuant to 10 CFR 50.92, Georgia Power Company has evaluated the proposed amendment for Plant Hatch Units 1 and 2 and has determined that its adoption would not involve a significant hazard.
The basis for this determination is as follows:
A.
PROPOSED CHANGE It is proposed to revise Action Statement 104 of Unit 1 Table 3.14.2-1 and Unit 2 Table 3.3.6.10-1, so that, the flowrates must be estimated every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> rather than every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to allow effluent releases to continue with less than a minimum number of channels of instrumentation operable.
BASIS U
The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated because the system will still fu,1ction as described in the FSAR.
The proposed change does not create the possibility of a new or different kind of accident previously evaluated because the system will still function as described in the FSAR.
The proposed change does not involve a significant reduction in the margin of safety because Plant Hatch does not have a gaseous retention system, and therefore, the gaseous radioactive effluent release rates through the main stack are essentially constant.
Since the flowrates are constant, an increase in the time interval of estimates is not a concern.
For the other pathways, under the worst case assumption there would be no releases through the pathway with no flow; therefore, there is no degradation of the margin of safety.
B.
PROPOSED CHANGE It is proposed to revise Unit 1 Table 4.15.2-1 and Unit 2 Table 4.11.2-1 to delete footnote
'c' from applying to tritium levels.
Footnote 'c' requires additional sampling following shutdown, startup or power level changes greater than 15% of rated thermal power.
BASIS The proposed change does not involve a significant increase i' the probability or consequences of an accident previously evaluated lacause the system will still function as described in the FSAR.
The proposed change does not create the possibility of a new or different kind of accident from accidents previously evaluated because the system will still function as described in the FSAR.
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ATTACINENT 3 GeoigiaPower h 10 CFR 50.92 Evaluation (Continued)
The proposed change does not involve a significant reduction in the margin of safety because tritium levels in BWRs are fairly low and do not significantly change during power level changes.
In addition, Regulatory Guide 1.21 only requires that the tritium concentration be determined monthly for continuous releases.
C.
PROPOSED CHANGE It is proposed to revise footnotes 'c' and
'd' of Unit 1 Table 4.15.2-1 and Unit 2 Table 4.11.2-1 so that additional monitoring is not required unless the dose equivalent iodine level increases by more than a factor of three and greater than 0.02 uCi/g.
BASIS The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated because the systems will still function as described in the FSAR.
The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated because the systems will still function as described in the FSAR.
The proposed change does not involve a significant reduction in the margin of safety because it will eliminate redundant testing of both water chemistry and plant effluents.
It is also similar to the Standard RETS for BWRs, NUREG-0473 Revision 3.
D.
PROPOSED CHANGE Footnote 'c' of Unit 1 Table 4.15.2-1 and Unit 2 4.11.2-1 will be revised to add a time limit of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for performing the analysis.
BASIS This change is similar to Item (ii) of the " Examples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the Federal Register, April ti, 1983 because it requires a time limit on performing the analysis which was not previously specified, making it a more restrictive specification.
The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated because the systems will still function as described in the FSAR.
The proposed change does not create the possibility of a new or ditferent kind of accident from any accident previously evaluated because the systems will still function as described in the FSAR, t
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A ATTACFMENT 3 GeorgiaPower BA 10 CFR 50.92 Evaluation (Cunt.inueu)
The proposed change does not involve a significant reduction in the margin of safety because it adds an additional sampling requirement.
The change is made to prevent a possible misinterpretation that the sample'should be taken at all points before the gaseous radioactive effluent in question could reasonably be expected to be available for sampling.
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Georgia Power d ATTACl!!iEt:T 4 NRC DOCKET 50-321 OPERATING LICENSE DPR-57 EDWIN I. HATCH NUCLEAR PLANT UNIT 1 REQUEST TO REVISE RADI0 ACTIVE EFFLUENT TECHNICAL SPECIFICATIONS The proposed change to Technical Specifications ( Appendix A to Operating License DPR-57) would be incorporated as follows:
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