ML20205J704

Application for Amends to Licenses NPF-2 & NPF-8, Supplementing 851209 Submittal,Proposing Administrative Tech Spec Changes Re Fire Detection Instrumentation.Significant Hazards Evaluations Encl

ML20205J704
Person / Time
Site:	Farley
Issue date:	02/18/1986
From:	Mcdonald R ALABAMA POWER CO.
To:	Rubenstein L Office of Nuclear Reactor Regulation
Shared Package
ML20205J709	List: ML20205J704 ML20205J710
References
TAC-60355, TAC-60356, NUDOCS 8602260350
Download: ML20205J704 (36)

Text

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' Ma4Hng Address -

'#. . Al;ttm3 Power Company

. 600 North 18th Street

~iT ' Post Office Box 2641 o- Birmingham Alabama 35291 Telephone 205 783-6090 R. P. Mcdonald Senior Vice President Flintridge Building Alabama Power -

February 18, 1986 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 H. Farley Nuclear Plant - Units 1 and 2 Proposed Administrative Technical Specification Changes Gentlemen:

By letter of December 9,1985, Alabama Power Company submitted proposed Administrative Technical Specification changes. During subsequent discussions with the NRC Staff, additional information to support the evaluation of these changes was requested. Attachment I contains a detailed 10CFR50.92 evaluation for each proposed technical specification change submitted in the December 9,1985 letter. Each evaluation consists of a specific review of the proposed change without reference to any previous examples given by the NRC' of changes that are considered not likely to involve significant hazards considerations.

Attachment 2 contains revised proposed changed pages for Units 1 and 2 Technical Specification pages 3/411-9 and Unit 2 Technical Specification pages 3/4 8-19 and B3/4 8-2. Each of these pages were submitted in the 4 December 9,1985 letter; however, proposed page 3/411-9 (Table 4.11-2) for ,

each unit contained an editorial error. Table notation "n" on the' Minimum Detectable Concentration of Table 4.11-2 should be notation'"h". This editorial error currently exists in only the Unit 1 Technical Specification Table 4.11-2. Additionally, the previously proposed additions to pages 3/4

.8-19 and B3/4 8-2 for periodic fuse size verificatf on are being withdrawn.

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a Mr. L. S. Rubenstein ,

February 18, 1986 U. S. Nuclear Regulatory Commission Page 2 In accordance with NRC approval for other licensees, Alabama Power Company proposes to perform the periodic fuse size verification through plant procedures. The appropriate 10CFR50.92 evaluations included in Attachment 1 for these particular pages are written to support the revised proposed changes. The Plant Operations Review Committee has reviewed this proposed change and the Nuclear Operations Review Board will review this proposed change at a future meeting. Pursuant to 10CFR170.21, the rule on license fees, the required License Amendment Application Fee of $150 was enclosed with Alabama Power Company's December 9,1985 submittal.

In accordance with 10CFR50.90, three (3) signed originals and 4r, copies of this request are enclosed. A copy of this change has been sent to Mr.

Dan Turner, the Alabama State Designee in accordance with 10CFR50.91(b)(1).

If there are any questions, please advise.

Yours truly,

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bW R. P. ficDonald RPM / JAR: dst-051 Attachments cc: Mr. L. B. Long SWORN TO AND SUBSCRIBED BEFORE ME Dr. J. N. Grace ph -L lir. E. A. Reeves THIS 0 DAY OF DMttaN ,1986 Mr. W. H. Bradford ,J Mr. Dan Turner pO,J Notary P h ic My Commission Expires: k--/[-N

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ATTACHMENT 1 Significant Hazards Evaluations Pursuant to 10CFR50.92 for Each Proposed Technical Specification Change Submitted in Alabama Power Company Letter of December 9,1985 from R. P. Mcdonald to L. S. Rubenstein of the NRC JAR: dst-051

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SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGE TO THE FNP UNITS 1 AND 2 FIRE DETECTION INSTRUENTATION TECHNICAL SPECIFICATION Proposed Change Revise Surveillance Requirement 4.3.3.9.1 to appropristely require a heat source rather than a test aerosol for testing of heat detectors If sted in Table 3.3-12.

Background

As a result of the recently completed update of the Joseph M. Farley Nuclear Plant - Units 1 and 2 Fire Protection Program Reevaluation and its representation of actual plant conditions, a clarification to the fire protection technical specifications is needed. Specification 4.3.3.9.1 currently requires an aerosol test for the detectors listed in Table 3.3-12.

However, Table 3.3-12 contains both smoke detectors and heat detectors. The heat detectors cannot use aerosol as a test means but must be functionally tested by a heat source according to design. Therefore, this change proposes to incorporate a heat soun:e, as appropriate, into the surveillance requirement in order to functionally test the heat detectors.

Analysis Alabama Power Company has reviewed the requirements of 10CFR50.92 as they relate to the proposed fire detection instrumentation technical specification change and considers this change not to involve a significant hazards consideration. In support of this conclusion, the following analysis is provided:

1) The proposed change will not increase the probability or consequences of an accident previously evaluated because the proposed change clarifies the method of functionally testin3 heat detectors in accordance with the design of the heat detectors. This change will ensure operability of fire detection instrumentation and enhance the overall fire protection program. This proposed change will not impact the design of the system nor the capability to protect safe shutdown equipment. Therefore, the probability or consequences of an accident previously evaluated. will not be increased.

2) The proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated because this change does not affect the design or operation of the system. This proposed change incorporates the correct method of testing and will ensure that system operability is maintained. Because this proposed change does not involve a change to the system but only the method of testing, this proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

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SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92

=FOR THE PROPOSED CHANGE TO THE FNP UNITS 1 AND 2 FIRE DETECTION INSTRUENTATION TECHNICAL SPECIFICATION Page z

.3) The proposed change will not involve a reduction in a margin of safety because this change will enhance system operability by appropriately testing the fire detection instrumentation. Because this instrumentation will be tested in accordance with the design, a more accurate indication of system operability will be obtained from the surveillance test. Thus, this change will not involve a reduction in a margin of safety.

Conclusion Based upon the analysis provided herewith, Alabama Power Company has determined that the proposed change to the technical specifications will not increase the probability or consequences of an accident previously evaluated, c.'eate the possibility of a new or different kind of accident from any accident previously evaluated, or involve a reduction in a margin of safety.

Therefore, Alabama Power Company has determined that the proposed change meets the requirements of 10CFR50.92(c) and does not involve a significant hazards consideration.

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SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGES TO THE FNP UNITS 1 AND 2 FIRE DETECTION INSTRUMENTATION TECHNICAL SPECIFICATIONS Proposed Change Revise Specification 3.3.3.9, Table 3.3-12 to clarify the number of smoke detectors and their location with respect to the ceiling in the control room complex, clarify the number of smoke detectors in the strainer bay of the service water structure, and correct the room numbers of the A-train and B-train battery rooms.

Background

Unit 1 (Unit 2) Table 3.3-12 lists for the control room the total number of smoke detectors above the ceiling in Room 401 (2401) as 13 (16) and the minimum number of operable smoke detectors as 7 (8). The table is misleading because the 13 (16) detectors listed are actually located in the space above the suspended ceiling of both Rooms 401 (2401) and 416 (2471), not just in Room 401 (2401). In addition, four smoke detectors have been relocated and an additional four detectors have been installed in Unit 1 in the space above the suspended ceiling of Rooms 401 and 416 to enhance the fire detection capability and clarify compliance with NFPA 72E regarding detector placement.

Thus, the installation of these detectors was perfonned to enhance the fire detection capabilities of the plant and not to comply with technical specification requirements. In order to clarify the location of the detectors in the control room complex, Table 3.3-12 should be modified to show the number of detectors above and below the suspended ceiling for all rooms in the compl ex. Therefore, a change is proposed to increase by four the total number of smoke detectors above the ceiling of the Unit 1 side of the control room and to provide an accurate breakdown of the detectors located above and below the suspended ceiling for all rooms in the Unit 1 and 2 control room complex.

Units 1 and 2 Table 3.3-12 If sts the total number of smoke detectors in Room 72A in the Strainer Bay as 12 and the minimum number of operable smoke detectors as 6. Each of the twelve installed smoke detectors are on the ceiling of the service water structure and would detect a fire anywhere in the a rea. However, six new detectors were installed under the service water pump deck strictly as an enhancement to the current fire detection capabilities.

Therefore, a change is proposed to increase the number of smoke detectors in Room 72A for the Strainer Bay from 12 to 18.

Unit 1 Table 3.3-12 currently lists Room 212 as Battery Room 1A and Room 214 as Battery Room 18. The correct descriptions should If st Room 212 as Battery Room IB and Room 214 as Battery Room 1A. Unit 2 Table 3.3-12 currently lists Room 2212 as Battery Room 1A and Room 2214 as Battery Room 18. The correct descriptions should list Room 2212 as Battery Room 28 and Room 2214 as Battery Room 2A. Thus, changes are proposed to correct these errors. These changes involve the room descriptions only and have no impact on the total number of smoke detectors or the minimun number of operable smoke detectors.

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r SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE

, PROPOSED CHANGES TO THE FNP UNITS 1 AND 2 FIRE DETECTION INSTRUENTATION TECHNICAL SPECIFICATIONS Page Z Analysis Alabama Power Company has reviewed the requirements of 10CFR50.92 as they relate to the proposed fire detection instrumentation technical specification change and considers these changes not to involve a significant hazards consideration. In support of this conclusion, the following analysis is provided:

1) The proposed changes will not increase the probability or consequences of i an accident previously evaluated because the proposed changes consist of I

editorial clarifications or increase the total number of smoke detectors.

The proposed changes either maintain or increase the number of minimum required operable smoke detectors. Thus, the fire detection system capabilities have been increased and enhanced with respect to that previously evaluated and demonstrated to be acceptable. Therefore, the probability or consequences of an accident previously evaluated will not be increased by these proposed changes.

2) The proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated because these changes involve clarifications or enhancements to the fire protection detection system, which have been previously analyzed for impact on the safe-shutdown capability of the plant in the event of a fire. Thus, these i

proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

l 3) The proposed changes will not involve a reduction in a margin of safety l

because the minimum number of required operable smoke detectors has not l

been decreased. To the contrary, the minimum number of operable smoke detectors in the control room complex has been increased which will i

provide an even higher level of confidence that the fire protection system will perform its intended function of protecting safe-shutdown equipment in the event of a fire. The other changes are editorial clarifications or fire protection system enhancements. Thus, the proposed changes will not involve a reduction in a margin of safety.

Conclusion '

Based upon the analysis provided herewith, Alabama Power Company has determined that the proposed changes to the technical specifications will not increase the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a reduction in a margin of safety.

Therefore, Alabama the requirements Power Company)has of IOCFR50.92(c determined and do not that the proposed involve a significant hazards changes mee consideration, i

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SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGE TO THE EMERGENCY

, CORE COOLING SYSTEMS TECHNICAL SPECIFICATION Proposed Change Revise Surveillance Requirement 4.5.3.2, to include a disconnect device as an acceptable means for removing power from the motor operators on the charging pump discharge valves to the reactor coolant system (RCS) hot legs.

Background

The existing specification requires that the breaker for the valve operators for the charging pump discharge valves to the reactor coolant system (RCS) hot legs be verified locked open. In accordance with commitments made to comply with NUREG-0737, provisions have been made for these valves to have a separate disconnect device installed in order to obviate the need to operate the circuit breaker in an emergency. The disconnect device is a better suited device due to its location for energizing the valve operators in an emergency than are the circuit breakers. Reference to circuit breakers needs to be retained in this specification for the RHR system valves which do not have a new disconnect device provided because these valves are not required to be operated in an emergency. Thus, a change to Specification 4.5.3.2 is proposed to include a disconnect device as a means of removing power from the motor operators on the charging pump discharge valves since the devices have already been installed to comply with NUREG-0737.

Analysis Alabama Power Company has reviewed the requirements of 10CFR50.92 as they relate to the proposed emergency core cooling systems technical specification change and considers this change not to involve a significant hazards consideration. In support of this conclusion, the following analysis is provided:

1) The proposed change will not increase the probability or consequences of an accident previously evaluated because the proposed change accomplishes the same function as required by the current specification. The valves in this specification are nonna11y closed and power to their operators removed. In an emergency, manual actions are required to restore power to the operators. Due to its location, the disconnect device is better suited for restoring power to the operators than are the circuit breakers. Therefore, the probability or consequences of an accident previously evaluated will not be increased.

2) The proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated because the current surveillance requirement ensures that, as a minimum, the assumptions used in the accident analyses are met. This proposed change does not change the requirement to ensure that power is removed from the valve operators, but accomplishes the surveillance with a different device. Thus, the surveillance requirement remains consistent with the 5

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'SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 iOR THE PROPOSED CHANGE TO THE EMERGENCY CORE COOLING SYSTEMS TECHNICAL SPECIFICATION Page 2 previously evaluated accident analyses. Therefore, this proposed change will not create the possibility of a new or different kind of accident-from any accident previously evaluated.

3) The proposed change will not involve a mduction in a margin of safety because the disconnect device will accomplish the same function as the circuit bmaker for removing power from the valve operators. In accordance with commitments made to comply with NUREG-0737 and to minimize radiation exposure, the disconnect- devices wem installed to obyf ate the need to operate the circuit breakers during an emergency. Thus, this proposed change to the technical specifications clariff es the actual plant configuration and does not represent a reduction in a margin of safety.

Conclusion Based upon the analysis provided herewith, Alabama Power Company has detemined that the proposed change to the technical specifications will not increase the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a reduction in a margin of safety.

Therefore, Alabama Power Company has determined that the proposed change meets the requirements of 10CFR50.92(c) and does not involve a.significant hazards consideration.

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SIGNIFICANT HA7.ARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGE TO THE CONTROL ROOM EERGENCY VENTILATION SYSTEM TECHNICAL SPECIFICATION Proposed Change Revise Surveillance Requiremnts 4.7.7.b and 4.7.7.e.4 to clarify that the

- pressurization system is the only control room emergency ventilation system which contains heaters.

Background

The current specification acknowledges that there are two types of systems, pressurization and recirculation, which serve the control room. The pressurization system is the only system which contains heaters. In order to clarify Technical Specification 4.7.7.b and 4.7.7.e.4, reference to the pressurization -system for heater verification is proposed by Alabama Power Company as an editorial correction to the Technical Specifications.

Analysi s Alabama Power Company has reviewed the requirements of 10CFR50.92 as they relate to the proposed control room emergency ventilation system technical specification change and considers this change not to involve a significant hazards consideration. In support of this conclusion, the following analysis is provided:

1) The proposed change will not increase the probability or consequences of an accident previously evaluated because the proposed change is only an editorial clarification and does not represent a decrease or relaxation in surveillance testing. Heaters are not required in the control room recirculation system but are required in the control room pressurization system. Therefore, the probability or consequences of an accident previously evaluated will not be increased by this proposed change to the technical specifications.

2) The proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated because thf s change is only an editorial clarification and does not involve a design change or change in the surveillance requirements. Thus, this proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

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SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGE.T0 THE CONTROL ROOM EMERGENCY VENTILATION SYSTEM TECHNICAL SPECIFICATION Page 2

3) The proposed change will not involve a reduction in a margin of safety because the same testing and surveillance requirements will be performed as previously established in order to ensure system operability. This change only clariffes the applicability of the surveillance requirement with respect to the pressurization and recirculation systems. Thus, this proposed change does not reduce a margin of eafety.

Conclusion '

Based upon the analysis provided herewith, Alabama Power Company has determined that the proposed change to the technical specifications will not increase the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a reduction in a margin of safety.

Therefore, Alabama Power Company-has determined that the proposed change meets the requirements of 10CFR50.92(c) and does not involve a significant hazards consideration.

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SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGE TO THE FIRE SUPPRESSION WATER SYSTEM TECHNICAL SPECIFICATION Proposed Change Revise Surveillance Requirement 4.7.11.1.3(c)(1) to clarify the scope of the visual inspection by removing the words " cell plates."

Background

This specification currently requires that the batteries, cell plates and battery racks of the fire pump diesel starting 24-volt battery bank be verified once per 18 months to show no visual indication of physical damage or abnomal deterioration. However, the batteries are not designed for visual inspection of cell plates. Battery casings are opaque and it is not feasibic to inspect the cell plates without destroying the integrity of the battery.

Therefore, a change to this specification is proposed for deleting the words

" cell plates" in order to clarify the scope of the visual inspection.

Analysis Alabama Power Company has reviewed the requirements of 10CFR50.92 as they relate to the proposed fire pump diesel starting battery technical specification change and considers this change not to involve a significant hazards consideration. In support of this conclusion, the following analysis ,

is provided:

1) The proposed change will not significantly increase the probability or consequences of an accident previously evaluated because the proposed change merely consists of a clarification to the visual inspection of the batteries. This inspection is perfomed once per 18 months to detect abnomal deteriorations which may have occurred but is not an actual test Battery o)erability is assured by Specification of battery (operability.

4.7.11.1.3 a)(2), which verifies t!1at minimum battery voltage requirements are met at least once per 7 days. Therefore, the probability or consequences of an accident previously evaluated will not be signiticantly increased by this proposed change.

2) The proposed change will not create the possibility of a new or different kind of accident fron any accident previously evaluated because this change is a clarification of an existing specification which does not change the purpose of the existing surveillance requirement or require any new surveillance requirements. Thus, this propcsed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

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SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGE TO THE FIRE SUPPRESSION WATER SYSTEM TECHNICAL SPECIFICATION Page 2

3) The proposed change will not involve a significant reduction in a margin of safety because the purpose of the existing specification will be maintained with this change. The battery power supply for the fire pump diesel and its associated margins of saft.ty are unchanged by this proposed change to the technical specifications.

Conclusion Based upon the analysis provided herewith, Alabama Power Company has determined that the proposed change to the technical specifications will not significantly increase the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in a margin of safety. Therefore, Alabama Power Company has detennined that the proposed change meets the requirements of 10CFR50.92(c) and does not involve a significant hazards consideration.

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r SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGE TO THE FIRE PROTECTION SPRAY AND/0R SPRINKLER SYSTEMS TECHNICAL SPECIFICATION Proposed Change Revise Table 3.7-5 (Specification 3.7.11.2) to reflect the actual plant configuration by clarification of the sprinkler system coverage provided in the service water intake structure. The sprinkler system in the service water structure is designated as a Unit 1 system, but it services both units.

Therefore, changes to both the Unit 1 and Unit 2 Technical Specifications are proposed.

Backgrotmd i

This specification lists spray and/or sprinkler systems required to be operable. Zone 72A, which is the service water pump area of the service water

! structure, currently lists sprinkler system ISW-111 in Unit 1 Technical l Specification Table 3.7-5. To enhance the coverage in this room, two new l

systems (111A and 1118) were added. As described in the Joseph M. Farley l Huclear Plant Fire Protection Program Reevaluation (FPPR), each system has i

been designated to provide suppression coverage for certain areas within Zone 72A while all three systems are activated by fire detection system ISW-111.

Thus, in order to clarify the technical specification table to be consistent with the FPPR and the plant configuration, a change is proposed to add sprinkler systems ISW-111A and ISW-1118 to Table 3.7-5 of the Farley Technical Specifications.

1 Analysis Alabama Power Company has reviewed the requirements of 10CFR50.92 as they relate to the proposed fire suppression spray and/or sprinkler system technical specification change and considers this change not to involve a significant hazards consideration. In support of this conclusion, the following analysis is provided:

1) The proposed change will not increase the probability or consequences of an accident previously evaluated because the proposed change represents an enhancement to the fire protection suppression system. Although the suppression capability was previously acceptable, the addition of two new

systems will provide a higher level of confidence that the fire protection system will protect the safe-shutdown capability of the plant in the event of a fire. Therefore, the probability or consequences of an accident previously evaluated will not be increased.

2) The proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated because the proposed change represents an enharcement to an existing system which has been provfously analyzed for accident consequences. Thus, this proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

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SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGE TO THE FIRE PROTECTION SPRAY AND/0R SPRINKLER SYSTEMS TECHNICAL SPECIFICATION Page Z

3) The proposed change will not involve a reduction in a margin of safety because this change enhances the fire protection suppression coverage in the service water intake structure. Thus, the margin of safety associated with protection of the service water system in the event of a fire will not be reduced but will rather be increased.

Conclusion Based upon the analysis provided herewith, Alabama Power Company has determined that the proposed change to the technical specifications will not significantly increase the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident fron any accident previously evaluated, or involve a significant reduction in a margin of safety. Therefore, Alabama Power Company has determined that the proposed change meets the requirements of 10CFR50.92(c) and does not involve a significant hazards consideration.

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SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGES TO THE LOW PRESSURE AND HIGH PRESSURE CO2 SYSTEMS FIRE PROTECTION TECHNICAL SPECIFICATIONS l

l Proposed Change

! Revise specifications 4.7.11.3.2(b)(2) and 4.7.11.3.3(b)(2) for low pressure and high pressure CO2 systems, respectively, to clarify flow verification during a " puff test" by removing reference to nozzles.

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Background

These specifications currently require that the low pressure and high pressure CO2 systems listed in Specification 3.7.11.3 verify, once per 18 months, flow from each nozzle during a " Puff Test." Verification of these tests is accompitshed by visual inspection. The nozzles included in these surveillance requirements, except for those in the diesel generator, day tank and cable

( spreading rooms, are located internal to switchgear panels and most of the i panels are energized when the test is required. Verification of CO2 flow through inaccessible nozzles located inside energized switchgear is performed by visually observing the CO2 discharge from the exterior of the switchgear cabinets in the general location of the inaccessible nozzles. Any other effort to physically observe CO2 discharge from the inaccessible nozzles would represent a significant potential personnel hazard. Additionally, any visual verification of flow at the inaccessible nozzle location would represent a potential source of plant transients due to personnel contact with

! the energized switchgear. It should be noted that there are no isolation l valves in the CO2 system betwoon the accessible and inaccessible nozzles and

! both accessible and inaccessible nozzles share common headers. Therefore, i

verification of flow during a " Puff Test" provides reasonable confidence that CO2 would fill the switchgear and extinguish the fire. Thus, a change is proposed to clarify how the surveillance test is performed by deleting reference to nozzles in order to preclude any interpretation which could create a personnel hazard or increase the itkelihood of unnecessary plant transients. It should be noted that the National Fire Protection Association Standard which governs CO2 extinguishing systems (12.1-11) does not require visual verification of flow through each nozzle.

Analysis Alabama Power Company has reviewed the requirements of 10CFR50.92 as they relate to the proposed CO2 systens fire protection technical specification change and considers these changes not to involve a significant hazards consideration. In support of this conclusion, the following analysis is provided:

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1) The proposed changes will not significantly increase the probability or consequences of an accident previously evaluated because the proposed changes will maintain verification of CO2 system operability and will reduce the likelihood of unnecessary plant trans'ents. The safe thutdown capabilities of the plant in the event of a fire will be maintained because the fire protection system capabilities will not be decreased.

These changes actually enhance plant safety by reducing the potential for l plant transients and unnecessary challenges to the systems important to l

plant shutdown. Therefore, the probability or consequences of an accident previously evaluated will not be increased by these proposed changes to the technical specifications.

2) The proposed changes will not create the possibility of a new or different

! kind of accident from any accident previously evaluated because the proposed changes clarify an existing surveillance requirement but do not change the purpose of the verification being performed, nor do these changes create any requirements for new surveillances. Thus, these proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated, l

1 3) The proposed changes will not involve a significant reduction in a margin of safety because the verification of CO2 flow will be accomplished, i

thus ensuring the fire protection system capabilities. Additionally, the I proposed changes will reduce the likelihood of unnecessary plant transients and thus will enhance overall plant safety. Thus, these proposed changes will not involve a significant reduction in a margin of safety.

Conclusion Based upon the analysis provided herewith, Alabama Power Company has determined that the proposed change to the technical specifications will not significantly increase the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in a margin of safety. Therefore, Alabama Power Company has detemined that the proposed changes meet the requirements of 10CFR50.92(c) and do not involve a significant hazards consideration.

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O SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGES TO THE FIRE PROTECTION

[ FIRE HOSE STATION TECHNICAL SPECIFICATION l

I Proposed Change l

! Revise Table 3.7-6 (Specification 3.7.11.4) to show the correct location of fire hose cabinets in the service water intake structure and to correct the elevation of Room 602 in the auxiliary buf1 ding.

Background

As a result of the recently completed Amendment 6 to the Joseph M. Farley

, Nuclear Plant - Units 1 and 2 Fire Protection Program Reevaluation and its

! representation of actual plant conditions, clarifications to the fire i protection technical specifications are needed. Table 3.7-6 currently lists l

two fire hose cabinets as being in Zone 72A of the service water intake structure. However, the hose cabinets are actually located just outside Zone 72A in Zones 72C and 720. Table 3.7-6 also lists Room 602 in the auxiliary butiding at elevation 139'-0", but the actual elevation of this room is 130'-0". Therefore, changes are proposed to correct the room numbers to show the actual location of the hose cabinets and to correct the elevation error.

Analysts Alabama Power Company has reviewed the requirements of 10CFR50.92 as they relate to the proposed administrative changes to the If st of fire hose stations and considers these changes not to involve a significant hazards

consideration. In support of this conclusion, the following analysis is l provided

1) The proposed changes will not significantly increase the probability or consequences of an accident previously evaluated because the proposed changes correct errors regarding the location of ff re protection system equipment, which would enhance the capabilities of plant operations and/or i fire brigade personnel in mitigating the consequences of a fire.

l Therefore, the probability or consequences of an accident previously evaluated will not be signtficantly increased.

2) The proposed changes will not create the possibillty of a new or different

, kind of accident from any accident previously evaluated because the proposed changes simply correct errors in the If sted location of fire protection equipment. Thus, these proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

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D SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGES TO THE FIRE PROTECTION FIRE HOSE STATION TECHNICAL SPECIFICATION Page 2

3) The proposed changes will not involve a significant reduction in a nargin of safety because these changes do not affect the fire protection i capability of the plant. These changes correct errors in the listed location of fire protection equipment within the technical specifications. Thus, the margins of safety associated with this fire protection equipment will not be significantly reduced by the proposed changes to the technical specifications.

Conclusion Based upon the analysis provided herewith, Alabama Power Company has determined that the proposed changes to the technical specifications will not significantly increase the probability or consequences of an accident

! previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in a margin of safety. Therefore, Alabama Power Company has determined that the proposed changes meet the requirements of 10CFR50.92(c) and do not involve a significant hazards consideration.

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P SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGE TO THE FIRE PROTECTION FIRE H0SE STATION TECHNICAL SPECIFICATION Proposed Change Add the hose station isolation valves inside containment and the hoses stored in a storage locker in the auxiliary building outside the containment entrance to Table 3.7-6 (Specification 3.7.11.4).

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Background

As a result of the recently completed Amendment 6 to the Joseph M. Farley i Nuclear Plant - Units 1 and 2 Fire Protection Program Reevaluation and its representation of actual plant conditions, a clarification to the fire protection technical specifications is needed. This change was proposed t previously in accordance with Facility Operating License NPF-2 Amendment 11, but was not incorporated into the Technical Specifications. This amendment ,

added a license condition relating to the completion of facility modifications in order to complete the fire protection program reevaluation against Appendix ,

A to Branch Technical Position APCSB 9.5-1. Amendment 11 to NPF-2 also required updated technical specifications for any completed modifications.

One of the required modifications was the installation of standpipe and hose  !

stations inside containment. This modification was coupleted and Alabama Power Company proposed to add this hose station to the Technical Specifications by letter dated January 8,1900 from F. L. Clayton, Jr. to A.

Schwencer of the NRC. Because this. change was not incomorated into the Technical Specifications as requireo, Alabama Power Company proposes a change to add this hose station to Table 3.7-6.

Analysis Alabama Power Company has reviewed the requirements of 10CFR50.92 as they relate to the proposed fire hose station list technical specification change and considers this change not to involve a significant hazards consideration.

In support of this conclusion, the following analysis is provided: i i

1) The proposed change will not significantly increase the probability or l consequences of an accident previously evaluated because the proposect change consists of an added clarification that represents an enhancement ,

to the fire protection system capabilities as currently Itsted in the '

technical specifications. This proposed change has no impact on the actual plant fire protection system capabilit' es because the hose stations, isolation valves and hoses are installed and tested for i operability per the requirements of the technical specifications. This  ;

fire protection equipment was inadvertently omitted from the technical  ;

specification list. This proposed change corrects the list. Therefore, i the 1robability or consequences of an accident previously evaluated will not w increased.

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r SIGNIFICANT HAZARDS EVAL.UATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGE TO THE FIRE PROTECTION FIRE HOSE STATION TECHNICAL SPECIFICATION

Page Z l 2) The proposed change will not create the possibility of a new or different i kind of accident from any accident previously evaluated because the proposed change does not involve any actual plant changes. This change only corrects the list of fire hose stations in the technical l specifications. Thus, this proposed change will not create the i

possibility of a new or ditferent kind of accident from any accident i

previously evaluated.

3) The proposed change will not involve a significant reduction in a margin of safety because the proposed change represents an increase in fire protection system capabilities as listed in the technical specifications but has no impact on the actual system capabilities. The margin of safety associated with these fire protection capabilities is unaffected by this editorial clarification to the technical specifications.

Conclusion Based upon the analysis provided herewith, Alabama Power Company has determined that the proposed change to the technical specifications will not significantly increase the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in a margin of safety. Therefore, Alabama Power Company has detennined that the proposed change meets the requirements of 10CFR50.92(c) and does not involve a significant hazards consideration.

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r SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGE TO THE FIRE PROTECTION YARD FIRE HYDRANTS AND HYDRANT HOSE HOUSES TECHNICAL SPECIFICATION Proposed Change Correct the valve numbers for the yard fire hydrants and associated hydrant hose houses listed in Table 3.7-7 (Specification 3.7.11.5) for the valves located east and west of the service water intake structure, l

Background

l As a result of the recently completed Amendment 6 to the Joseph M. Farley Nuclear Plant - Units 1 and 2 Fire Protection Program Reevaluation and its representation of actual plant conditions, a clarification to the fire protection technical specifications is needed. Specification 3.7.11.5, Table 3.7-7 lists valve N1Y43V121 as west of the service water intake structure and valve N1Y43V122 as east of the service water intake structure. The Unit i valves are If sted in both Units 1 and 2 Technical Specifications because the service water intake structure is common to both units. The valve numbers listed are actually reversed. Therefore, an editorial correction is proposed to list valve N1Y43V121 as east of the service water intake structure and valve N1Y43V122 as west of the service water intake structure in order to correct the existing error, l

Analysis Alabama Power Company has reviewed the requirements of 10CFR50.92 as they relate to the proposed fire protection technical specification change and considers this change not to involve a significant hazards consideration. In support of this conclusion, the following analysis is provided:

1) The proposed change will not increase the probability or consequences of an accident previously evaluated because the proposed change only corrects an editorial error in the technical specifications. The fire protection l system mitigation capabilities are unaffected by this proposed change.

Therefore, the probability or consequences of an accident previously l evaluated will not be increased.

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2) The proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated because there are no changes to the fire protection system design because of this change.

The proposed change only corrects an editorial error as if sted in the

, Technical Specifications. Thus, this proposed change will not create the i

possibility of a new or different kind of accident from any accident previously evaluated.

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SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGE TO THE FIRE PROTECTION YARD FIRE HYDRANTS AND HYDRANT HOSE HOUSES TECHNICAL SPECIFICATION Page z

3) The proposed change will not involve a reduction in a margin of safety because the design and mitigation capabilities of the fire protection system are unaffected by this proposed change. This change simply corrects an editorial error in the technical specifications. Therefore, the margfr of safety associated with this fire protection system cannot be reduced by this proposed change to the technical specifications.

Conclusion Based upon the analysis provided herewith, Alabama Power Company has determined that the proposed change to the technical specifications.will not increase the probability or consequences of an accident previously evaluated,~

create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a reduction in a margin of safety.

Therefore, Alabama Power Company has determined that the pronosed change meets the requirements of 10CFR50.92(c) and does not involve a significant hazards consideration.

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SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGES TO THE UNIT 2 CONTAINMENT PENETRATION CONDUCTOR OVERCURRENT PROTECTION DEVICES TECHNICAL SPECIFICATION Proposed Change Eliminate the periodic fuse testing requirement of Specification 4.8.3.1, renumber the surveillance requirements of Specification 3/4.8.3 due to duplication, and remove the tabular listing of overcurrent protection devices in Table 3.8-1 from the technical specifications.

Background

Alabama Power Company proposes a technical specification change to eliminate the requirement for periodic fuse testing for the containment penetration conductor overcurrent protection devices on the following bases:

1) The physical nature of fuses eliminates the need for perfonnance testing because a fuse is a passive component consisting of an electrical conductor of specified electrical properties inside a sealed container.

11) Fuses are simple, passive devices that are highly reliable. WASH 1400, the NRC Reactor Safety Study, detennined that a conservative probabigity for a single fuse failure to open on demand is 1 x 10 , which substantiates the high reliability of fuses, iii) Each installed fuse required to be operable in Modes 1-4 is backed up by another fuse or a mechanical breaker (some fuses do not have backup protection provided and the circuits containing these fuses are required to be deenergized during Modes 1-4). WASH 1400 estimates the probability of mechanical breaker is 1 x 10 gailure to open onIEEE Additionally, demand 500,for a 1977, estimates the probabigity of failure for all modes for a mechanical breaker to be 4 x 10 , and the probabilit demand for a mechanical breaker is 2 x 10 g ofThus, failure thetopopen upon of failure upon demand for two fuses in series is 1 x 10 gbabilityand the probabilitg of failure upon demand for a fuse and breaker in series is 1 x 10- in accordance with WASH 1400. Per IEEE 500, the probability would be even less. . Therefore, the probability of occurrence for a fuse failure to protect a containment penetration on demand is so low as to preclude the necessity for periodic fuse testi ng.

Alabama Power Company notes that the elimination of periodic fuse testing has been previously approved by the NRC on other plants. Additionally, the basis provided by the NRC for granting approval-of this change was that operational i experience has indicated the protection capability of current limiting fuses i does not decrease with service life, periodic fuse testing is not meaningful, and additional handling of fuses during surveillance testing may compromise fuse integrity. The NRC did, however, require appropriate plant procedures for periodic verification of correct fuse sizes. Accordingly, Alabama Power Company proposes to establish an appropriate plant procedure that will j

periodically verify correct fuse sizes are installed.

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SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGES TO THE UNIT 2 CONTAINMENT PENETRATION CONDUCTOR OVERCURRENT PROTECTION DEVICES TECHNICAL SPECIFICATION Page 2 In addition, Surveillance requirements 4.8.3.1 and 4.8.3.2 necessarily should be renumbered as 4.8.3.1.1 and 4.8.3.1.2 to avoid confusion with Surveillance Requirements 4.8.3.2 found on page 3/4 8-29 of the Unit 2 Technical Specifications.

Finally, consistent with the philosophy of NRC Generic Letter 84-13,

" Technical Specification for Snubbers", Alabama Power Company proposes that the contents of Technical Specification Table 3.8-1 be controlled in -

accordance with 10CFR50.59. This would eliminate the need for fomal License Amendment whenever minor changes are proposed to the tabular listing of overcurrent protection devices. License Amendment 34 for Unit 2 will serve as the baseline list for the Farley Unit 2 procedures.

Analysis Alabama Power Company has reviewed the requirements of 10CFR50.92 as they relate to the proposed overcurrent protection device' technical specification changes and considers these changes not to involve a significant hazards consideration. In support of this conclusion, the following analysis is provided:

1) The proposed changes will not 3fgnificantly increase the probability or consequences of an accident previously evaluated because 1) periodic fuse testing has been determined not to be meaningful for ensuring fuse operability and the elimination of. such testing will not significantly reduce the overall operability requirements of the overcurrent protection devices. Other surveillances for ensuring system operability are in place and include periodic and functional testing of. circuit breakers, integrated system functional tests using simulated automatic actuation signals, and channel calibrations; 11) the correction of incorrectly numbered surveillance requirements is strictly an editorial clarification; and 111) the removal of the . tabular listing of overcurrent protection devices from the technical specifications will eliminate the need for a formal License Amendment whenever minor changes to the table are required. Consistent with the philosophy of NP,C Generic Letter 84-13, the contents of the table would be maintained and controlled in accordance with 10CFR50.59 and the surveillance requirements will still be performed. Therefore, the probability or consequences of an accident j previously evaluated will not be increased by these proposed changes.

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SIGNIFICANT= HAZARDS EVALUATION PURSUANT TO 10CFR50.92

- FOR THE PROPOSED CHANGES TO 'THE UNIT 2 CONTAINENT PENETRATION CONOUCTOR OVERCURRENT PROTECTION DEVICES TECHNICAL SPECIFICATION Page 3

2) The proposed changes.will .not create the possibility of a new or different

kind of accident.from any accident previously evaluated because 1) the

elimination of periodic fuse testing has been detemined not to

! significant1y' reduce the likelihood of fuse operability. In addition, each overcurrent protection cin:uit fuse has a ~ backup protection device, and the failure of a fuse -has been previously analyzed;- (11) the. editorial correction of incorrectly numbered -surveillance requirements has no . impact

, on the system function or operability; and (iii) the removal of a tabular listing from the technical . specifications will be maintained and

[ controlled in accordance with other 10CFR50.59. The surveillances'will still be conducted for each item in the listing. Therefore, these proposed changes will not create.the possibility of a new or different kind of accident from any accident previously evaluated.

, 3) The proposed changes will not involve a significant reduction in a margin-of safety because (i) the elimination of periodic fuse testing will not significantly reduce the tests and surveillances required to-demonstrate

, overcurrent protection device; operability. Other:surveillances for-ensuring system operability include periodic and functional testing of 4

circuit breakers, integrated system functional. tests using simulated-automatic actuation signals, and channel calibrations. Additionally,

periodic fuse testing has been detemined not be meaningful for ensuring fuse operability; (ii) the. renumbering of incorrectly numbered surveillance requirements is strictly an editorial correction that has nothing to do with the~ purpose of the surveillances; and (iii) the removal of the tabular listing of overcurrent protection devices from the technical specifications will not significantly decrease the existing requi rements. The listing will be maintained and controlled in accordance 1

I with 10CFR50.59 and the surveillance requirements will still. be.

i perfonned. Therefore, these proposed changes to the technical

specifications will not involve a significant reduction in a margin of i safety.

Conclusion

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, Based upon the analysis provided herewith, Alabama Power Company has determined that the proposed changes to the technical specifications will not significantly increase the probability or consequences of an accident 4

previously evaluated,- create the possibility of a new or different kind of-j accident from any accident previously evaluated,' or involve 'a significant reduction in a margin of safety. Therefore, Alabama Power Company has 1 determined Lthat the proposed changes meet the requirements of 10CFR50.92(c) '

i and do not involve a significant hazards consideration.

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SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGES-T0 THE CONTAINMENT PURGE LINE AND EXHAUST FILTER TECHNICAL SPECIFICATIONS Proposed Change Revise Specification 3.9.14 for both Units 1 and 2 and Bases 3/4.6.1.7 for

- Unit 1 to reflect the 8-inch mini-purge isolation valves which are installed at Farley Nuclear Plant.

Background

The Farley Nuclear Plant, Units 1 and 2 no longer have 18-inch mini-purge isolation valves. The 18-inch valves were replaced with 8-inch valves in accordance with commitments made to the NRC Staff. . Alabama Power Company, therefore, proposes a change to these specifications to reflect the installed 8-inch mini-purge valves and to make these specifications consistent with Specification 3/4.6.1.7, which was approved in Unit 1 License Amendment 33 and Unit 2 License Amendment 34 Analysis Alabama Power Company has reviewed the requirements of 10CFR50.92 as they relate to the proposed containment purge system technical specification changes and considers these changes not to involve a significant hazards consideration. In support of this conclusion, the following analysis is provided:

1) The proposed changes will not increase the probability or ' consequences of an accident previously evaluated because the proposed changes are editorial corrections to make the Technical Specifications consistent throughout. These changes reflect commitments made to the NRC Staff which have been previously reviewed and approved by the NRC for incorporation into other specifications. Therefore, the probability or consequences of an accident previously evaluated will not be increased.

2) The proposed changes will not create the possibility.of a new or different kind of accident from any accident previously evaluated because these changes are simply editorial corrections to make these specifications consistent with other specifications that- have been previously evaluated, as well as being reviewed and approved by the NRC. Thus, these proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

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c SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92

'FOR THE PROPOSED CHANGES TO THE CONTAINMENT PURGE LINE AND EXHAUST FILTER TECHNICAL SPECIFICATIONS Page 2

3) The proposed changes will not involve a reduction in a margin of safety because they are only editorial corrections to make the Technical Specifications consistent throughout. The modification from 18-inch to 8-inch mini-purge valves was made in response to the requirements of NUREG-0737, Item II.E.4.2 and has already been incorporated in other sections of the Technical Specifications. Therefore, the proposed changes do not involve a reduction in a margin of safety.

Conclusion Based upon the analysis provided herewith, Alabama Power Company has determined that the proposed changes to the technical specifications will not increase the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a reduction in a margin of safety.

Therefore, Alabama Power Company has determined that the proposed changes meet the requirements of 10CFR50.92(c) and do not involve a significant hazards consideration.

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-e SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGES T0.THE LIQUID AND GASEOUS.

EFFLUENT RADI0 ACTIVE EFFLUENT TECHNICAL SPECIFICATIONS Proposed Changes Revise Table 4.11-1, Table notation "b" (Specification 4.11.1.1.2) and Table 4.11-2, Table Notation "i" (Specification 4.11.2.1.2) to include a~ requirement to report any discrepancies in .the development of composite samples in the semi-annual Radioactive Effluent Release Report.- Also revise Table 4.11-2'to delete reference to I-131 and other gamma emitters from the ' particulate sample gamma emitter MDC requirements and correct MDC notation "n" to notation "h".

Background

Table Notation "b" of Technical Specification Table 4.11-1 and Table Notation "i" of Technical Specification Table 4.11-2 describe the appropriate methods of-perfoming composite sampling for liquid and gaseous effluents, respectively. Alabama Power Company proposes that these: table notations be clarified to include a requirement to report any discrepancies in the development of composite samples in the Semi-annual Radioactive Effluent Release Report. This is consistent with what is required for deviations from Minimum Detectable Concentrations (MDC) as described in Table Notations "g" and "h" for Technical Specification Tables 4.11-1 and 4.11-2, respectively.

This proposed change simply provides. guidance for what action is to be taken should a discrepancy in composite sampling occur and is considered a clarification to the technical specifications.

In addition, Table Notation "g" of Technical Specification Table 4.11-2 excludes I-131 and other gamma emitters from the application of the MDC specification. Alabama Power Company therefore proposes to delete reference to I-131 and other gamma emitters from the particulate sample gamma emitter -

MDC requirements of Table 4.11-2, Item D. This proposed change is considered to be editorial and a clarification in that the parenthetical phrase in the table is inconsistent with note "g".

Table 4.11-2 contsins an editorial error on the MDC heading. The heading shows table notation "n", but no such table notation exists. The correct table notation should be "h". This proposed change is strictly an editorial correction.

Analysis Alabama Power Company has reviewed the requirements-of 10CFR50.92'as they relate to the proposed liquid and. gaseous effluent radioactive' effluent technical specification changes and considers these changes not to involve a significant hazards consideration. In support of this conclusion, the following analysis is provided:

1) The proposed changes will' not significantly increase the probability or consequences of an accident previously evaluated because the proposed changes are editorial clarifications and enhancements to the technical specifications which will eliminate any potential for confusion and ensure appropriate reporting requirements are maintained. Additionally, the 26

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SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGES TO THE LIQUID AND GASEOUS- ~'

l EFFLUENT-RADIOACTIVE EFFLUENT TECHNICAL SPECIFICATIONS Page Z radioactive effluent reporting requirements are for nonnal operating releases that are conservatively bounded by the calculated accident analysis releases which have been demonstrated to be well. within the acceptable limits established by the NRC. Therefore, the probability or consequences of an accident previously evaluated will not be increased by these proposed changes.

2) The proposed changes will not create the possibility 'of a new or different '

kind of accident from any accident previously evaluated because these changes are editorial clarifications and enhancements to the . technical specifications. Therefore, these proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3) The proposed changes will not involve a significant reduction in a margin of safety because the changes are editorial clarifications and enhancements to the technical specifications which will eliminate any potential for confusion and ensure the appropriate reporting requirements are maintained. Since these changes are editorial clarifications and enhancements,_ the margins of safety associated with these specifications will not be reduced.

Conclusion Based upon the analysis provided herewith, Alabama Power Company has .

determined that the proposed changes to the technical specifications will not significantly increase the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant redu tion in a margin of safety. Therefore, Alabama Power Company has .

detecmined that the proposed changes meet the requirements of 10CFR50.92(c) and do not involve a significant hazards consideration.

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SIGNIFICANT HAZARDS EVALUATION PURSUANT.TO 10CFR50.92 FOR THE PROPOSED CHANGES TO THE GASEOUS AND LIQUID

' EFFLUENT SITE. BOUNDARY MAPS TECHNICAL SPECIFICATIONS Proposed Change Revise Figures 5.1-3 and 5.1-4 (Specifications 5.1.3 and 5.1.4, respectively) to show the completed Training / EOF Center.

Background

The existing Technical Specification figures reflect the Training / EOF Center as not complete. The Training / EOF Center is complete. Thus, a change js

-proposed to revise these figures to reflect the completion of the Training / EOF Center.

Analysis Alabama Power Company has reviewed the requirements of 10CFR50.92 as they relate to the proposed gaseous and liquid effluent site boundary maps technical specification changes and considers these changes not to involve a significant hazards consideration. In support of this conclusion, the following analysis is provided:

1) The proposed changes will not increase the probability or consequences of an accident previously evaluated because the proposed changes simply update the site boundary maps to reflect the existing structures on the site boundary. These proposed changes have no impact on the definition of the site boundary or the function of the Training / EOF Center. Therefore, the probability or consequences of an accident previously evaluated will not be increased.

2) The proposed changes will not create the possibility of _a new or different kind of accident from any accident previously evaluated because the proposed changes reflect the completion of the Training / EOF Center on the site boundary maps but have nothing to do with the function of the Center or the definition of the site boundary. These proposed changes are strictly editorial corrections to the maps. Thus, these proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

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1 SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGES TO THE GASEOUS AND LIQUID EFFLUENT' i SITE BOUNDARY MAPS TECHNICAL SPECIFICATIONS

- Page 2 i

3) The proposed changes will not involve a reduction in a margin o'f' safety because these changes-update the site boundary maps to reflect the 4

completed Training / EOF Center and do not involve any changes associated with~ the definition of the site boundary or the function of the Center.

Therefore, these proposed changes will not. involve a reduction in a margin of safety.

l Conclusion Based upon the analysis provided herewith, Alabama Power Company has .

-determined that the proposed changes to the technical specifications will not

, increase the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any l

accident previously evaluated, or involve a reduction in a margin of safety. '

Therefore, Alabama Power Company has determined that the proposed changes meet

the _ requirements of 10CFR50.92(c) and do not inv'olve a significant hazards consideration.

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4 SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGE TO THE MONTHLY OPERATING REPORT ADMINISTRATIVE CONTROLS TECHNICAL SPECIFICATION Proposed Change Revise Specification 6.9.1.10 to require that routine reports of operating statistics and shutdown experience be submitted to the Director, Office of Resource Management.

Background

As a result of NRC Management changes, the existing Technical Specification reference to the Director, Office of Management Program Analysis is inappropriate. Alabama Power Company, after consultation with the NRC staff, proposes to revise the reference to Director, Office of Resource Management.

This is considered to be an editorial correction.

Analysis Alabama Power Company has reviewed the requirements of 10CFR50.92 as they relate to the proposed monthly operating report administrative controls technical specification change and considers this change not to involve a significant hazards consideration. In support of this conclusion, the following analysis is provided:

1) The proposed change will not increase the probability or consequences of an accident previously evaluated because the proposed change incorporates the appropriate NRC office for submittal of operating reports as a result of recent NRC reorganization. Therefore, the probability or consequences of an accident previously evaluated will not be increased.

2) The proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated because the monthly operating report consists of normal operating statistics and shutdown experience, and changing the office at NRC to which these reports are submitted has no potential to create a new or different accident.

Thus, this proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3) The proposed change will not involve a reduction in a margin of safety because it is a change that was necessitated by recent NRC management changes. Thus, this change will not involve a reduction in a margin of safety.

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'SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGE TO THE MONTHLY- OPERATING REPORT ADMINISTRATIVE CONTROLS TECHNICAL SPECIFICATION Page Z Conclusion Based upon the analysis provided herewith, Alabama Power Company has-determined that the proposed change to the: technical specifications will not increase the probability or consequences of an accident. previously evaluated, 3 create the possibility of a new or different kind of accident from any.

l' accident previously evaluated, or involve a reduction in a margin of safety.

Therefore, Alabama Power Company has determined that the proposed change meets

the requirements of 10CFR50.92(c) and does -not involve a significant hazards 1 - consideration. -

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SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR$0.92 FOR THE PROPOSED CHANGE TO THE RECORD RETENTION ADMINISTRATIVE CONTROLS TECHNICAL SPECIFICATION Proposed Change Revise Specification 6.10.2.1 to require the retention of safety-related quality assurance records that are required by the Operations Quality Assurance Policy Manual but are currently not specifically described in Specification 6.10.1.

Background

Technical Specification 6.10.2 describes the records which must be retained for the life of the Unit Operating License. Technical Specification 6.10.1 describes the records which need be retained for only 5 years. Ambiguity exists in that the Operations Quality Assurance Policy Manual (0QAPM) covers (among other things) activities which are specifically described as requiring 5-year record retention, but Specification 6.10.2.1 currently implies that all quality assurance records addressed in the OQAPM should be retained for the life of the Operating License. Alabama Power Company, after consultation with the NRC Staff, proposes a change to clarify Specification 6.10.2.1 to require the retention of safety-related quality assurance records that are required by the 0QAPM but are currently not specifically described in Specification 6.10.1.

Analysis Alabama Power Company has reviewed the requirements of 10CFR50.92 as they relate to the proposed record retention administrative controls technical specification change and considers this change not to involve a signPicant hazards consideration. In support of this conclusion, the following analysis is provided:

1) The proposed change will not increase the probability or consequences of an accident previously evaluated because the proposed change merely clarifies an ambiguity between two record retention specifications for safety-related quality assurance records. Since this proposed change does not decrease the requirements for storage of records but clarifies the applicability of two specifications, this change will not increase the probability or consequences of an accident previously evaluated.

2) The proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated because this proposed change is a clarification of existing specifications that does not decrease the requirements for records storage below those previously established as acceptable to the NRC. Thus, this proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

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m SIGNIFICANT HAZARDS EVALUATION PURSUANT TO 10CFR50.92 FOR THE PROPOSED CHANGE TO THE RECORD RETENTION ADMINISTRATIVE CONTROLS TECHNICAL SPECIFICATION Page Z

-3) The proposed change will not involve a reduction in a margin of safety because this change is a clarification of existing requirements that were apparently conflicting. This proposed change will ensure that.the requirements for retention of safety-related quality assurance records are clear and unambiguous in the Technical Specifications, and thus does not involve a reduction in a margin of safety.

Conclusion Based upon the analysis provided herewith, Alabama Power Company has determined that the proposed change to the tecnnical specifications will not increase the probability o'r consequences of an accident previously evaluated, citate the possibility of a new or different kind of accident from any accident previously evaluated, or involve a reduction in a margin of safety.

Therefore, Alabama Power Company has determined that the proposed change meets the requirements of 10CFR50.92(c) and does not involve a significant hazards consideration.

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