ML20205T001
| ML20205T001 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/23/1998 |
| From: | SOUTHERN NUCLEAR OPERATING CO. |
| To: | |
| Shared Package | |
| ML20205S953 | List: |
| References | |
| FNP--M-11, FNP-0-M-011, NUDOCS 9904270109 | |
| Download: ML20205T001 (30) | |
Text
12/17/98 11:26:55 FNP-0-AP-1 FIGURE 1 PROCEDURE REQUEST FORM (PRF)
[
(1)
FNP-0-M-011 16 Procedure Nurnber Current Reviilon Procedure
Title:
Offsite Dose Calculation Manual O New E Revision #
17 O Deletion E Safety Related O Non-Safety Related O Infrequently Performed Test or Evolution (2)
Description of Change (s) and Page Number (s) Affected: Table 2-3 p.2-9: added superscript d above Turbine Buildine Sump Grab Sample: Table 2-3 p.2-10: added notation d.
Reason for change: These channes are beine made to the ODCM to make it consistent with the recent chanees to the FSAR (ABN-98-0-1258) relative to sampline the Turbine Buildine Sump.
These channes are consistent with definitions already provided in the ODCM.
- - A 'F T% f N (3)
Prepared by:
Mw
[9B spad s e-oh, (4) 10CFR 50.59 and if applicable 50.54(q), or 50.54(p) Review Form attached:
E Yes Environmental Evaluation Determination was Required (if yes, attach Figure 4):
O Yes E No Commitment Update Required (if yes, attach Figure 5):
0 Yes E No PORC review required (AP-2 or Safety Evaluation)
E Yes O No Licensing Document Chan a Re uest Required (ifyes, complete AP-98):
E Yes O No Reviewed By:
b
//</7 7/
( p,..
u.a (5)
Cross-Disciplinary Review:
Group Sienature Title Date PORC Review:
/
M*/f'98 (6)
Final Approval O
Group Supervisor
/
O Manager
/
O MSAER
/
O Vice President -Project
/
O 31
/
Nuclear Plant General Manager M///8C
/ /4/A3/f[.
~ ~ ' kkaturt
- Dad f\\
Page1of1 Revision 38 PDR ADOCK 05000348
,9 0(
R PDR
I1/13/98 10:01:55 2
FNP-0-AP-98 RTYPE A6.35 FIGURE 1 O)
(.
FARLEY NUCLEAR PLANT LICENSING DOCUMENT CHANGE REQUEST LDCR NO: #J 8- 0 4 i FS TOTAL ATTACHMENTS l
SHEET I OF: 2 SECTION I.:
Preparer: Ed Carmack Date: Il 13-98 Licensing Document: FSAR and ODCM i
Change
Description:
Revise FSAR section 11.4.2.4.f and FSAR table 11.4-6 and FSAR-3A to incorporate chances to the samole procedure and freauency for the turbme buildine sumn.
Reason for Change: The change is made to accurately describe the sampling of the turbine building sump during and j
prior to release, ABN 98-0Mpr ides the FSAR changes, The ODCM changes are attached.
lag l
SECTION 11: Does this change:
l.
l l Yes l x l No Require a change to the: (Identify which)
O Operating License O TechnicalSpecifications O Environmental Protection Plan if the answer to question (1) is yes, perform a 10 CFR 50.92 evaluation. NRC approval will be required prior to implementation of this change.
2.
l lYes l x l No Require a change to the Quality Assurance Program (FS AR 17.2)?
If the answer to question (2) is yes, perform a 10 CFR 50.54(a) evaluation. NRC approval may be required prior to implementation of this change. Changes to the FSAR 17.2 also require a 10CFR50.59 evaluation. By reference, items in FSAR Section 3A may also be considered a$s part ofJthe Qbf S& M l5 5 j ytUt /.2.1 5 n d /c g/dw R
m ff6 7At $l[< f W d n d 5 2t N.
/
~n>
3.
l l Yes l x l No Require a change to any of the following: (Identify which)
O Security Plan (contains Contingency Plan)
O Security Personnel Training and Qualification Plan If the answer to question (3) is yes, perform a 10 CFR 50.54(p) evaluation. NRC approval may be required prior to implementation of this change.
4.
l l Yes l x l No Require a change to the Emergency Plan?
If the answer to question (4) is yes, perform a 10 CFR 50.54(q) evaluation. NRC approval may be required prior to imp lementation of this change.
OV Page1of2 Revision 2
I1/13/98 10:01:55 FNP-0-AP-98 RTYPE A6.35 FIGURE 1 O
5.
3 Yes No Require a change to: (Identify which) The FSAR and ODCM O the plant as described in the FSAR or requires a O Technical Specification Bases revision or an addition to the FSAR O TechnicalRequirementsManual bcumes as aesenbed in the FSAR3 (TRM)(when issued)
O involve a test or experiment not described O Pressure Temperature Limits in the FSAR_
Report (PTLR)(when issued)
{
Cu Offsite Dose Calculation Manual (ODCMD D Core Operating Limits Report O Process Control Program (PCP)
(COLR)
O Fire Hazard Analysis (FHA)(part of FSAR)
If the answer to question (5) is yes, perform: (Identify which) ka complete 10 CFR 50.59 evaluation.
O a 10 CFR 50.59 screening for editorial changes. (Refer to FNP-0-AP-88) 6.
Constitute a matter which could result in adverse environmental impact (either direct or indirect)? Check (a) or (b),
a.
x No The nature or this matter is such that it will not produce conditions which could result in adverse environmentalimpact. 54 M'" ~#a#***k / b5 " "' ' * N ' d*P l
b.
Possibly (Explain Briefly):
Y Ifitem (b) is checked, this matter must be referred to Southem Nuclear-Environmental Services for preparation of an Environmental Evaluation.
j SECTION 111 Based on the evaluations performed for this change, is NRC approval required prior to p
e implementation of this change?
O Yes j
x No Based on the evaluations performed for this change, is a PORC review required prior to e
implementation of th' han e?
X yes o
LDCR Preparer:
M Date: /Ob LDCR Review:
Date: 8-f i fSi Group:C ate:
ll
- l8 Cross Disciplinary Review:
~
()
()
Cross Disciplinary Review:
Group:
Date:
FNP Responsible Dept. Manager:
dM Date: /.2 ~ / O N LDCR Coordinator:
Date: l A- / 5 -M SECTION IV PORC Review: Date: / 2 -ir-1F PORC Meeting No. 3d/
SECTION V Follow-up Action:(if required)
Change Implemented: Document No. & Rev.:
Closed By-Date:
Page 2 of 2 Revision 2
GO-NG-42 FIGURE 1 1
FARLEY NUCLEAR SUPPORT 10 CFR 50.59 EVALUATION SHEET I
OF 7
A Unit
[] One
[] Two
[x] Shared:
Evaluation Revision Number:
Number:
Document Number: Offsite Dose Calculation Manual Revision or "IEN Nurrber: J6 h FNP-0-M-011 B
10 CFR 50.59 SCREENING r1
~
Does the document to which this evaluation applies represent:
1.
[] Yes
[x] No A change to the plant as described in the FSAR, or will this change require a revision or an addition to some portion of the PSAR7 Basis for Answer:
This change provides a change to the sample frequency for the Turbine Buildirag Sump sampling frequency described in Table 2 3 of the Offsite Dose Calculation Manual. 'Ihe PSAR changes associated with this activity were addressed in the safety evaluation for ABN 98-0-1258 and consisted of changes to the text in FSAR Section 11.4.2.4.F. FSAR Table 11.4-6 and FSAR-3A, Regulatory Guide 1.21 (Item #1).
2.
[x] Yes
[] No A change to the procedures described in the FSAR7 Basis for Answer:
'Ihis change provides a change to the sampling frequency for the Turbine Building f
Sump described in Table 2-3 of the Offsite Dose Calculation Manual. Since the 1
ODCM is referenced in the FSAR, the propowl change to the sampling frequency is I
considered a change to procedures described in the FSAR.
3.
[] Yes
[x] No A test or experiment not described in the PSAR7 Basis for Answer:
The proposed activity consists of text changes to the Offsite Dose Calculation Manual that provide a change to the sampling frequency for the Turbine Building Sump. The proposed activity is a routine verification that does not involve placing the plant in any non-previously analyzed condition.
i i
Rev.5
wm, GO-NG-42 FIGURE 1 (Continued)
O FAR12Y NUCLEAR SUPPORT 10 CFR 50.59 EVALUATION SHEET 2
OF 7
B 4.
[] Yes
[x] No A change to the Technical Specific.tions and/or Environmental Protection Plan incoiW in the operating license?
Basis for Answer:
Technical Specification 6.8.3.e(iii) requires a program be contained in the Offsite Dose Calculation Manual to provide for sampling and analysis ofliquid and gaseous effluents. This proposed activity provides for a change to the sampling frequency for radioactive effluents from the Turbine Building Sump as described in Table 2-3 of the Offsite Dose Calculation Manual. *Ihis ODCM change does not invalidate the programmatic requirements of Technical Specification 6.8.3.e(iii). The Environmental Protection Plan (non-radiological) is not affected by this proposed change.
If ANY of the four questions in Section B are answered "Yes", then PORC review of the safety evaluation is required prior to implementation and a change to a licensed document is indicated. Refer to FNP-0-AP-98.
Preparer:
h *-
Date:#/Af/f/ ReviewedBy:
Date:
8#
Reviewer:
Date: // 2 ff Reviewed By:
1 Date:Md*N
~
Reviewed By:
Date: ID-E-M Approved By:
Date:
(>
u
\\
Reviewed By:
Date:
FNP Approved:
d&/
Date: /WM j
Reviewed By:
Date:
PORC Revie Date: /M/IIIf Reviewed By:
Date:
NORB Review:
Date:
y A 4w.on g m w A '4 hk -osus p% do e nabe.n % 4 n
ng
.a. e.o.bawa n. WM
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oG Rev.5
mm GO-NG-42 FIGURE 2 FARLEY NUCLEAR SUPPORT SAFETY EVALUATION SHEET 3
OF
~1 SAFETY EVALUATION:
D 1.
[] Yes
[x] No May the proposed activity increase the probability of occurrence of an accident previously evaluated in the FSAR7 Basis for Answer:
The proposed changes to the Offsite Dose Calculation Manual (ODCM) involves the sampling frequency for the Turbine Building Sump. "Ihe proposed activity does not involve physical changes to the plant nor changes to instrument setpoints or operating p i
- s. The proposed activity will not degrade the ability of any system, structure or component to perform its designated func' ion. Therefore, the proposed activity will not increase the probability of occurrence of an accident previously evaluated in the FSAR.
2.
[] Yes
[x] No May the proposed activity increase the consequences of an accident previously evaluated in the FSAR7 Basis for Answer:
The proposed changes to the ODCM involve the sampling frequency for the Turbine Building Sump. The proposed activity does not cause changes in the processing of radiological effluents. The proposed changes will not alter any conditions or assumptions on which the PSAR accident analyses are based nor will they affect a structure or component which is required to mitigate the consequences of an accident.
Therefore, the proposed changes will not increase the consequences of an accident previously evaluated in the FSAR.
3.
[] Yes
[x] No May the proposed activity increase the probability of occurrence of a malfunction of equipment important to safety previously evaluated in the l
FSAR7 Basis for Answer:
'Ihe proposed changes to the ODCM involve the sampling frequency for the Turbine Building Sump. The proposed changes do not change the way safety-related equipment is operated or maintained. The proposed activity will not introduce any new system interaction or adversely impact the reliability of any equipment important to safety. The proposed activity will not degrade the ability of any systein, structure or component to perform the safety functions described in the FSAR. Therefore, the proposed changes will not increase the probability of occurrence of a malfunction of equipment important to safety previously evaluated in the FSAR.
\\
Rev.5
m,_.
GO-NG-42 FIGURE 2 (Continued)
FARLEY NUCLEAR SUPPORT SAFETY EVALUATION SHEET 4
OF 7
l D
4.
[] Yes
[x] No May the proposcJ activity increase the consequences of a malfunction of
. equipment important to safety previously evaluated in the FSAR?
t Basis for Answer:
The pioposed changes to the ODCM involve the sampling frequency for the Turbine Building Sump. De proposed changes do not change the processing of radiological effluents. The proposed changes do not change any conditions or assumptions previously nade in evaluating the consequences of a malfunction of equipment important so safety as discussed in the FSAR, nor will they affect any structure, system or component which is required to mitigate the radiological consequences of an accident. Thus, the pioposed changes to the ODCM will not increase the consequences of a malfunction of safety-related equipment previously evaluated in the FSAR.
5.
[] Yes [x] No May the proposed activity create the possibility of an accident of a different type than any previously evaluated in the PSAR?
Basis for Answer:
The proposed changes to the ODCM involve sampling frequency for the Turbine Building Sump. De proposed changes do not involve any physical changes to the plant or to the way in which any system, structure or component is operated or maintained. Consequent y, the proposed changes do not introduce a different l
type of failure or make any existing failure probability more credible. Therefore, the proposed changes will not create the possibility of an accident of a diffeient i
type than any previously evaluated in the FSAR.
l 6.
[] Yes [x] No May the proposed activity create the possibility of a malfunctions of equipment important to safety of a different type than any previously evaluatedin the FSAR7 Basis for Answer:
ne proposed changes to the ODCM involve sampling frequency for the Turbine Building Sump. De proposed changes do not result in any new system interactions or change the way in which any system, structure or component is operated or maintained. The proposed changes do not introduce any new failure modes or limiting single failures. Derefore, the proposed changes will not create the possibility of a malfunction of equipment important to safety of a different type than any previously evaluated in the FSAR.
1 Rev.5 t
1
GO-NG-42 FIGURE 2 (Continued)
FARLEY NUCLEAR SUPPORT SAFETY EVALUATION SHEET 5
OF 7
D 7.
[] Yes
[x] No Does the proposed activity reduce the margin of safety as defined in the basis for any Technical Specification?
Basis for Answer:
The proposed changes to the ODCM involve the sampling frequency for the Turbine Building Sump. The proposed changes will not adversely impact the availability or capability of any system, structure or component that is governed by or required to be operational in the Technical Specifications. The programmatic requirements of Technical Specification 6.8.3.e(iii) will continue to remain valid. Therefore, the proposed changes will not reduce the margin of safety as defined in tim basis for any Technical Specification.
s If the answer to ANY of the seven questions in Section D is "Yes", an unreviewed safety question may be Indicated. Approval from the NRC is required before the document / activity may be implemented.
\\
Rev.5
m.
GO-NG-42 l
FIGURE 3 O
i 10 CFR 50.59 SAFETY EVALUATION WRUTEN DESCRIPTION SHEET 6
OF 7
E Unit Number:
[] One
[] Two
[x] Shared Document Number: Offsite Dose Calculation Manual Revision or TCN Number:36 FNP-0-M-011
/1 References.
NRC Regulatory Guide 1.21 (Safety Guide 21) " Measuring and Reporting of Effluents from Nuclear Power Plants,"
12/29n1.
NRC NUREG-0800 " Standard Review Plan" Revision 3, July 1981.
NRC NUREG-1301 "Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Pressurized Water Reactors," April 1991.
Justification:
NRC NUREG-1301 "Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Pressurized Water Reactors" provides in the notations to Table 4.11 1 " Radioactive IJguid Waste Sampling and Analysis Program" definitions for batch release, composite sample and continuous release. The definitions are as follows:
A batch release is the discharge ofliquid wastes of a discrete volume. Prior to sampling for analyses, each batch shall be isolated, g
and then thoroughly mixed by a rnethod described in the ODCM to assure representative sampling.
(
A composite sample is one in which the quantity ofliquid sampled is proportional to the quantity ofliquid waste discharged and in which the methad of samphng employed results in a specimen that is representative of the liquids released.
A continuous release is the discharge oflicp d wastes of a nondiscrete volume, e.g., from a volume of a system that has an input ti flow during the continuous release.
Sy these definitions, release of any volume that is not discrete is categorized as a continuous release even though flow from the release point may be continual (intermittent) rather than continuous.
1 NRC NUREG-0800 " Standard Review Plan" Section 11.5 " Process and Effluent Radiological Monitoring lastrumentation and Sampling Systems" recognizes the different characteristics of liquid waste systems and presents acceptable methods of assuring representative samples from these different systems, as follows: :
For liquid - ;
- tanks, or " batch" releases, an acceptable method for assuring representative samples is to recirculate the tank contents, prior to sampling, at lease two tank volumes with a pump capable or recirculating two tank volumes in less than eight hours.
For continuous releases one acceptable option is to obtain samples using a continuous sampling system that collects at a sample ratt,,)roportional to the effluent release rate. Alternatively, a periodic automatic grab sampling system that collects a fixed volume of a sample at a rate proportional to the rate of effluent release may be used.
A further option is given for " continuous" releases that are actually intermittent (or continual) rather than truly continuous. These sampling systems should be designed to automatically take samples whenever there is flow in the effluent stream.
Section 11.5 of NUREG-0800 goes on to say that for all of the samples collected as discussed above, a periodic analysis frequency for the collected samples should be specified in the technical specifications (now, for radiological effluents, in the ODCM).
C Rev.5
~~.-
GO-NG-42 FIGURE 3 (Continued)
L 10 CFR 50.59 SAFETY EVALUATION WRTITEN DESCRIFi1ON SHEET 7
OF 7 For the FNP hrbine Building Sump, normally the sump is not isolated and there can be flow into the sump at any time. When the liquid in the sump reaches a certain level, the sump pump starts and discharges the contents into the Service Water discharge line for release to the environment. At the same time the sump pump starts, an automatic sampler that collects samples from the sump discharge also starts. De automatic sampler collects aliquots from the sump discharge at selected intervals, which results in a collected sample proportional to the volume released.
This method of sampling is consistent with NUREG-0800 in that it follows closely the method described above for obtaining representative samples from continual (intermittent) releases. Collected samples are combined into weekly composites for analysis, consistent with NUREG-1301.
When FNP ODCM General Revision 13, effective date January 1,1994, was developed under provisions of NRC Generic Letter 89 01, definitions of batch release, composite sample and continuous release were incorporated into the FNP CDCM consistent with the deGnitions presented in NUREG-1301. At the time of development of General Revision 13,it was recognized that releases from the Turbine Building sump were consistent with the definition of continuous release as stated in NUREG-1301. Also, the method used for sample collection and analysis was consistent with the definition of composite sample from NUREG-1301. Derefore, the hrbine Buildmg sump was listed in Table 2-3 " Radioactive liquid Waste Sampling and Analysis Program" as a continuous release with sample analyses to be performed on weeltly composite samples. Further, releases from the hrbine Building sump were described in the FNP ODCM, General Revision 13, Section 2.2 as follows: "One potential release pathway, the hrbine Building Sump discharge,is not monitored during release, but is sampled regularly during discharges." liowever, the sampling frequency notation that should have been included in Table 2-3 to reflect the sampling methodolgy described in Section 2.2 was inadvertendy omitted.
His proposed change to the ODC)1 Wil modify the table notation of Table 2-3 to state clearly the sampling frequency consistent with NUREG-0800, NUREG-1301 sA Regulatory Guide 1.21.
1 I
i Rev.5
l FNP-0-M-011 O
October'29, 1998 Revision 17
' SOUTHERN NUCLEAR OPERATING COMPANY JOSEPH M. FARLEY NUCLEAR PLANT l
FNP-0-M-011 OFFSITE DOSE CALCULATION MANUAL
~
S A
PROCEDURE USAGE REQUIREMENTS-per FNP-0-AP-6 SECTIONS F
E Continuous Use T
Y Refert.nce Use Information Use.
ALL
'E-L A
T E
UNCONTROLLED COPY n
Approved:.
CAUTION: m.=py w =< m.ni-aea cunent. Do not use in a Salsey Related Actway Nu61 ear Plant -_ General Manager
~
Date Issued: /b'N List of Effective Paaes Page Rev.
i to vii, 2-1 to 2-8, 2-11 to 4-3, 4-5 to 4-9, 4-11 to 4-12, 4-15 to 4-16, 4-18 to 7-1, 7-3 to 10-1, 10-8 13 4-17 14 viii,'4-10, 72 15 1-1, 4-4, 4-13 to 4-14, 10-2 to 10-7 16 2-9 to 2-10 17 V
Intracompany Correspondence O
A NEL-98-0286 DATE:
August 3, 1998 RE:
ABN 98-0-1258 Turbine Building Sump Sampling FROM:
M. J Ajluni TO:
W. C. Carr As the result of a resiew it was deternuned that the subject ABN will require a change to the Farley ODCM. Please prepare the change along with the associated 50.59 safety evaluation.
EWC:maf abntur. doc Attachments cc:
D. A. Hostetter - w/ Attachment J. W. Bryan - w/o Attachmet O
O
[
r Dormady, William N.
From:
Bryan, James Quitman Sent:
Tuesday, July 21,199811:02 AM i
(~}Tc:
Dormady, William N.; Wehrenberg, James A.
VCc:
Welliver, Donald E.; Clowers, Donald J.
l Sut$ect:
FW ABN 98-0-1258, Rev. 0 - FSAR Changes After reviewing the followin,g purposed changes to the FSAR document, I am in agreement with these words for the changes. They are in keeping with the Reg. Guide 1.21 document and are the correct statements as to Chemistry current procedures at FNP. Thanks Jim Bryan l
l l am preparing the 10 CFR 50.59 Evaluation for ABN 98-0-1258. Rev. O, and would like to recommend the following additional information to be added to the text for the above ABN:
- 1. As noted in the existing ABN a portion if the existing text in FSAR section 11.4.2.F reads: "will be grab sampled and analyzed prior to its discharge."
Recommend: "will be grab sampled for composite prior to or during its discharge in conformance with the Reg. Guide 1.21.".
- 2. As noted in the existing ABN the text in FSAR table 11.4-6 Sheet 1 of 2 (Sample Frequency) reads " Grab sample prior to release" Recommend: " Grab sample prior to or during release"
- 3. Revise FSAR-3A Regulatory Guide 1.21 (Measuring and Reporting of Effluents from Nuclear Power Plants) The text in item No.1 reads " Grab samples are taken and analyzed for es::h batch released."
Recommend: " Grab samples are taken for composite prior to or during its discharge for each batch released."
g,4 g eu m g,h)T Fo r.
4 6N T f 12 SF,- A 6 V, 0 O
1
~
10 CFR 50.59 EVALUATION Farley Nuclear Plant 50.59 evisio :
Page 1 of 7
$ NY ll /S Activity No. ABN 98-0-1258 Rev.: 0 Unit: 1&2 ABN Response: Rev. O Responsible Organization:
SCS l X l BPC l l
Site l l
Other l l
J A. ACTIVITY
SUMMARY
Background:
The text in FSAR section 11.4.2.4.F (Turbine Building Sump Release Procedure) reads as follows: "There are two collection sumps located in each turbine building, each having a 30,000-gal capacity and isolated from each other. The radiation activity levels in these sumps are expected to be minimal.
Each sump is provided with recirculation capability and will be grab sampled and analyzed prior to its discharge". Plant personnel requested a change to a portion of the text in this procedure to revise the sample frequency of the Turbine Building sump.
==
Description:==
This ABN revises the following:
(
- 1) The text in FSAR section 11.4.2.4.F (Turbine Building Sump Release Procedure). The text in this section will be revised from "Each sump is I
provided with a recirculation capability and will be grab sampled and analyzed prior to its discharge" to read "Each sump is provided with a recirculation capability and will be grab sampled for composite prior to or during its discharge in conformance with Regulatory Guide 1.21".
- 2) The sample frequency for the Turbine building sump in FSAR Table 11.4-J 6, Sheet 1 of 2. This text is revised from " Grab sample prior to release" to read
{
" Grab sample prior to or during release".
- 3) The text in FSAR -3 A, Regulatory Guide 1.21, (Item #1). This text is
]
revised from " Grab samples are taken and analyzed for each batch released" to i
read " Grab samples are taken for composite prior to or during its discharge for each batch released".
The FSAR mark-ups illustrating the proposed changes are includedwith this safety evaluation.
l O
10 CFR 50.59 EVALUATION Farley Nuclear Plant 50.59 Revision:
Page 2 of 7 Activity No. ABN 98-0-1258 Rev.: 0 Unit: 1&2 ABN Response: Rev. O Responsible Organization:
SCS l X ]
BPCl l
Site l l
Other l l
Reference:
FSAR, Rev.14 - Section 11.4.2.4.F - Turbine Building Sump Release Procedure FSAR, Rev.14 - Table 11.4-6 (Sheet I of 2) Effluent Sample & Analysis Schedule FSAR, Rev.14 - Section 3A Conformance with NRC Regulatory Guides Unit 1 Tech. Specs., amendment 136 - Sections 3/4.6,3/4.7 & Appendix B Unit 2 Tech. Specs., amendment 129 - Sections 3/4.6,3/4.7 & Appendix B U.S. Atomic Energy Commission Regulatory Guide 1.21, Dec.1971 Memo (
Subject:
ABN 98-0-1258, Rev. 0 - FSAR Changes) from James Q. Bryan (FNP) to William N. Dormady (SCS) dated 7/21/98 FNP-0-M-011 - Offsite Dose Calculation Manual Prepared By:
g{ g M.
7-2. l-7 ff Reviewed By:
[g [h 7 -z./ - 16 Nuclear Support Review: /
72/ M Date:
Approved By:
gg],My 7 -M-T "I*
FNP Approval:
g%
/ /tifff PORC Approval:
ate:
~
jyjg NORB Approval:
O
~
~
le CFR 50.59 EVALUATION Farley Nuclear Plant 50.59 Revision:
Page 3 of 7 Activity No. ABN 98-0-1258 Rev.: 0 Unit: 1&2 ABN Response: Rev. O Responsible Organization:
SCS l X l BPC l l
Site l l
Other l l
The activity to which this evaluation applies represents:
- 1. [ X ] Yes [] No A change to the plant as described in the FSAR, or will this change require a revision or an addition to some portion of the FSAR?
Basis for answer:
The proposed activity consists of changes to the text in FSAR section 11.4.2.4.F, FSAR Table 11.4-6 and FSAR-3A, Regulatory Guide 1.21.
(Item #1). This ABN provides a change to the sample frequency for the Turbine Building sump as described in the FSAR. Thew FSAR text revisions constitute a change to the plant as described in the FSAR.
- 2. [ X ) Yes [] No A change to procedures as described in the FSAR?
Basis for answer:
his ABN provides FSAR changes to the sample frequency for the Turbine building sump as noted in FSAR Table 11.4-6, Sheet 1 of 2, FSAR-3A, and Regulatory Guide 1.21,(Item #1).
The proposed activity also consists of a text change to the procedures in FSAR section 11.4.2.4.F (Turbine Building Sump Release Procedure).
This change constitutes a change to the plant procedures as described in the FSAR.
- 3. [] Yes [X) No A test or experiment not described in the FSAR?
Basis for answer:
The proposed activity consists of text changes to the FSAR. These changes do not involve any non-previously analyzed test or experiments.
Therefore, the proposed activity does not represent a test or experiment not described in the FSAR.
O l
le CFR 59.59 EVALUATION -
Farley Nuclear Plant.
50.59 Revision:
Page 4 of 7 O
' Activity No. ABN 98-0-1258 Rev.:0 Unit: 1&2 ABN Response: Rev. 0 Responsible Organization:
SCS l X l BPC l
Site l
Other j
- 4. [] Yes [X) No A change to the Technical Specifications and/or Environmental Pro'ection Plan incorporated in the operating license?
Basis for answer:
The proposed activity consists of text changes to the FSAR as noted above. A review of the FNP Unit I and Unit 2 TS, including sections 3/4.6,3/4.7, and the Environmental Protection Plan was conducted. His change does not impact the FNP TS or Environmental Protection Plan. Therefore, the proposed activity does not result in a change to Technical Specifications or Environmental Protection Plan as incorporated in the operating license.
If the answer to all the questions above is NO, skip the following section because this activity does not present an unreviewed safety question. If the answer to any question above is YES, the following section must be completed.
C. UNREVIEWED SAFETY QUESTION CRITERIA:
- 1. [] Yes [ X ] No May the proposed activity increase the probability of an occurrence of an accident previously evaluated in the FSAR?
Basis for answer: The proposed activity consists of text changes to FSAR section 11.4.2.4.F.
FSAR Table 11.4-6, and FSAR section 3A as previously described. The proposed activity does not impact the operations or maintenance procedures such that the result would be an increase in the probability of I
an accident. De proposed activity does not involve a physical change to the plant nor a change to instrument setpoints, instrument accuracies, instrument response times or operating parameters. The proposed activity will not degrade the ability of any system, structure or component (SSC) to perform its designed function. The proposed activity will not cause a system to be operated outside its design or testing limits nor cause a change to any system interface. Therefore, the proposed activity will not increase the probability of an accident previously evaluated in the FSAR.
O
[
~,
le CFR 50.59 EVALUATION Farley Nuclear Plant 50.59 Revision:
Page 5 of 7 O
Activity No. ABN 98-0-1258 Rev.: 0 Unit: 1&2 ABN Response: Rev. O q
Responsible Organization:
SCS l X l BPCl l
Site l l
Other l l
i l
- 2. [] Yes [ X ] No May the proposed activity increase the consequences of an accident I
previously evaluated in the FSAR?
Basis for answer: The proposed activity consists of text changes to FSAR section 11.4.2.4 F, FSAR Table 11.4-6, and FSAR section 3A as previously described. The proposed activity will not increase the possibility of any on-site or off-site personnel receiving a radiological dose above the acceptable limit for the plant as currently licensed. Therefore, the proposed activity will not increase the consequences of an accident as previously evaluated in the FSAR
- 3. [] Yes [ X ] N May the proposed activity increase the probability of occurrence of a malfunction of equipment important to safety previously evaluated in the FSAR.
Basis for answer: The proposed activity consists of text changes to FSAR seci9n 11.4.2.4.F, FSAR Table 11.44, and FSAR section 3A as previoasly described. The proposed activity will not alter the design basis or function of any system, structure or component important to safety. The proposed activity will not degrade the ability of any system, structure or component to perform the safety functions described in the FSAR. Therefore, this proposed activity will not increase the probability of occurrence of a malfanction of equipment important to safety previously evaluated in the FSAR.
- 4. [] Yes [ X ] No May the proposed activity increase the consequences of a malfunction of equipment imponant to safety previously evaluated in the FSAR?
Basis for answer: The proposed activity consists of text changes te FSAR section 11.4.2.4.F, FSAR Table 11.4-6, and FSAR section 3A as previously described. The proposed activity will not alter the design basis or function of any system, structure or component important to safety. The proposed activity will not change any conditions or assumptions previously made in evaluatirig the radiological consequences of a malfunction of equipment important to safety as discussed in the FSAR. Therefore, the proposed activity will not increase the consequence of a malfunction of equipment important to safety previously evaluated in the FSAR.
10 CFR 50.59 EVALUATION I
Farley Nuclear Plant 50.59 Revision:
Page 6 of 7 Activity No. ABN 98-0-1258 Rev.: 0 Unit: 1&2 ABN Response: Rev. 0 1
Responsible Organization:
SCS l X l BPC l l
Site l l
Other l l
5,[] Yes [ X ] No May the proposed activity create the possibility of an accident of a j
different type than any previously evahuted in the FSAR?
Basis for answer: The proposed activity consists of text changes to FSAR section 11.4.2.4.F, FSAR Table 11.4-6, and FSAR section 3A as previously described. The proposed activity does not change the way in which any system, structure or component is operated or maintained. The proposed activity does not create the possibility of sn accident initiator not previously considered in the FSAR. The proposed activity does not increase the probability of an accident which was previouslyjudged to be an incredible accident such that the accident could now be considered credible. Therefore, the proposed activity does not create the possibility of an accident of a different type than any previously esaluated in the FSAR.
- 6. [] Yes [ X ] No May the proposed activity create the possibility of a malfunction of equipment important to safety of a different type than any previously evaluated in the FSAR?
Basis for answer:
The proposed activity consists of text changes to FSAR section 11.4.2.4.F, j
FSAR Table 11.4-6, and FSAR section 3A as previously described. The proposed activity does not result in any new system interaction or change the way in which in which any system, structure or component is operated or maintained. The proposed activity does not introduce a new failure i
mode or limiting single failure. Therefore, the proposed activity does not create the possibility of a malfunction of equipment important to safety of a different type than previously evaluated in the FSAR.
O
l f
10 CFR 50.59 EVALUATION Farley Nuclear Plant 50.59 Revision:
Page 7 of 7 O
Activity No. ABN 98-0-1258 Rev.: 0 Unit: 1&2 ABN Response: Rev. 0 3
Responsible Organizatiori:
SCS l X l BPCl l
Site l l
Other l l
- 7. [] Yes [ X ] No Does the proposed activity reduce the margin of safety as defined in the basis for any Technical Specification?
Basis for answer: The proposed activity con::ists of text changes to FSAR section i1.4.2.4.F, FSAR Table 11.4-6, and FSAR section 3A as previously described above.
The Turbin.- Building sump sampling is neither discussed nor described in the Technical Specification. These changes will not impact the availability I
or capability of any system or component that is governed by or required to be operational by Technical Specifications O
If the answer to any of the questions in this section is YES, an unreviewed safety question is indicated. Approval from the NRC is required before the document activity may be implemented.
l f
O I
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.~
FSAR MARK-UI' SHEET 1 OF 3
/
ABN 98-0-1258, Rev. O FNP-FSAR-11 for composite prior to or during its discharge in conformance with Regulatory Guide 1.21.
isolated from each other. f The radiation activity levels in these sumps are Lexpected to be minimal.
Each sump is provided with\\ recirculation capability _
Jrid will be crab sameled>--d ~ -1;;;4 p- ~ u ne)
LE fif 'gr The discharge f rom this s6urce is constant flow durIhg a batch process.
Radiation monitors at the discharge line would provide no meaningful information since the laboratory analysis of grab samples will be much more accurate; also, the instrument performance would be questionable as to the quality of water discharged from this system.
Therefore, no in-process radiation monitors are justified, and none are provided.
G.
Main Condenser Blowdown The main condenser hotwell is blown down on occasion to assist in the maintenance of secondary water chemistry.
The release is via the condensate pump discharge to the turbine building sump pump discharge line.
This pathway is monitored as described in table
- 31. 4'- 6.
11.4.3 SAMPLING The following paragraphs present a detailed description of the radiological sampling procedures, frequencies, and objectives for all reactor plant process and effluent sampling.
The process sampling system is described in subsection 9.3.2.
11.4.3.1 Proce*9 Sampling The sample fre iency, type of analyses, analytical sensitivity, and purpose of the sample are summarized in table 11.4-4 for each liquid process sample location and in table 11.4-5 for each gas process sample location.
The analytical procedures uced in sample analysis are presented in paragraph 11.4.3.3.
This sampling monitors activity levels within various plant systems.
11.4.3.2 Effl.1ent Sampling 11.4.3.2.1 Normal Operation Sampling O
Effluent sampling of all potentially radioactive liquid and gaseous effluent paths will be conducted on a regular basis in order to verify the adequacy of effluent processing to meet the 11.4-30 REV 8 7/90
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e SHEET 3 OF 3 FNP-FSAR-3A ABN 98-0-1258, Rev.0 Reaulatory Guide 1.21 MEASURING AND REPORTING OF EFFLUENTS FROM NUCLEAR POWER PLANTS (SAFETY GUIDE 21, 12/29/71)
CONFORMANCE The Farley units are in compliance with Regulatory Guide 1.21 l
with the following exceptions:
- 1. There are no continuous monitors on the turbine
{
building drains.
Grab samples are taken 6no analyied]
for each batch released.
2.
Gamma spectroscopy measurements are used as the basis for estimating the quantity of icw-level particulate activity released.
I 3.
I-135 is not monitored in gaseous effluents due to its
{
short half-life.
j
- 4. The staan jet air ejector is monitored by monthly grab samples in accordance with Unit 1 and Unit 2 Technical Specification Table 4.11-2.
for composite prior to or dwing its discharge l
i O
3A-1.21-1 REV 10 6/92
m FARLEY NUCLEAR PLANT LICENSING DOCUMENT CHANGE REQUEST LDCR NO:
p g. O 33 p 3 TOTAL ATTACHMENTS 0
SHEET I OF: 3 SECTION 1.:
W ldl [ *4 bu T e..= /A.d U*"; //2.3/f Y 1ma=W ABN 98-0-1258, Rev.O g
Change: This ABN revises text in FSAR section 11 A.2.4.F. FSAR Table 11.4-6 and FSAR 3 A, Regulatory Guide 1.2 (ltem #1). This ABN provides a change to the sample frequency for the Turbine Buildmg sump as described in the FSAR.
1 Justification: g jggj j g g,pgg gy/ j g
g l
SECTION 11: Does this change:
W-M -rt' pyj 1.
l l Yes l X l No Require a change to the: (Identify Which)
Operating License Technical Specifications Environmental Protection Plan If the answer to question (1)is yes, perform a 10 CFR 50.92 evaluation. NRC approval will be required prior to 1
implementation of this change.
o 2.
U Yes X No Require a change to the Quality Assurance Program (FSAR 17.2)?
If the answer to question (2) is yes, perform a 10 CFR 50.54(a) evaluation. NRC approval may be required prio implementation of this change. Changes to the FSAR 17.2 also require a 10CFR50.59 evaluation. By reference, item FSAR Section 3A may also be considered as part of the QAP.
3.
R Yes X No Require a change to any of the following: (Identify Which)
Security Plan (contains Contingency Plan)
Security Personnel Training and Qualification Plan if the answer to question (3) is yes, perform a 10 CFR 50.54(p) evaluation. NRC approval may be required prior to implementation of this change.
4.
U Yes W No Require a change to the Emergency Plan?
If the answer to question (4) is yes, perform a 10 CFR 50.54(q) evaluation. NRC approval may be required prior to implementation of this change.
LDCR Revision 1 Form revised 8/14/98 PDI 005.41, Rev. O
u, Page 2 of 3 FARLEY NUCLEAR PLANT LICENSING DOCUMENT CHANGE REQUEST 5.
x Yes ] No Require a clianae to:
[* the plant as described in the FSAR or requires a Technical Specification v
L revision or an addition to the FSAR Bases
(*
to procedures as described in the FSAR 5 Technical Requirements involve a test or experunent not described Manual (TRM)(when e
in the FSAR issued)
[ Offsite Dose Calculation Manual (ODCM Pressure Temperature r*
Process ControlProgram (PCP)
Limits Report (PTLR)
Fire Hazard Analysis (FHA)(part of FSAR)
(when issued)
Core Operating Limits Report (COLR)
If the answer to question (5)is yes, perform a complete 10 CFR 50.59 evaluation. NRC approval may be required prior to implementation of that change. If the document change is editorial, a clarification, or is supported by an activity previously approved by the NRC, then a complete 10 CFR 50.59 evaluation is not required but a 10 CFR 50.59 screening is required. (Refer to FNP-0-AP-88) Explain on LDCR continuation sheet.
6.
Constitute a matter which could result in adverse environmental impact (either direct or indirect)? Check (a) or (b).
a.
No The nature or this matter is such that it will not produce conditions which could result in edverse environmentalimpact.
b.
x Possibly (Explain Briefly): See continuation page 3 Ifitem (b) is checked, this matter must be referred to Southern Nuclear-Environmental Services for preparation of an Environmental Evaluati...
SECTION 111 Based on the evaluations performed for this change, is NRC approval requir
'or to s
t implementation of this ch e7 Yes No LDCR Preparer: MN '
'A b M kW2f Date:
LDCR Review:
[
h Date:
2 ff Cross Disciplinary Review:
J b
Group: dNm Date: 9[2f/fg Cross Disciplinary Review:
,P'./ I Group: Ez4r#- Date: Mz6/96 Cross Disciplinary Review:
Group:16C Date: b.2O 7F Originating Dept. Manager Nkh Date: JO/Z.1/9 P LDCR Coordinator-Date:
IL/4/*)B v
e SECTION IV 4j PORC Review: M Date: i ///2/12f PORC Meeting No. $2fP NRC Approval Obtained (if applicable):
Date:
(LDCR Coordinator)
NPGM Approval:
Date:
SECTION V Not Applicable Follow-Up Action:
Change implemented: Document No. & Rev.:
O LDCR Coordinator:
Date:
LDCR Revision 1 Form revised 8/l4/98 PD1005.4-1, Rev. O
D]
/
LDCR CONTINUATION SHEET Sheet 3 of 3 LDCR NO.
ABN 98-0-1258, Rev. O revises the following documents:
- 1. The text in the FSAR section 11.4.2.4.F (Turbine Building Sump Release Procedure). The text in this section will be revised from "Each sump is provided with a recirculation capability and will be grab sampled and analyzed prior to its discharge" to read "Each sump is provided with a recirculation capability and will be grab sampled for composite prior to or during its discharge in conformance with Regulatory Guide 1.21".
- 2. The sample frequency for the Turbine Building Sump in FSAR Table 11.4-6, Sheet 1 of 2. This text is revised from " Grab sample prior to release" to read " Grab sample prior to or during release".
- 3. The text in FSAR-3A, Regulatory Guide 1.21, (Item #1). This text is revised from " Grab samples are taken and analyzed for each batch released" to read " Grab samples are taken for composite prior to or during its discharge for each batch released".
Comment: i> wight Hostetter (Environmental Services) has been contacted for review of changes that are impacted in Section 2, Item 5 of the ODCM & PCP.
V]
[
LDCR Revision i Revised 8/14/98 PDI 005.4-1, Rev. 0
FSAR MARK-UP SHEET I OF 3 ABN J8-0-1258, Rev. O FNP-FSAR-11 F>r composite prior to or during its discharge in Ms.ir.cc with Regulatory Guide 1.21.
AP isolated from each other.
The radiation activity levels in these sumps are xpected to be minimal.
Each sump is provided wit _
recirculation capability J nd will be irrab samoledi m ---l;;;q p. m-_;; m)
[_f12:ir!;_.y ~The discharge from this sFurce is constant flow durrng a batch process.
Radiation monitors at the discharge line would provide no meaningful information since the laboratory analysis of grab samples will be much more accurate; also, the instrument performance would be questionable as to the quality of water discharged from this system.
Therefore, no in-process radiation monitors are justified, end none are provided.
G.
Main Condenser Blowdown
~
The main condenser hotwell is blown down on occasion to assist in the maintenance of secondary water chemistry.
The release is via the condensate pump discharge to the turbine building sump pump discharge line.
This pathway is monitcred as described in table
- 11. 4'- 6.
O 11.4.3 SAMPLING The following paragraphs present a detailed description of the radiological sampling procedures, frequencies, and objectives for all reactor plant process and effluent sampling.
The process sampling system is described in subsection 9.3.2.
11.4.3.1 Process Sampling The sample frequency, type of analyses, analytical sensitivity, and purpose of the sample are summarized in table 11.4-4 for each liquid process sample location and in table 11.4-5 for each gas process sample location.
The analytical procedures used in sample analysis are presented in paragraph 11.4.3.3.
This sampling monitors activity levels within various plant systems.
11.4.3.2 Effluent Sampling 11.4.3.2.1 Normal Operation Savpling
()
Effluent sampling of all potentially radioactive liquid and gaseous effluent paths will be conducted on a regular basis in order to verify the adequacy of effluent pro. cessing to meet the 11.4-30 REV 8 7/90
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SHEET 3 OF 3 FNP-FSAR-3A ABN 98-0-1258, Rev.0 Reculatorv Guide 1.21 MEASURING AND REPORTING OF EFFLUENTS FROM NUCLEAR POWER PLANTS (SAFETY GUIDE 21, 12/29/71)
CONFORMANCE The Farley units are in compliance with Regulatory Guide 1.21 l
with the following exceptions:
- 1. There are no continuous monitors on the turbine building drains.
Grabsamplesaretaken(andanalyied]
for each batch released.
2.
Gamma spectroscopy measurements are used as the basis for estimating the quantity of Icw-level particulate activity released.
3.
I-135 is not monitored in gaseous effluents due to its short half-life.
- 4. Tne steam jet air ejector is monitored by monthly grab samples in accordance with Unit 1 and Unit 2 Technical Specification Table 4.11-2.
O j
1 for composite prior to or during its Awharge I
l l
O 3A-1.21-1 REV 10 6/92 1
uuss.:.s c. s m u-. can s u FNP-0-M-011 Table 2-3.
Radioactive Liquid Waste Sampling and Analysis Program Sampling and Analysis Requirementa,b a
MINIMUM DETECTABLE Liquid Minimum CONCENTRATION Release Sampling Analysis Type of Activity (MDC)
Type FREQUENCY FREQUENCY Analysis (4Ci/mL)
A.
Waste Tanks Producing BATCH RELEASES PRINCIPAL GAMMA 5 E-7
{
P P
EMITTERS l
Each BATCH Each BATCH I-131 1 E-6 Dissolved and 1 E-5 One TCH/M ra ned Gases All (Gamma Emitters)
H-3 P
M 1 E-5 Each BATCH COMPOSITE Gross Alpha 1 E-7 Sr-89, Sr-90 5 E-8 p
g Each BATCH COMPOSITE F -55 1 E-6 i
'G B.
CONTINUOUS RELEASESC l
PRINCIPTL GAMMA 5 E-7 D
W EMITTERS Grab Sample COMPOSITE I-131 1 E-6
)
Dissolved and 1 E-5 M
Entrained Gases Steam Grab ample Generator (Gamma Emitters)
Blowdown H-3 D
M 1 E-5 Grab Sample COMPOSITE Gross Alpha 1 E-7 St-89, St-90 5 E-8 D
Q Grab Sample COMPOSITE Fe-55 1 E-6 Turbine PRINCIPE GN 5 E-7 P
W EMITTERS Building Grab Sample COMPOSITE ump H-3 1 E-5 O
2-9 Gen. Rev. 13
FNP-0-M-011 Table 2-3 (contd).
Notation for Table 2-3 All requirements in this table apply to each unit. Deviation from the MDC a.
requirements of this table shall be reported in accordance with Section 7.2.
b.
Terms printed in all capital letters are defined in chapter 10.
Sampling will be performed only if the effluent will be discharged to the c.
environment.
O O
2-10 Gen. Rev. 13
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