ML20207F321
| ML20207F321 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 07/10/1986 |
| From: | Beckham J GEORGIA POWER CO. |
| To: | Muller D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20207F327 | List: |
| References | |
| 0578C, 578C, 587C, SL-862, TAC-60728, TAC-60729, NUDOCS 8607220517 | |
| Download: ML20207F321 (5) | |
Text
)
Georgia Power Company o,
333 Piedmont Avenue Atlanta. Georgia 30308 Telephone 404 526-7020 Mailing Address:
Post Office Box 4545 Atlanta, Georgia 30302 Georgia Power VIce P side t a General Manager Nuclear Operations SL-862 0578C July 10,1986 Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 Division of Boiling Water Reactor Licensing U. S. Nuclear Regulatory Commissicn Washington, D..C.
20555 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2 REQUEST TO REVISE TECHNICAL SPECIFICATIONS DOCUMENTATION OF TELECON Gentlemen:
By our letter of January 27, 1986, Georgia Power Company submitted to the NRC proposed Technical Specifications changes to the requirements for the analysis and monitoring of gaseous radioactive effluents.
It was proposed to:
(1) Allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before the flowrates of various radioactive gaseous effluent pathways must be estimated when less than the minimum number of required channels are operable.
(2) Eliminate checking the tritium levels during startup and power level changes.
(3) Require additional monitoring of gaseous effluents only if necessitated by changes in water chemistry.
(4) Add a time frame for performance of gaseous waste analyses.
Pursuant to a telephone conversation on June 9,1986, between members of our respective staffs, we have determined that several modifications to the form and content of our submittal need to be made.
During the phone call, the intent of the proposed technical specification changes was discussed and suggested alternative approaches were pursued.
This submittal revises our proposed amendment based upon those discussions.
For clarity, we will first list each change as described in our January 27, 1986, letter and then describe the proposed modification for that change.
h, DO o
1
i GeorgiaPower A Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 July 10, 1986 Page Two "A. Proposed Change:
It is proposed to revise Action Statement 104 of Unit 1 Table 3.14.2-1 and Unit 2 Table 3.3.6.10-1, so that, the flowrates must be estimated every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, rather than every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, to allow ef fluent releases to continue with less than a minimum number of channels of instrumentation operable."
We hereby withdraw this change from the submittal.
The desired clarification of the term " estimated" will be noted in the Offsite Dose Calculation Manual (00CM).
The change to the ODCM will be forwarded to the NRC with the next Semi-Annual Effluent Release Report after incorporation as per Technical Specification 6.17.1.
The net effect of this modification to the submittal is that Action Statement 104 will be unchanged from Amendment 110 for Unit 1 and Amendment.48 for Unit 2.
"B. Proposed Change:
It is proposed to revise Unit 1 Table 4.15.2-1 and Unit 2 Table 4.11.2-1 to delete footnote
'c' from applying to tritium levels.
Footnote 'c' requires additional sampling following shutdown, startup or power level changes greater than 15% of rated thermal power."
We hereby propose a change to the method of incorporation of the proposed revision.
Instead of moving the placement of footnote 'c' in Tables 4.15.2-1 and 4.11.2-1, we would alter the wording of the footnote. The net effect of this modification is that the tables will be unchanged from Amendment 110 for Unit 1 and Amendment 48 for Unit 2 However, the wording of footnote 'c' would change to:
" Sampling and analyses of principal gamma emitters shall..."
0578C
GeorgiaPower A Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 July 10,1986 Page Three "C: Proposed Change:
Footnotes 'c' and
'd' of Unit 1 Table 4.15.2-1 and Unit 2 Table 4.11.2-1 will be revised.
Both footnotes will be revised so that additional monitoring is not required unless the dose equivalent iodine level increases by more than a factor of three and greater than 0.02 Ci/g."
We hereby propose that the proposed amendment wording of the footnotes be changed to no longer state a specific dose equivalent iodine level but still include the factor of 3 increase.
Instead, we would rely on an increase by a factor of 3 in the Main Stack Noble Gas Activity Monitor reading as the joint conditional precursor of accelerated l
sampling.
Therefore, the wording modification would read:
...if analysis shows that the DOSE EQUIVALENT I-1 31 concentration in the primary coolant and the Main Stack Noble Gas Activity Monitor reading have increased more than a factor of 3."
The intent of this change is the same as a revision to the BWR Standard Technical Specifications (STS) which was not in effect at the time we wrote our original Radiological Effluent Technical Specifications.
However, the STS have subsequently been approved.
"D. Proposed Change Footnote 'c' of Unit 1 Table 4.15.2-1 and Unit 2 Table 4.11.2-1 will be revised.
A time frame of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for performing the analysis will be added."
As with proposed Change
'A',
we withdraw Change
'D'.
Our interpretation of the required sample times would be incorporated into the ODCM and submitted with the next Semi-Annual Effluent Release Report.
The not effect of this modification is that this portion of footnote
'c' will be unchanged from Amendment 110 for Unit 1 and Amendment 48 for Unit 2.
0578C 100115
GeorgiaPower d Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 July 10, 1986 Page Four The revised Technical Specifications pages, which reflect changes
'B' and
'C' above and the modifications of April 4,
1986, are enclosed.
Although the wording of changes
'B' and 'C' has been modified from our submittal of January 27, 1986, the logic upon which each change is based has not. Therefore, the 10 CFR 50.92 evaluation remains the same.
Additionally, it is our understanding from the June 9th telephone conversation that no additional Radiological Effluent Technical Specifications are necessary for the Purge System.
This understanding resolves the reviewer's concern from his review of the Radiological Effluent Technical Specifications submittal of October 1, 1984.
The additional Technical Specifications are not required due to the design of the Plant Hatch Purge System.
The Plant Review Board and the Safety Review Board Subcommittee have reviewed the proposed changes.
If you have further questions regarding this matter, please contact this office at any time.
Pursuant to the requirements of 10 CFR 50.91, Mr. J. L. Ledbetter of the Environmental Protection Division of the Georgia Department of Natural Resources will be sent a copy of this letter and all applicable attachments.
J. T. Beckham, Jr. states that he is Vice President of Georgia Power Company and is authorized to execute this oath on behalf of Georgia Power Company, and that to the best of his knowledge and belief the facts set forth in this letter are true.
GEORGIA POWER COMPANY Bhd T. Beckham, Jr. [/
Sworn to and subscribed fore me this 10th day of July,1986
_q Notary Public, Georsis, State at Large g
j (/
[
7 My Commission f.apires Sept.18,1987 l
~ ~ Notary Public MJB/lc Enclosures 0578C l
rmits
GeorgiaPower A Director of Nuclear Reactor Regulation Attention: Mr. D. Muller, Project Director BWR Project Directorate No. 2 July 10,1986 Page Five c: Georc ia Power Company Nuclear Regulatory Commission Mr. i. P. O'Reilly Dr. J. N. Grace, Regional Administrator Mr. J. T. Beckham, Jr.
Senior Resident Inspector Mr. H. C. Nix, Jr.
GO-NORMS State of Georgia Mr. J. L. Ledbetter 0578C 700775