ML20216C189

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Safety Evaluation Supporting Amends 136 & 128 to Licenses NPF-2 & NPF-8,respectively
ML20216C189
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 04/09/1998
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML20216C169 List:
References
NUDOCS 9804140359
Download: ML20216C189 (5)


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Ta6FETY EVALUATION BY THE OFFICE OF NUCI FAR REACTOR REGULATJQN RFI ATED TO _APENrmENT NO.136TO FACILITY OPERATING LICENSE NO. NPF-2 AND AMENDMENT NO.128 TO FACILITY OPERATINC-11 CENSE NO. NPF4 SOUTHERN NUni FAR OPERATING COMPANY. INC.. ET AL.

JOSEPH M. FARI FY NUCI FAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-348 AND 50-364

1.0 INTRODUCTION

By letter dated July 23,1997, as supplemented by letters dated September 30 October 27, and December 18,1997, and February 12,1998, the Southem Nuclear Operating Company, Inc.

(SNC) et al.', submitted a request for changes to the Joseph M. Farley Nuclear Plant, Units 1 and 2, Technical Specifications (TS). The requested changes included (1) establishing new reactor coolant system pressure / temperature (P/T) limit curves, (2) relocating the P/T limits curas from the TS to a licensee-controlled Pressure and Temperature Limits Report (PTLR),

1 (3) referencing the PTLR in the affected Limiting Conditions for Operation and Bases, (4) changing the TS temperature at which reactor coolant system overpressure protection is

. required, (5) adding TS administrative controls to control reactor coolant pump operation, (6)

' adding the PTLR to the definitions section of the TS, and (7) adding a new section to the reporting requirements in the' administrative controls sechon of the TS delineating the necessary reports. Guidance on the proposed changes was developed by the Nuclear Regulatory Commission (NRC) on the basis of a proposal by the owners groups during the development of the improved standard technical specifications (STS). This guidance was

. provided to all power reactor licensees and applicants by Generic Letter (GL) 96-03,

" Relocation of the Pressure Temperature Limit Curves and Low Temperature Overpressure Protection System Limits," dated January 31,1996.

L The July 23,19g7, application was noticed in the Federal Register on September 10,1997

. (62 FR 47699). ' The September 30 and October 27,1997, supplements provided additional information that did not change the initial proposed no significant hazards consideration determination. The December 18,1997, supplemental letier provided additional information -

that revised SNC's original evaluation of the significant hazards consideration, and therefore,

( was noticed in the Federal Register on January 14,1998 (63 FR 2281). The February 12, j

1998, supplement provided additional information that rev;aed SNC's evaluation of the i

significant hazards consideration. Thereforo, renotification of the Commission's proposed determination of no significant hazards consideration was necessary and published in the Federal Register on February 23,1998 (63 FR 9020).

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2.0 '

BACKGROUND Section 182a of the Atomic Energy Act of 1954, as amended (the Act), requires applicants for nuclear power plant operating licenses to include TS as part of the license. The Commission's L

regulatory requirements related to the content of TS are set fosth in 10 CFR 50.36. That '

i regulation requires that the TS include items in five speciRc categories: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for opershon; (3) surveillance requirements; (4) design featuroo; and.(5) administrative controls, and states miso that the Commission may include such additional TS as it finds to be appropnate.

p However, the regulation does not spedfy the particular requirements to be included in'a plant's

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TS.

a Section 50.36 of 10 CFR identifies four criteria to be used in determining whether a particular.

matter is required to be included in the TS, as follows: (1) installed instrumentation that is used

~ to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; (2) a process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumee the

' failure of or presents a challenge to the integrity of a fission product barrier; (3) a structure, system, or component that is part of the primary success path and which funchons or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a i

challenge to the integrity of a fission product barrier; (4) a structure, system, or component that operating experience or probabilistic safety assessment has shown to be significant to public 1 L,

health and safety. As a result, existing TS requirements that fall within or satisfy any of these criteria must be retained in the TS, while those TS requirements that do not fall within or satisfy these criteria may be relocated to other licensee-controlled documents.

3.0.

EVALUATION All components of the reactor coolant system (RCS) are designed to withstand the effects of cyclic loads resulting from system pressure and temperature changes. These loads are

' introduced by heatup and cooldown operations, power transients, and reactor trips. In accordance with Appendix G to 10 CFR Part 50, TS limit the pressure and temperature

' changes during RCS hestup'and cooldown within the design assumptions and the stress limits for cyclic operation.' These limits are defined by P/T limit curves for huatup, cooldown, low-temperature overpressure protection (LTOP), and inservice leak and hydrostatic testing. Each curve defines an acceptable region for normal operation. The curves are used for operational guidance during heatup and cooldown maneuvering, when pressure and temperature

' indications are monitored and compared to the applicable curve to determine that operation is L

within the allowable region.

At Farley, the residual heat removal (RHR) system relief valves are used to mitigate 1

overpressure transients at low temperatures to protect the integrity of the reactor coolant

. boundary by preventing the violation of 10 CFR Part 50, Appendix G for the design basis t-s overpressure transients. The RHR suction relief valves have a constant setpoint and are available for LTOP whenever the corresponding RHR train is valved into service (TS 3.4.10.3

)

' requires that the two RHR relief valves be set less than or equal to 450 psi). Altematively, SNC I-i

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may vent the RCS with a vent greater than or equal to 2.85 in" (TS 3.4.10.3.b value) or remove the vessel head to prevent an overpmssure event. The NRC accepted the use of the RHR relief valves as the means of providing LTOP in a safety evaluation report dated, July 31,1979, that concluded no single active failure could disable the overpressure mitigatior,' function.

The licensee-proposed changes to the TS are in accordance with the guidance in GL 96-03, as follows:

'(1)

The definitions section of the TS was modified to include a definition of the PTLR to which the figures, values, and parameters for P/T limits wiH be relocated on a unit-specific basis in accordance with a methodology approved by the NRC that maintains the acceptance limits and the limits of the safety analysis. As noted in the definition, plant operation within these limits is addressed by individual specifications.

(2)

The footnote (*) associated with TS 3.4.1.3 is being modified to raise the temperature,

- from 310 *F to 325 *F, below which a reactor coolant pump (RCP) is not permitted to be started unless certain conditions are met. This temperature corresponds to the enable temperature. Based on the staffs review, the new enable temperature is acceptable and, thus, the TS change is acceptable.

(3)

TS 3.4.1.4 and its asseisted Bases is being modified to add a note to prevent starting a second RCP below 110 *F. This is needed because the limit curves do not consider the operation of all the RCPs below 110 *F. It is also being modified to raise the temperature, from 310 *F to 325 *F, below which an RCP is not permitted to be started unless certain conditions are met. This temperature corresponds to the enable temperature. Based on the staffs review, the new enable temperature is acceptable arvi, thus, the TS change is acceptable.

(4)

The following specification and associated Bases were revised to replace the P/T limits with a reference to the PTLR that provides these limits:

TS 3/4.4.10, " Pressure / Temperature Limits" In addition, TS 3.4.10.3 is being modified to raise the temperature LTOP is required, from 310 *F to 325 *F. Based on the staff review, the new enable temperature is acceptable and, thus, the TS change is acceptable.

(5)

Specification 6.9.1.15, " Pressure Temperature Limits Report (PTLR)," was added to the reporting requirements of the administrative controls section of the TS. This specification requires that the PTLR be submitted, upon issuance, to the NRC Document Control Desk with copies to the regional administrator and resident inspector.

The report provides the explanations, figures, values, and parameters of the P/T limits for the applicable effective period. Furthermore, this specification requires that the figurss, values, and parameters be established using the methodology approved by the NRC for this purpose in the NRC letter approving a plant-specific methodology as

L referenced in the TS and be consistent with all the applicable acceptance limits and the 7

limits of the safety analysis.

L Finally, the specification requires that all changes in values of these limits be

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documented in the PTLR each effective period and submitted upon issuance to the l

NRC.'

Relocation of the P/T curves d' oes not eliminate the requirement to operate in accordance with the limits specified in Appendix G to 10 CFR part 50. The requirement to operate within the L

limits in the PTLR is specified m, and controlied by, the TS. Only the figures, values, and L

parameters associated with the P/T limits are to be relocated to the PTLR. In order for the curves to be relocated to a PTLR, a methodology for their development must be reviewed and approved in advance by the NRC. The methodology to be approved by the NRC is to be -

developed in accordance with GL 96-03. This GL provides guidance regarding referencing the methodology and development of the PTLR including, but not limited to, the requirements of Appendix G to 10 CFR Part 50. Since the methodology is referenced in the TS, changes to the I

methodology must be approved by the NRC. Further, when changes are made to the figures, i

values, and parameters contained in the PTLR, the PTLR is to be updated and submitted to the l

NRC upon issuance.

I On this basis, the NRC staff concludes that SNC provided an acceptable means of establishing and maintaining the detailed values of the P/T limit curves. Further, because plant operation continues to be limited in accordance with the requirements of Appendix G to 10 CFR Part 50 and the P/T limits in the TS will be established using a methodology approved by the NRC, these changes will not impact plant safety.

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' The staff also concludes that the above-relocated requirements relating to the P/T limits are not required to be in the TS under 10 CFR 50.36, and are not required,to obviate the possibility of an abnormal _ situation or event giving rise to an immediate threat to the public health and safety.

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Accordingly, the staff concludes that the proposed changes are acceptable and that these requirements may be relocated from the TS to the PTLR.

A detailed discussion of the staff's basis for acceptance of SNC's proposed methodology is provided in the attached letter from J. Zimmerman to D. Morey, "Farley Nuclear Plant, Units 1 and 2, Acceptance of Referencing of Pressure Temperature Limits Report," dated March 31, 1998, as corrected April 3,1998.

4.0 STATE CONSULTATION

in accordance with the Commission's regulations, the Alabama State official was notified of the proposed issuance of the amendments. The State official had no comments.

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5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that tne amendments involve no significant hazards consideration, and there has been no public comment on such finding (62 FR 47699 dated September 10,'1997; 63 FR 2281 dated ' -

January 14,1998; 63 FR 9020 dated February 23,' 1998). Accordingly, the amendments meet the eligibility criteria for categorical acclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impo:t statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 -. CONCLU31QN "The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Attachment:

As stated PrincipalContributor: J. Zimmerman Date: April 9,1998 9

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