ML20077Q266

Provides Addl 10CFR50.92 Justification for 830531 & 0615 Applications for Amends to Tech Specs Re Change in Dose Equivalent Iodine & Change in Purge Valve Operability Specs

ML20077Q266
Person / Time
Site:	Hatch
Issue date:	09/01/1983
From:	Gucwa L GEORGIA POWER CO.
To:	Stolz J Office of Nuclear Reactor Regulation
References
NED-83-416, TAC-42603, TAC-42604, TAC-51984, TAC-51985, TAC-53476, TAC-53477, TAC-59543, TAC-59544, NUDOCS 8309160053
Download: ML20077Q266 (9)

Text

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. Geor@a Poer Company 333 hedmmt Awnue f ArWa Georqu 303G8 -

Tekphorm 404 526 6 % 6 Whng Address Post Ofie Box 454S Aranta Georg a 30302 b Georgia Power l #'"

• Power Generation Department NED-83-416 September 1, 1983 I Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 i Division of Licensing U. S. Nuclear Regulatory Ccanission Washirgton, D. C, 20555 NBC DOCKEIS 50-321, 50-366 i OPERATING LICENSES DPR-57, NPF-5 EININ I. HA'ICH NUCLEAR PLANT UNITS 1, 2

, CLARIFICATION OF PURGE AND VENT SUBMITTAIS i

) Gentlemen:

The purpose of this letter is to provide additional 10 CFR 50.92 justification for the two amendments to the Technical Specifications proposed in our submittals of May 31, 1983 and June 15, 1983.

In the May 31, 1983 letter, we proposed a change to Dose Equivalent Iodine (CEI) for Unit 1. Unit 1 was licensed with a DEI limit of 10 microcuries per gram of coolant on a site specific basis. The submittal requested to change this basis to a worst-case non-site specific limit of 0.2 microcuries per gram. % is change is clearly in the conservative direction. The change also provided for minor administrative changes in the terminology in the specification and frequency of analyses.

In the June 15, 1983 letter, we proposed a charge to purge valve operability specifications for both units. Unit 2 was licensed with a restriction inposed on the amount of time that the 18" purge and vent isolation valves

.could be open. In subsequent discussions with the NRC Staff it was determined that if: 1) a site specific dose analysis was submitted; 2) measures were taken to protect downstream structures; and 3) valve operability was demonstrated; then the restrictions on valve operability could be lifted. The dose analysis and the valve operability data, with the exception of ~ the seismic test results sumary, were submitted in our letter of May 31, 1983. %e sumary of the seismic test data was included as an attachment to our June 15, 1983 letter. A sumary of a proposed design modification to protect downstream structures was also attached to our letter of June 15, 1983. The proposed change cannot and will not be implemented until after the design modification has been made. A committment similar to the current Unit 2 Technical Specification for valve operability was made for Unit 1 in our letter of October 1, 1982. The i intent of the proposed change is to supplant the comittment in the October 1, 1982 letter with a Technical Specification on Unit 1 and remove the restrictions on Unit 2 upon implementation of the design modification on both units. (

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Georgia Power A Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Comnissica Washington, D. C. 20555

. Septenber 1,1983 Page 'No In the attachments to this letter we are providing the requested 10 CFR 50.92 analysis for each proposed change to the Technical Specifications.

If you have further questions, please contact this office, Very Truly Yours, ee .r & n L. T. Gucwa Manager-Nuclear Engineering and Chief Nuclear Engineer MIB Attachnents

, xc: J. P. O'Reilley H. C. Nix, Jr.

Senior Resident Inspector i

700775

ATTACFNENT l NRC DOCKET 50-321 OPERATING LICENSE DPR-57 EININ I. HA'ICH NUCLEAR PLAr7T UNIT 1 CLARIFICATION OF PURGE AND VENT SUBMITTALS DOSE EQUIVALENT IODINE (DEI)

Letter of May 31, 1983

1. Change from "10 microcuries per gram" to "0.2 microcuries per gram":

BASIS:

This change constitutes a more restrictive operational limitation to Unit 1. The resultant doses from a potential accident are less since the allowable initiating point for the transient is lower.

The change constitutes a major decrease in the effects of accidents previously analyzed, does not create any new accidents, and -

increases the margin of safety. % erefore, the results of this change are clearly within acceptance criteria, and this change is consistant with Item (ii) of the " Examples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6, 1983, issue of the Federal Register.

2. Change from operation at " equilibrium values by a factor of more than 10" to "less than or equal to 4.0 microcuries per gram":

BASIS:

This change constitutes a more restrictive operational limitation to Unit 1. The resultant doses from a potential accident are less since the allowable initiating point for the transient is lower.

%e change constitutes a major decrease in the effects of accidents previously analyzed, does not create any new accidents, and increases the margin of safety. %erefore, the results of this change are clearly within acceptance criteria, and this change is consistant with Item (ii) of the " Examples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6, 1983, issue of the r a deral Register.

3. Change from "more than 5 percent of its yearly power operation" to "does not exceed 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in any consecutive 12 nonth period":

BASIS:

The change does not raise the probability or the consequences of an accident already evaluated. The charge by itself may increase the allowable time in excess of the DEI limit. However, the lower level of allowable DEI offsets any increase in time exposure. Were are no new modes of operation. There is no significant reduction in the margin of safety. %erefore, the results of this change are clearly within acceptance criteria, and this change is consistant with Item (vi) of the " Examples of Amendments that are Considered N0t Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6, 1983, issue of the Federal Register.

This change is also administrative in that there is a change in nomenclature. The proposed change in nomenclature does not:

involve a significant increase in the probability or consequences of an accident previously evaluated; create the possibility of an accident of a type different from any evaluated previously; or involve a significant reduction in a margin of safety. Therefore, this change is consistant with Item (i) of the "Exanples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6, 1983, issue of the Federal Register.

4. Add to the Technical Specifications:

"Should the total operating time of a specific activity greater than 0.2 microcuries per gram dose equivalent I-131 exceed 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> in any consecutive 6 month period, the licensee shall report the number of hours of operation above this limit to the NBC within 30 days":

BASIS:

This change constitutes a more restrictive operational limitation to Unit 1. %e resultant doses from a potential accident are less since the allowable initiating point for the transient is lower.

The change constitutes a major decrease in the effects of accidents previously analyzed, does not create any new accidents, and increases the margin of safety. Werefore, the results of this change are clearly within acceptance criteria, and this change is consistant with Item (ii) of the " Examples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6,1983, issue of the Federal Register.

5. Change from " steam line isolation valves shall be closed immediately" to

" steam line isolation valves closed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />":

BASIS:

The change does not raise the probability or the consequences of an accident already evaluated. The charge by itself may increase the allowable time in excess of the DEI limit. However, the lower level of allowable DEI offsets any increase in time exposure. There are no new modes of operation. There is no significant reduction in the margin of safety. Werefore, the results of this change are clearly within acceptance criteria, and this charge is consistant with Item (vi) of the " Examples of Amendments that are Considered l Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6, 1983, issue of the Federal Register.

6. Charge " isotopic" to " iodine":

BASIS:

This change is administrative in that it is a charge in ncmenclature. The charge is a clarification of an existirg practice. Without this change the Technical Specification could be construed to mean that the total isotopic inventory must be converted to an equivalence of I-131. This is clearly not the intent of the specification. The intent is that all iodine

isotopes must be converted to an equivalence of I-131. The proposed change does not: involve a significant increase in the probability or consequences of an accident previously evaluated; create the possibility of an accident of a type different from any evaluated previously; or involve a significant reduction in a margin of safety. Therefore, this change is consistant with Item (i) of the " Examples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6,1983, issue of the Federal Register.

7. Add to the Technical Specifications: "(net change averaged for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />)":

BASIS:

This charge is administrative in thc.t it is a clarification in nomenclature. The proposed charge does not: involve a significant increase in the probability or consequences of an accident previously evaluated; create the possibility of an accident of a type different from any evaluated previously; or involve a significant reduction in a margin of safety. Therefore, this change is consistant with Item (i) of the " Examples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6, 1983, issue of the Federal Register.

8. Add to the Technical Specifications:

"3) ...at release rate less than 80,000 microcuries per second, or 4)

The off-gas levels at the SJAE, increases by more than 15% in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at release rate greater than 75,000 microcuries per second."

BASIS:

This change constitutes a more restrictive operational limitation to Unit 1. By a more restrictive limitation of when samples must be taken, the net effect is an improvement in the data base available to the plant staff. The resultant doses from a potential accident are less since the allowable initiating point for the transient is lower. The change constitutes a major decrease in the effects of accidents previously analyzed, does not create any new accidents, and increases the margin of safety. Therefore, the results of this change are clearly within acceptance criteria, and this charge is consistant with Item (ii) of the " Examples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6, 1983, issue of the Federal Register.

9. Charges to the bases reflect the above mentioned charges:

BASIS:

These changes overall constitute more restrictive operational limitations to Unit 1. The resultant doses from a potential accident are less since the allowable initiating point for the transient is lower. These charges constitute a major decrease in the effects of accidents previously analyzed, do not create any new accidents, and incre.ases the margin of safety. 'Iherefore, the results of these changes are clearly within acceptance criteria, and these charges are consistant with Items (i) , (ii) and (vi) of

the "Exanples of Amendments that are Considered Not Likely to

.Invol ve Signi ficant Hazards Considerations" listed on page 14,870 j

of the April 6,1983, issue of the Federal Register, i

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ATTACINENr 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDNIN I. HA'ICH NUCLEAR PLANP UNITS 1, 2 CIARIFICATION OF PURGE AND VENP SUBMITTAIS PUHGE VALVE OPERABILITY Ietter of June 15, 1983

1. (Unit 1) Md to the Technical Specifications:

"3.7.A.8 Primary Containment Purge System a.) when primary containment is required, all drywell and suppression chamber 18 inch purge supply and exhaust isolation valves shall be operable and in the fully closed position except when required for inerting, deinerting, or pressure control. b.) Each drywell and suppression chamber 18 inch purge supply and exhaust -isolation valve shall have a leakage rate as specified in 4.7.A.2. If either of these requirements cannot be met, close the valve (s) or otherwise isolate the penetration (s) within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or be in

~at least Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in Cold Shudown within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

4.7.A.8 Primary Containment Purge System a.) Each drywell and suppression chamber 18. inch purge supply and exhaust isolation valve shall be verified to be closed at least monthly, b.) Each refueling outage ' each drywell and suppression chamber 18 inch purge supply and exhaust isolation valve with a resilient material seat shall be demonstrated operable by having its valve seat replaced and verifyirg that the leakage rate is within its limit."

BASIS:

This change constitutes a more restrictive operational limitation to Unit- 1. The probability of a potential accident is not changed. The effects of a postulated accident are not changed since ' assurance is provided that the downstream filters are protected from the IDCA induced pressure, spike by the proposed design change. The. Technical Specification change does not create any new accidents, and increases the margin of safety. Therefore, the results of this change are clearly within acceptance criteria, and . this change is consistant with Item (vi) of the " Examples of Amendments ;that are Considered Not Likely to Involve Significant l-Hazards Considerations" . listed on page 14,870 of 'the April 6,1983, issue of the Federal Register.

2. (Unit 1) Mditions to the bases to reflect the above mentio"A change:

BASIS:

This change constitutes a more restrictive operational limitation to Unit 1. %e probability of a potential accident is not changed. The effects of a postulated accident are not charged since assurance is provided that the downstream filters are protected from the IDCA induced pressure spike by the proposed

, design change. The Technical Specification change does not create any new accidents, and increases the margin of' safety. %erefore, the results of this change are clearly within acceptance criteria, and this change is consistant with Item (ii) of the " Examples of

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, u Amendments that are Considered Not Likely to Involve Significant t Hazards Considerations" listed on page 14,870 of the April 6,1983, issue of the Federal Register.

f 3. (Unit 2) Deletion of 4.6.1.1.b:

I BASIS:

This specification is being replaced by 3/4.6.6.5. This change does not change the effects or probability of accidents previously analyzed, does not create any new accidents, or decrease the margin of safety. %erefore, the results of this change are clearly within acceptance criteria, and this change is consistant with Item (i) of the " Examples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6, 1983, issue of the Federal Register.

4. (Unit 2) Add to the Technical Specifications:

"CONTAIl@ENT SYSTENS PRIMARY CONTAINMENT PUICE SYSTEM LIMITING CObDITION FOR OPERATION 3.6.6.5 'Ihe drywell and suppression chamber 18 inch purge supply and exhaust isolation valves shall be OPERABLE with: a.) Each valve may be open for purge system operation for inerting, deinerting and pressure control; b.) A leakage rate such that the provisions of Specification 3.6.1.2 are met.

APPLICABILITY: OPERATIONAL CONDITIONS 1,2 and 3.

AcrION: a.) With an 18 inch drywell and suppression chamber purge stpply and/or exhaust isolation valve (s) inoperable or open for reasons other than inertina, deinerting or pressure control, close the open 18 inch valve (s) or otherwise isolate the peretration(s) within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or be in at least HOP SHU'IDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHU'IDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SURVEILIANCE REQUIRENENTS 4.6.6.5 The primary containment purge system shall be demonstrated OPERABLE: at least once per 31 days, when not purging and venting, by verifying that each 18 inch drywell and suppression chamber valve is closed; at least once per 18 months by replacing the valve seat of each 18 inch drywell and suppression chamber purge supply and exhaust isolation valve having a resilient seat and verifying that the leakage rate is within its limit."

BASIS:

This change is administrative in that it is a change in nomenclature by defining when the valves may be open rather than a set number cf hours per year. By so doing the proposed change does not: involve a significant increase in the probability or consequences of an accident previously evaluated; create the possibility of an accident of a type different from any evaluated previously; or involve a significant reduction in a margin of safety. Werefore, this change is consistant with Item (i) of the

" Examples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6, 1983, issue of the Federal Register.

This change also constitutes a more restrictive operational limitation to Unit 2 by mandating when the valve seats must be

replaced. The probability of a potential accident is not changed by the limitations on the lergth of time that a valve seal may be in service. %e change provides added assurance that the effects of the same postulated accident are as described in the FSAR. The change constitutes no change in the probability or effects of accidents previously analyzed, does not create any new accidents, and increases the margin of safety. Werefore, the results of this charge are clearly within acceptance criteria, and this change is consistant with Item (ii) of the " Examples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6,1983, issue of the Federal Register.

This change constitutes a more restrictive operational limitation to Unit 2. %e probability of a potential accident is not charged. %e effects of a postulated accident are not changed since assurance is provided that the downstream filters are protected from the ILCA induced pressure spike by the proposed design charge. The Technical Specification change does not create any new accidents, and increases the margin of safety. Therefore, the results of this change are clearly within acceptance criteria, and this change is consistant with Item (ii) of the " Examples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6, 1983, issue of the Federal Register.

5. (Unit 2) Additions to the bases to reflect the above mentioned charges:

BASIS:

These changes overall constitute more restrictive operational limitations to Unit 2. %e probability of a potential accident is not charged. The effects of a postulated accident are not charged since assurance is provided that the downstream filters are protected from the IOCA induced pressure spike by the proposed design change. %e Technical Specification charges do not create any new accidents, and increase the margin of safety. %erefore, the results of these changes are clearly within acceptance criteria, and this charge is consistant with Items (i), (ii) and (vi) of the " Examples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14,870 of the April 6, 1983, issue of the Federal Register.

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