ML17222A697

Proposed Tech Specs Implementing Recommendations of Generic Ltr 85-19

ML17222A697
Person / Time
Site:	Saint Lucie
Issue date:	02/21/1989
From:	FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17222A696	List: ML17222A695 ML17222A697
References
GL-85-19, NUDOCS 8903010120
Download: ML17222A697 (26)

Text

ATTACHMENT 1 Marked-up St. Lucie Unit 1 Technical Specification Pages:

3/4 4-17 3/4 4-18 B

3/4 4-5 6-16 (with insert)

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REACTOR COOLANT SYSTEM SPECIFIC ACTIVITY LIMITING CONDITION FOR OPERATION 3.4.8 The specific activity of the primary coolant shall be limited to:

a.,

< 1.0 uCi/gram DOSE EQUIVALENT I-131, and b.

< 100/E uCi/gram.

APPLICABILITY:

MODES 1, 2. 3, 4 and 5.

ACTION:

MODES 1, 2 and 3*:

octa MODES 1 o Mith the specific activity of the primary coolant 0 1.0 uCi/gram DOSE EQUIVALENT I-131 for more than 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> during one con-tinuous time interval or exceeding the limit line shown on Figure 3.4-1, be in HOT STANDBY with T c 500'F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Mith the specific activity of the primary coolant 0 100/7 yCi/gram, be in HOT STANDBY with T v 500.'F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

2, 3. 4 and 5:

Mith the specific activity of the primary coolant 0 1.0 uCi/gram DOSE EQUIVALENT I-131 or 0 100/Z uCi/gram. perform the sampling and analysis requirements of item 4 a) of Table 4.4-4 until the specific activity of the primary coolant is restored to within its limits.

'Mith T 0 500'F.

ST.

LUCIE - UNIT 1 3/4 4-17 Amendment No. 6g

REACTOR COOLANT SYSTEM ACTION:

Continued SURVEILLANCE RE UIREMENTS 4.4.8 The specific activity of the primary coolant shall be determined to be within the limits by performance of the sampling and analysis pro-gram of Table 4.4-4.

ST.

LUCIE - UNIT 1 3/4 4-18

REACTOR COOLANT SYSTEM SASES time and temperature dependent.

Corrosion studies show that operation may be continued with contaminant concentration levels in excess of the Steady State Limits, up to the Transient Limits, for the specified limited time intervals without having a significant effect on the structural integrity of the Reactor Coolant System.

The time interval permitting continued operation within the restrictions or the Transient Limits provides time for taking corrective actions to restore the contaminant concentrations to within the Steady State Limits.

The surveillance requirements provide adequate assurance that con-centrations in excess of the limits will be detected in ".ufficient time to take corrective action.

3/4.4.8 SPECIFIC ACTI'/ITY The limitations on the specific activity of the primary coolant ensure that the resulting 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> doses at the site boundary will not exceed an appropri tely small fraction of Part 100 limits following a steam generator tube rupture accident in conjunction with an assumed steady state primary-to-secondary steam generator leakage rate or 1.0 GPH and a concurrent loss of offsite electrical power.

The values for the limi s on specific activity represent+a4~a-limits based uoon a

parametric evaluation by the NRC of typical site locations.

These values are conservative in that specific site parameters of the St. Lucie si te, such as site boundary location and meteorological conditions, were not considered in this evaluation.

The ACTION statement permitting POWER OPERATION to continue for limited time periods with the primary coolant's specific activity > 1.0 pCi/gram OOSE EQUIVALENT I-131, but within the allowable limit shown on Figure 3.4-1, accorrmodates possible iodine spiking phenomenon

,vhich may occur fATbmtng changes in THERMAL POWER.

ST.

LUCIE - UNIT 1

8 3/4 4-5

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St. Lucie Unit 1 Insert page 6

16 Annual reports shall also include the results of specific activity analysis in which the primary coolant exceeded the limits of Specification 3.4.8.

The following information shall be included:

(1)

Reactor power history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (2)

Results of the last isotopic analysis for radioiodine performed prior to exceeding the limit, results of analysis while the limit was exceeded and results of one analysis after the radioiodine activity was reduced to less than the limit.

Each result should include date and time of sampling and the radioiodine concentrations; (3)

Clean-up system flow history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (4)

Graph of the I-131 concentration and one other radioiodine isotope concentration in microcuries per gram as a function of time for the duration of the specific activity above the steady-state level; and (5)

The time duration when the specific activity of the primary coolant exceeded the radioiodine limit.

GL85-19.EJW

ATTACHMENT 2 Marked-up St. Lucie Unit 2 Technical Specification Pages 3/4 4-25 3/4 4-26 B 3/4 4-6 B 3/4 4-7 6-17 (with insert)

GL85-19.EJW

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REACTOR COOLANT SYSTEM 3/4. 4, 8 SPECIFIC ACTIVITY LIMITING CONDITION FOR OPERATION 3.4.8 The specific activity of the primary coolant shall be limited to:

a.

Less than or equal to 1.0 microcurie/gram DOSE E(UIVALENT I-131, and b.

Less than or equal to 100/E microcuries/gram.

APPLICABILITY:

MODES 1, 2, 3, 4 and 5.

1 ACTION:

MODES 1, 2 and 3":

D~ 1~le With the specific activity of the primary coolant greater than 1.0 microcurie/gram DOSE EgUIVAtENT I-131 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during one continuous time interval or exceeding the limit line shown on Figure 3.4-1, be in at least HOT STANDBY with T less than 5004F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

avg With the specific activity of the primary coolant greater than 100/E microcuries/gram, be in at least HOT STANDBY with T less than 5004F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

avg With T greater than or equal to 500 F.

avg ST,.

LUCIE " UNIT 2 3/4 4-25

REACTOR COOLANT SYSTEM ACTION:

(Continued) a

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MODES 1, 2, 3, 4 and P.'ith the specific activity of the primary coolant greater than 1 microcurie/gram DOSE EQUIVALENT I-131 or greater than 100/E microcuries/gram,'perform the sampling and analysis require-ments of item 4 a) of Table 4.4-4 until the specific activity of the primary coolant is restored to within its limits. ~Syee4A SURVEILLANCE RE UIREHENTS 4.4.8 The specific activity of the primary coolant shall be determined to be within the limits by performance of the sampling and analysis program of Table 4.4-4.

ST.

LUCIE - UNIT 2 3/4 4-26 Amendment No.

13

REACTOR COOLANT SYSTEM BASES CHEMISTRY Continued the chemistry within the Steady State Limits provides adequate corrosion protection to ensure the structural integrity of the Reactor Coolant System over the life of the plant.

The associated effects of exceeding the oxygen, chloride and fluoride limits are time and temperature dependent.

Corrosion studies show that operation may be continued with contaminant concentration levels in excess of the Steady State Limits, up to the Transient Limits, for the specified limited time intervals without having a significant effect on the structural integrity of the Reactor Coolant System.

The time interval permitting continued operation within the restrictions of the Transient Limits provides time fot taking corrective actions to restore the contaminant concentrations to within the Steady State Limits.

The surveillance requirements provide adequate assurance that concentrations in excess of the limits will be detected in sufficient time to take corrective action.

3/4. 4. 8 SPECIFIC ACTIVITY The limitations on the specific activity of the primary coolant ensure that the resulting 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> doses at the'ite boundary will not exceed an appro-priately small fraction of Part 100 limits following a steam generator tube rupture accident in conjunction with an assumed steady state primary-to-secondary steam generator leakage rate of '1.0 gpm and a concurrent loss of offsite electrical power.

The values for the limits on specific activity represent limits based upon a parametric evaluation by the NRC of typical site locations.

These values are conservative in that specific site parameters of the St.

L'ucie

site, such as site boundary location and meteorological conditions, were not considered in this evaluation.

The ACTION statement permitting POWER OPERATION to continue for limited time periods with the primary coolant's specific activity greater than 1.0 microcurie/gram 00SE E(UIVALENT I-131, but within the allowable limit shown on Figure 3. 4-1, accommodates possible iodine spiking phenomenon which may occur following -changes in THERMAL POWER.

ST.

LUCIE " UNIT 2 B 3/4 4-6

REACTOR COOLANT SYSTEM BASES SPECIFIC ACTIVITY Continued The sample analysis for determining the gross specific activity and can exc de the radioiodines because of the low primary coolant 1imit of 1 cro-curie am OOSE E(UIVALENT I-131, and because, if the limit is exceed, the radioio e level is to be determined every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

If the gross ecific activity 1

el and radioiodine level in the primary coolant were their limits, the dioiodine contribution would be approximately 1X.

In a release of primary coo nt with a typical mixture of radioactivity, t actual radioiodine cont 'bution would probably be about 20K.

The elusion of radionuclides with alf-lives less than 10 minutes from t se determinations has been made for se ral reasons.

The first.considera on is the difficulty in identifying short-1 ed radionuclides in a sample at requires a significant time to collect, transpo

, and analyze.

The secon consideration is the predictable delay time bet en the postulated rel se of radioactivity from the primary coolant to its r ease to the envir ment and transport to the SITE BOUNOARY, which is relata e to at least 0 minutes decay time.

The choice of 10 minutes for the hal life cuto was made because of the nuclear characteristics of the typical prim y co ant radioactivity.

The radionuclides in the typical primary coolant have h

1 lives of less than 4 minutes or half-lives of greater than 14 minutes, whi allows a distinction between the radionuclides above and below a hal life f 10 minutes.

For these reasons the radionuclides that are exclud from co ideration are expected to decay to very low levels before thay uld be trans rted from the primary coolant to the SITE BOUNOARY under an accident condit Based upon the above onsiderations for exclu certain radionuclides from the sample analysi

, the allowable time of 2 hou between sample taking and completing the in ial analysis is based upon a typ al time necessary to, perform the samplin

, transport the sample, and perform t analysis of about 90 minutes.

The oss count should be made in a reproducib geometry of sample and coun r having reproducible Y or p self-shielding operties.

The counter shoul be reset to a reproducible efficiency versus ene

. It is not necess to identify specific nuclides.

T determination of the contributors to the E result should be sed upon ose energy peaks identifiable with a 95K confidence level.

The dio-ch seal determination of nuclides should be based on multiple counting o

e sample with typical counting basis following sampling of less than 1 ho about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, about 1 day, about 1 week, and about 1 month.

Reducing~-- -to less than 5004F prevents the release of activity should a steam generator tube rupture since the saturation pressure of the primary coolant is below the liftpressure of the atmospheric steam relief valves.

The surveillance requirements provide adequate assurance that excessive specific activity levels in the primary coolant will be detected in sufficient time to take corrective action.

Information obtained on iodine spiking will be used to assess th'e parameters associated with spiking phenomena.

A reduction in frequency of isotopic analyses following power changes may be permissible if justified by the data obtained.

ST.

LUCIE - UNIT 2 B 3/4 4-7

ADMINISTRATIVE CONTROLS ANNUAL REPORTS (Continued) greater than 100 mrems/yr and their associated man-rem exposure according to work and job functions, e. g., reactor operations and 2/

surveillance, inservice inspection, routine maintenance, special maintenance (describe maintenance),

waste processing, and refueling.

The dose assignments to various duty functions may be estimated based on pocket dosimeter, TLD, or film badge measurements.

Small exposures totalling less than 20% of the individual total dose need not be accounted for.

In the aggregate, at least 80% of the total whole body dose received from external sources should be assigned to specific major work functions.

MONTMLY OPERATING REPORTS

6. 9. 1.6 Routine reports of operating statistics and shutdown experience, including documentation of all challenges to the PORVs or safety valves, shall.

be submitted on a monthly basis to the

NRC, no later than the 15th of each month following the calendar month. covered by the report.

2This tabulati~osuppleaents the requirements of $20.407 of 10 CFR Part 20.

'ST.

LUCIE - UNIT 2 6-17 Amendment No.

18.

St. Lucie Unit 2 Insert 6

17 b.

The results of specific activity analysis in which the primary coolant exceeded the limits of Specification 3.4.8.

The following information shall be included:

(1)

Reactor power history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (2)

Results of the last isotopic analysis for radioiodine performed prior to exceeding the limit, results of analysis while the limit was exceeded and results of one analysis after the radioiodine activity was reduced to less than the limit.

Each result should include date and time of sampling and the radioiodine concentrations; (3) Clean-up system flow history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (4)

Graph of the I-131 concentration and one other radioiodine isotope concentration in microcuries per gram as a function of time for the duration of the specific activity above the steady-state level; and (5)

The time duration when the specific activity of the primary coolant exceeded the radioiodine limit.

GL85-19.EJW

ATTACHMENT 3 SAFETY ANALYSIS Introduction These amendments are submitted to implement the NRC recommendations of Generic Letter (GL) 85-19, "Reporting Requirements on Primary Coolant Iodine Spikes" dated September 27, 1985.

In GL 85-19, the staff determined that the primary coolant iodine spike reporting requirement could be reduced from a short-term report (e.g.,

Special Report or Licensee Event Report) to an item which is included in the Annual Report.

Additionally, the staff determined that the existing requirements to shut down a plant if coolant iodine activity limits are exceeded for 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12-month period can be eliminated.

The St.

Lucie Unit 1

and 2

Technical Specifications 3.4.8, and Bases for these Technical Specifications are proposed to be revised.

Discussion St.

Lucie Unit 1

and 2 Technical Specifications currently include ACTION requirements to be taken when the specific activity of the primary coolant exceeds certain limits.

In Generic Letter 85-19, "Reporting Requirements on Primary Coolant Iodine Spikes,"

dated September 27,

1985, the NRC determined that. the reporting requirements for iodine spiking can be reduced from a short-term report (Special Report or Licensee Event Report) to an item which is to be included in the Annual Report.

The information to be included in the Annual Report is similar to that previously required in the Licensee Event Report but has been changed to more clearly designate the results to be included from the specific activity analysis and to delete the information regarding fuel burnup by core region.

The staff also determined that the existing requirements to shut down a plant if coolant iodine activity limits are exceeded for 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12-month period can be eliminated.

The quality of nuclear fuel has been greatly improved over the past decade with the result that normal coolant iodine activity (i.e.

in the absence of iodine spiking) is well below the limit.

Appropriate actions would be initiated long before accumulating 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> above the iodine activity limit.

In

addition, 10 CFR 50.72(b)(1)(ii) requires the NRC to be GL85-19.EJW

immediately notified of fuel cladding failures that exceed expected values or that are caused by unexpected factors.

Therefore, this Technical Specification limit is no longer considered necessary by the NRC on the basis that proper fuel management by licensees and existing reporting requirements should preclude ever approaching the limit.

Accordingly, FPL proposes to revise the St.

Lucie Unit 1 and 2 ACTION statements to reflect Generic Letter 85-19 proposed revisions and to revise the Bases of this Specification reflecting these revised requirements and to include in the Administrative Controls section the information to be included in the Annual Report.

GL85-19.EJW

ATTACHMENT 4 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION The standards used to arrive at a determination that a request for amendment involves no significant hazards consideration are included in the Commission s regulations, 10 CFR 50.92, which states that no significant hazards considerations are involved if the operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated or (3) involve a significant reduction in a margin of safety.

Each standard is discussed as follows:

(1)

Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The NRC Staff has previously evaluated this change in Generic Letter 85-19, "Reporting Requirements on Primary Coolant Iodine Spikes",'nd determined that the special reporting requirements related to primary coolant iodine spike's are unnecessary.

It has been determined by the NRC that the reporting requirements for iodine spiking can be reduced from a

short-term report (Special Report or Licensee Event Report) to an item which is to be included in the Annual Report.

The information to be included in the Annual Report is similar to that previously required in the Licensee Event Report but has been changed to more clearly designate the results to be included from the specific activity analysis and to delete the information regarding fuel burnup by core region.

The NRC has also determined that the existing requirements to shut down a plant if coolant iodine activity limits are exceeded for 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a

12-month period can be eliminated.

The quality of nuclear fuel has been greatly improved over the past decade with the result that normal coolant iodine activity (i.e. in the absence of iodine spiking) is well below the limit.

Appropriate actions would be initiated long before accumulating 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> above the iodine activity limit.

In addition, 10 CFR 50.72(b)(1)(ii) requires the NRC to be immediately GL85-19.EJW

r

'I N

notified of fuel cladding failures that exceed expected values or that are caused by unexpected factors.

Therefore, this Technical Specification limitis no longer considered necessary on the basis that proper fuel management by licensees and existing reporting requirements should preclude ever approaching the limit.

The changes do not affect assumptions contained in plant safety

analyses, nor do they affect Technical Specifications that preserve safety analysis assumptions.

Therefore, the proposed changes do not affect the probability or consequences of accidents previously analyzed.

(2)

Use of the modified specification would not create the possibility of a new or different kind of accident from any accident previously evaluated.

The NRC has previously evaluated this change in Generic Letter 85-19 and determined that it results in deleting unnecessary reporting requirements.

Additionally, the Technical Specification requiring reactor shutdown is no longer considered necessary on the basis that proper fuel management by licensees and existing reporting requirements in the Code of Federal Regulations should preclude ever approaching the limit. This change deletes reporting requirements and unnecessary shutdown requirements.

A new or different kind of accident is not created since Technical Specification limits on primary coolant specific activity remain unchanged.

(3)

Use of the modified specification would not involve a

significant reduction in a margin of safety.

The changes being proposed by FPL do not relate to or modify the safety margins defined in and maintained by the Technical Specifications.

Therefore, the proposed changes would not involve any reduction in a margin of safety.

Based on the above, we have determined that the amendment request does not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the probability of a

new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a

margin of safety; and therefore does not involve a

significant hazards consideration.

GL85-19.EJW

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