ML20113A799

Application to Revise Ts,Reflecting Implementation of 10CFR50,App J,Option B & Represent Crossed Beneficial Licensee Actions

ML20113A799
Person / Time
Site:	Farley
Issue date:	06/20/1996
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20113A802	List: ML20113A799 ML20113A805
References
NUDOCS 9606250347
Download: ML20113A799 (12)

Text

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l Southtrn Nuchar op;ratm0 Company

Post Offica Box 1295 Birmingham. Alabama 35201 Telephone (205) 868 5131 L

l o.ve uorey Vice Presir,ont Southern Nudear Operating Company "

Farley Proect the Southem electnc System June 20, 1996 Docket Nos.: 50-348 10 CFR 50.90 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington,DC 20555 Joseph M. Farley Nuclear Plant Request to Revise Technical Specifications 10 CFR 50. Appendix J. Option B Ladies and Gentlemen: ,

In accordance with the provisions of 10 CFR 50.90, Southern Nuclear Operating Company (SNC) hereby proposes changes to the Farley Nuclear Plant (FNP) Unit 1 and Unit 2 Technical Specifications (TS). The proposed changes reflect implementation of 10 CFR 50, Appendix J, Option B. This submittal includes the request to revise the TS and the implementation plan as required by Option B.

SNC has determined that this submittal represents a Cost Beneficial Licensing Action (CBLA),

in that the implementation of this request can result in a savings of approximately ten million dollars over the life of the plant based on industry cost estimates. SNC requests that this revision be approved by October 1,1996 in order for the change to be implemented during the FNP Unit 21Ith refueling outage in the Fall of this year. SNC will implement the proposed license amendment within 30 days of NRC issuance.

Enclosure 1 provides the background, description and safety basis for the proposed changes.

Enclosure 2 details the bases for SNC's determination that the proposed changes do not involve a significant hazards consideration nor significantly affect the quality of the environment. Enclosure 3 includes SNC's 10 CFR 50, Appendix J, Option B, implementation plan. Enclosure 4 provides page change instructions and revised TS and TS Bases pages for incorporating the proposed changes. Enclosure 5 provides the corresponding marked-up TS and TS Bases pages.

l 9606250347 960620 PDR ADOCK 05000348 P PDR l

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U. S. Nuclear Regulatory Commission Page Two In accordance with the requirements of 10 CFR 50.91, the designated State official will be sent a copy of this letter and all applicable enclosures. l The information provided herein is tme to the best of my knowledge and belief. If you have any questions, please advise.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY l ))

Dave Morey Sworn to andsubscribed before me this k day of M ,1996. \

hdAd Y d< t.-

'No'tary Public  !

My Commissicn Expires: My,1997 '

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EFB/ cit:appj_ts. doc

Enclosures:

1. Basis for Change Request

2. 10 CFR 50.92 Evaluation and Environmental Assessment

3. 10 CFR 50, Appendix J, Option B, Implementation Plan

4. Page Change Instructions and Revised TS Pages

5. Marked-up TS and TS Bases Changes cc: Mr. S. D. Ebneter, Region II Administrator Mr. B. L. Siegel, NRR Senior Project Manager Mr. T. M. Ross, FNP Sr. Resident Inspector Dr. Donald E. Williamson, State Department of Public Health

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Enclosure 1 Joseph M. Farley Nuclear Plant Request to Revise Technical Specifications:

Basis for Channe Recuest l i

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1 Enclosure 1 i

Joseph M. Farley Nuclear Plant Request to Revise Technical Specifications:

Basis for Channe Reauest i

Backaround 4

he contamment leakage rate testing program required by 10 CFR 50 Appendix J includes performance

of an Integrated Leakage Rate Test (ILRT) or Type A test, and Local Leakage Rate Tests (LLRTs) or Type B and C tests. The Type A test measures overall leakage rate of the reactor containment. The j Type B test detects leakage paths and measures leakage for certain containment penetrations. The Type

C test measures contamment isolation valve leakage rates.

l Appendix J testing requirements ensure leakage through the containment, as well as systems and j

components penetrating contamment, does not exceed the allowable leakage rate values specified in the  !

l TS or the associated Bases. Compliance with Appendix J testing requirements ensures the containment configuration is structurally sound and capable oflimiting leakage to the rates assumed in the safety analysis. These requirements also ensure an adequate containment boundary is maintained during and a

after an accident by minimizmg potential leakage paths to the environment, thereby assuring the j containment function assumed in the safety analysis is maintained.

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On September 12,1995, the NRC approved issuance of a revision to 10 CFR 50 Appendix J which

became effective on October 26, 1995. The NRC added Option B, " Performance-Based i Requirements," to allow licensees to voluntarily replace the prescriptive testing requirements of 10 CFR

} 50 Appendix J with testmg requirements based on both the overall leakage rate performance and the

{ performance ofindividual components.

I Regulatory Guide 1.163, " Performance-Based Containment Leak-Test P:ogram," dated September

, 1995 was developed as a method acceptable to the NRC staff for implementing Option B. Regulatoy l Guide 1.163 specifies an extension in Type A test frequency from three tests in ten years to at least one j test in ten years based upon two consecutive successful tests. Type B tests may be extended up to a

maximum interval of ten years based upon two consecutive successful tests and Type C tests may be extended up to a maximum interval of five years based upon two consecutive successful tests.

$ Regulatory Guide 1.163 endorses Nuclear Energy Institute (NEI) 94-01 Revision 0 dated July 26,1995,

, " Industry Guideline for Implementing Performance-Based Option of 10CFR50 Appendix J", with some exceptions. NEI 94-01 endorses ANSI /ANS - 56.8 - 1994, "Contamment System Leakage Testing Requirements," for detailed descriptions of the technical methods and techniques for performing Types A, B, and C tests with some exceptions.

On November 2,1995, the NRC transmitted a set of TS changes, based on the Improved TS model, to the Nuclear Energy Institute to serve as a model for licensees to develop plant specific TS in preparing amendment requests to implement Option B. Although FNP has not yet incorporated the full Improved j TS model, the proposed changes to incorporate 10 CFR 50, Appendix J, Option B, requirements were prepared and customized to be consistent with the NRC - approved model TS.

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I Enclosure 1 Request to Revise Technical Specifications:

Basis for Change Reauest Description of Change SNC proposes changes to the FNP TS in order to permit implementation of 10 CFR 50, Appendix J, Option B. 'Ihe TS are being changed to establish and reference a " Containment Leakage Rate Testing Program". The program will be added to the Admmistrative Controls portion of the TS. The new Specification 6.16, Contamment Leakage Rate Testing Program, includes the definition of P. and L. and specifies the leak rate acceptance criteria for Type A, B, and C tests and air locks. This specification commits that the program will be in accordance with Regulatory Guide 1.163 dated September 1995.

The only currently approved exemption to 10 CFR 50, Appendix J for FNP allows relief from the requirement in Paragraph III D.2(b)(ii), which states, " Air Locks opened during periods when contamment integrity is not required by the plant's TS shall be tested at the end of such period at not less than P.." This exemption from testing is allowed if the airlock surveillance is within its 6 month frequency and no maintenance has been done on the air lock that could affect the air lock sealing capability. The exemption, currently noted in TS 4.6.1.3.b.2, is being replaced by the Contamment Leakage Testing Program requirements. The new program requirements are in compliance with 10 CFR 50, Appendix J, Option B and NRC Regulatory Guide 1.163 which provide the desired flexibility; therefore, the exemption is no longer needed A requirement to perform a periodic visual inspection of exposed accessible interior and exterior surfaces of contamment has been added.

Duplicative details between these specifications and the 10 CFR 50, Appendix J regulations are being deleted. Other details not recommended for inclusion by the NRC - approved model TS are being moved to the Contamment Leakage Rate Testmg Program A mark-up ofwh unit's TS sections affected by the proposed changes is included in enclosure 5 .

Safety Assessmen_t The effect of increasing contamment leakage rate testmg intervals has been evaluated by the Nuclear Energy Institute using the methodology described in NUREG-1493, " Performance-Based Contamment Leak-Test Program," and historical representative industry leakage rate testing data. The results of this evaluation, as published in NEI 94-01, Revision 0, are that the increased safety risk correspondmg to the extended test intervals is small and compares well to the guidance of the NRC's safety goal. ILRTs have been &=m.ied to be of limited value in Wing significant leakages from penetrations and isolation valves. The containment leak rate data and component performance history at FNP are consistent with the conclusions reached in NUREG-1493 and NEI 94-01. "Iherefore, the proposed license amendments adopting a performance-based approach for verification of leakage rates for isolation valves, contamment psaations, and the contamment overall will continue to meet the regulatory goal of providing an essentially leak-tight contamment boundary (10 CFR 50, Appendix A, GDC 16), and will provide an equivalent level of safety as the current requirements.

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k Request to Revise Technical Specifications:

Basis for Channe Request The revised TS will continue to maintain the allowable leak rate (L.) as the overall containment leakage rate acceptance criterion. In addition, a requirement to perform a periodic general visual inspection of the containment is part of the performance based leakage testing program.

As supported by the findings of NUREG-1493, the percentage of leakages detected only by ILRTs is small (only a few percent) and Type B and C leakage tests are capable of detecting more than 97 percent of contamment leakages. During plant startup following testing in accordance with the Contamment Leakage Rate Testing Program, the leakage rate acceptance criteria for the combined Type B and C tests is conservatively limited to less than or equal to 0.60 L. to account for possible degradation between tests.

In conclusion, implementing the 10 CFR 50, Appendix J, Option B requirements for performance-based leakage testing at FNP does not impact plant safety margins.

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Enclosure 2 Joseph M. Farley Nuclear Plant Request to Revise Technical Specifications: i l

10 CFR 50.92 Evaluation and Environmental A=sessment  !

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. Enclosure 2

{ Joseph M. Farley Nuclear Plant j Request to Revise Technical Specifications:

j 10 CFR 50.92 Evaluation and Environmental Assessment

Proposed Channes i

5 The proposed changes incorporate 10 CFR 50, Appendix J, Option B, requirements into the FNP Technical Specifications (TS) in accordance with NRC Regulatory Guide 1.163, Resision 0 dated j September 1995, " Performance-Based Contamment Leak-Test Program" R.G.1.163 endorses Nuclear Energy Institute (NEI) 94-01, Revision 0, dated July 26,1995, " Industry Guideline for Implementing Performance Based Option of 10 CFR 50 Appendix J" with certain exceptions.

4 10 CFR 50.92 Evaluation j

Southern Nuclear Operating Company (SNC) has reviewed the proposed TS changes and determined l they do not involve a significant hazards consideration based on the following:

1. He proposed changes do not involve a significant increase in the probability of consequences of an accident previously evaluated. He proposed changes provide a mechanism within the TS for implementing a performance-based leakage rate test program which was promulgated by the revisica to 10 CFR 50 to incorporate Option B to Appendix J. He proposed changes do not involve any physical or operational changes to structures, systems or components. He proposed TS Limiting Conditions for Operation (LCO) are consistent with 10 CFR 50, Appendix J requirements and are equivalent to the current LCO requirements. The current safety analyses and safety design basis for the accident mitigation functions of the contamment, the airlocks, and the contamment isolation valves are maintained. Since the allowable containment leakage is still maintained within the analyzed limit assumed in the accident analyses, there is no adverse effect on either onsite or offsite dose consequences. Furthermore, contamment leakage is not an accident initiator. Therefore, these changes will not increase the probability or consequences of an accident previously evaluated.

2. The proposed changes do not create the possibility of a new or different kind of accident from any accident previously analyzed. De proposed changes do not involve any physical or operational changes to structures, systems or components. No new failure mechanisms beyond those already considered in the current plant safety analyses are introduced. Herefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident presiously

analyzed.

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Enclosure 2 Request to Revise Technical Specifications:

10 CFR 50.92 Evaluation and Environmental Assessment

3. He proposed changes do not involve a significant reduction in the margin of safety. Extending Type A, B, and C test intervals from those currently provided in the TS to those provided for in 10 CFR 50 Appendix J, Option B slightly increases risk due to an increased likelihood of containment leakage corresponding to the increased testing intervals. However, this is somewhat compensated by the corresponding risk reduction benefits received from the reduction in component cycling, stress, and wear associated with the increased intervals. When considering the total integrated risk, which includes all analyzed accident sequences, the additional risk associated with increasing test intervals is negligible.

The NRC letter to NEI dated November 2,1995, recogmzes that changes similar to the proposed changes at FNP are required to implement Option B of 10 CFR 50, Appendix J. In NUREG-1493, " Performance-Based Containment Leak-Test Program," dated September 1995, which forms the basis for the Appendix J revision, the NRC concludes that adoption of performance-based test intervals for Appendix J testing will not significantly reduce the margin of safety. The containment leak rate data and component performance history at FNP are consistent with the conclusions reached in NUREG-1493 and NEI 94-01. Hus, the proposed license amendments do not involve a significant reduction in a margin of safety and will continue to support the regulatory goal of ensuring an essentially leak-tight containment boundary.

Environmental Assessmsnt He proposed changes will have no significant impact on the environment. The proposed change does not involve a significant hazards consideration as discussed in the preceding section. He proposed change does not involve a significant change in the types or significant increase in the amounts of any effluents that may be released offsite. No new contamment boundary changes or changes to existing contamment boundary systems are proposed. There is no increase in the consequences of any previously evaluated accidents. Implementation of a performance-based contamment leakage rate testing approach will allow test intervals to be based on system and component performance. Therefore, the increased test intervals that are pennitted under this program are expected to decrease cumulative occupational exposure of employees conducting ILRTs and LLRTs. In conclusion, the proposed changes will have no significant impact on the environment.

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Enclosure 3 l i

Joseph M. Farley Nuclear Plant l Request to Revise Technical Specifications-l 10 CFR 50. Accendix L Ootion B. Imolementation Plan  !

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Enclosure 3 Joseph M. Farley Nuclear Plant Request to Revise Technical Specifications:

10 CFR 50. Appendix J. Option B. Implementation Plan Osnstal Southern Nuclear Operating Company (SNC) intends to implement the requirements of 10 CFR 50, Appendix J, Option B shortly following issuance of the requested license amendments. 10 CFR 50 Appendix J, Option B states:

" Specific guidance concerning a performance based leakage test program, acceptable leakage-rate test methods, procedures, and analyses that may be used to implement these requirements and criteria are provided in Regulatory Guide 1.163."

FNP's leakage rate testing program will be in compliance with 10 CFR 50, Appendix J, Option B and Regulatory Guide 1.163 prior to implementation of the TS amendments. Regulatory Guide 1.163 endorses NEI 94-01 with certain exceptions. NEI 94-01 further endorses ANSI /ANS-56.8-1994 for details describing how the testing should be performed with certain exceptions. In addition, SNC intends to maintain the option to continue using the BN TOP-1, " Testing Criteria for Integrated Leak - Rate Testing of Pnmary Contamment Structures for Nuclear Power Plants," Revision 1, November 1972" method for performing Type A tests.

Procedures and Documental 19n The procedures for the containment leakage rate testing program will follow the requirements and contain the performance criteria for the Types A, B, and C testing. He procedures will also contain the description of the record keeping and methodology to establish test intervals for equipment and components in the contamment leakage rate testing program.

The results of Type A, B, and C tests will be documented to show that performance criteria for leakage rates are met. Comparison with previous results will be documented to show that the test intervals established are adequate. These records will be available for inspection at the plant site. Failed tests will be reported in accordance with the existing 10 CFR 50.72 and 10 CFR 50.73 requirements.

Interval Extensions If data justifymg the extension of a Type B or C test interval have not been evaluated, the test interval will continue to be every refueling cycle. Any Type B and C tests conducted after amendment implementation will utilize ANSI /ANS-56.8 methodology.

In some mstances FNP's Inservice Testmg Program references the use of Appendix J testing requirements to meet ASME Code valve exercising or closure test requirements. If Appendix J testing methodology is utilized to satisfy these ASME Code test requirements, the test interval in these cases will be determmed by the ASME Code criteria and not the Appendix J Option B interval extension criteria.

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I Enclosure 3 Request to Revise Technical Specifications:

10 CFR 50. Appendix 1 Option B. Implementation Plan NEI Guideline Clarifications Sections 8.'O and 10.2 of NEI 94-01 recommend that the combined as-found leakage rates (Type B and C tests) determined on a Minimum Pathway Leakage Rate (MNPLR) basis for all penetrations be <

0.60 L, when containment integrity is required. The TS requirement is that the overall leakage rate be 5

!, The TS acceptance criterion is a reflection of the safety analysis assumptions. As an added  ;

conservatism, the measured leakage rates are further limited to 5 0.60 L. during performance of tests to I account for possible degradation of the contamment leakage barriers between leakage tests. Therefore, l SNC considers the 0.60 L. to be a performance limit, not a TS operability limit.

l NEI 94-01 and ANSI /ANS-56.8-1994 indicate that for a two barrier pathway, the Maximum Pathway l Leakage Rate (MXPLR) is the measured leakage through the worst of the two isolation valves. If a

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penetration is isolated by use of one closed and deactivated automatic valve, closed manual valve, or '

blind flange, SNC considers the MXPLR of the isolated penetration to be the measured leakage through the closed isolation device for purposes of satisfying the as-left leakage acceptance criteria.

NEI 94-01 Section 10.2.2.1 which addresses containment airlock test intervals states, " Door seals are not required to be tested when contamment integrity is not required, however they must be tested prior to reestablishing contamment imegrity." SNC's position is that testing would not be required if a plant shutdown occurs, no contamment entry is made, and airlock testing is otherwise current.

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