ML18030A385

Requests NRR Confirm TS Interpretation That Recognizes That Unit 2 Level Instrumentation Was Not Intended to Be Required Operable in Unit 2 When Unit 1 Irradiated Fuel Being Moved in Secondary Containment as Long as Unit 1 Operable

ML18030A385
Person / Time
Site:	Susquehanna
Issue date:	12/14/1993
From:	Byram R PENNSYLVANIA POWER & LIGHT CO.
To:	Chris Miller Office of Nuclear Reactor Regulation
References
PLA-4062, NUDOCS 9312220001
Download: ML18030A385 (2)

Text

'I'7/14/1993 I!l:A4 914-774-79nA PPI M II'. I TI'5'Nol Ci PARP'P V

Pennaytvanla Power & Light Company TWO Narth Ninth Streetehllentewn, PA 181M.11?9 ~ 215/774-6161 Robert G. 8yrin Senator V/ce PnegkArnt.iV'vo/oar 21 8/774.7502 DEC 14 1993 Director of Nuclear Reactor Regulation Attention'. Mr. C. L. Miller, Project Director Project Directorate 1-2 Division of Reactor Projects U.S. Nuclear Regulatory Commission Washington, D.C, 20555 SUSQUEHANNA STEAM ELECTRIC STATION REQUEST FOR TECH SPEC INTERPRETATION Llodcet Nos. Sh&7 and 50-3SS

Dear Mr. Miller:

Based on discussions with Mr. R.J. Clark of your staff, PP8c,L is documenting the follovring interpretation of the Susquehanna SES Unit 2 Technical Specifications, and requests your confirmation of its acceptability.

Currently, both SSES units are shutdown. Fuel reload of Unit 1 will be underway shortly, and we are preparing to install the commiltul water level modification in Unit 2 duc to a forced shutdown that occurred on December 11.

In order to install the Unit 2 tnndifications, the associated Unit 2 water level instrumentation (Level 2, r'ef, Technical Specification Table 3,3.2-1, Trip Function 2.a.) must be taken out of service. The Unit 2 Technical Spcciacations rcquirc this instrumentation to be OPERABLE under certain conditions, including while moving irradiated fuel in Secondary Containment.

The Technical RIIecificatiOnS dO nOt Clearly addreSS the COimncn SSES refueling flOOr, Unit 1 irradiated fuel will be moved in Secondary Containment in support of refueling that unit.

Therefore, PPZcL rcqucsts that NRR confirm an interpretation that recognizes that the Unit 2 I'.evel instrumentation was not intended to be required OPERABLE on Unit 2 when Unit 1 irradiated fuel is being moved in Secondary Containment as long as the Unit 1 Water Level instrumentation is fully OPERABLE in accordance with the Technical Specifications.

For your information, no CORP AT,TFRATIONS or operations with the potential for draining the reactor vessel will be perforined on Unit 2 while the water level instrumentation is out of service. Aho, one trip system of Level 2 instrumentation will bc maintained OPERABLE on Unit 2 while the modifications are being performed.

PACiF D'3 HLHS A17-2/R41-2 PLA~2 Mr. C. L. Miller PP&L has rcvicwed these nquircmcnts against thc neve Standard Tcchnical Spccifications (NUREG-1433), and have confirmed that the new Technical Specifications have appropriately deleted the requirement for the Level 2 water level instrumentation to be required OPERABLE when irradiated fuel is being moved in Secondary Containtnent. This confirms our belief that there is no safety basis for the existing requirement in our Technical Specifications. Ve plan to pursue a permanent change to both the Unit 1 and Unit 2 Tcchnical Specifications in the future that will provide consistency with the new STS.

Documented NRR concurrence with this interpretation is requested by Wednesday, December 15, 1993, We currently anticipate that the water level modifications will take no longer than 4 days; this includes post modification testing, Any questions should be directed to Mr. R. Sgarro at (215) 774-7914.

Very truly yours, cc: NRC Document Control Desk (original)

NRC Region I Mr. G. S. Barber, NRC Sr. Resident Inspector - SSES Mr, R. J, Clark, NRC Sr. Project Manager - Rockville