ML20135A999

Requests NRC Review & Concurrence of FNP Interpretation and Basis for TS 3/4.9.13, Storage Pool Ventilation (Fuel Movement)

ML20135A999
Person / Time
Site:	Farley
Issue date:	11/27/1996
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9612040123
Download: ML20135A999 (3)

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Dave Morer Southera Nuclest Vice President Operating Company Farley Project P0. Box 1235 Birmingham. Alabama 35201

'lel 205.992.5131 November 27, 1996 SOUTHERN COMPANY Docket Nos.: 50-348 Energy to Serve YourWorir 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Joseph M. Farley Nuclear Plant Technical Specification 3/4.9.13 Storage Popl ycnlilation (Fuel Movement)

Ladies and Gentlemen:

Recent differing opinions have arisen concerning application of Technical Specification 3/4.9.13 Storage Pool Ventilation (Fuel Movement) at Farley Nuclear Plant during modes 5, 6, or when defueled. The purpose of this letter is to request NRC review and concurrence of the FNP interpretation and basis for this technical specification. FNP is presently preparing a Technical SpeciEcation amendment to implement NUREG 1431, Rev. I and has committed to the NRC to do so in previous correspondence. Attachment I provides our position.

Respectfully submitted, d

0h blat Dave Morey MJA:maf fuelv2. doc Attachment cc:

Mr. S. D. Ebneter f

Mr. J. I. Zimmerman s

Mr. T. M. Ross

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I 9612040123 961127 PDR ADOCK 05000348 P

PDR 040044

FNP Technical SpeciGcation 3/4.9.13 Storane Pool Va=*n=*i- (Fuel Mov==an I=earor *=*ia=

l Technical Specification (TS) Limiting Condition For Operation 3.9.13 Two independent inadion room filtration systems (Specification 3.7.8) shall be OPERABLE and aligned to the spent fuel pool room:

APPLICABILITY: During crane operation with loads, over the fuel in the spent fuel pit and during fuel movement within the spent fuel pit.

Position:

A question has arisen as to whether the electncal system requirements for penuration room filtration system (PRF) in modes 5 or 6 are the same as required by TS 3.8.1.2.

In modes 5 or 6, TS 3.8.1.2 "Electncal Power" requires one circuit from the offsite transmission

' network to the switchyard and from the switchyard to the onsite Class IE distribution system, and one diesel generator. His is consistert with the FNP licensing basis described in the FSAR.

i-Therefore, when the plant is in mo&s 5 or 6 and normal power is available to both PRF systems through a single offsite power source (i.e. the normal in-plant IE distribution is cross enaa~'~I) and a single diesel generator is available, then both wanion filtration systems can be considered i

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OPERABLE. When the plant is defueled, modes 5 and 6 requirements can be applied.

1 Basis:

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hxiependence as used in 3.9.13 implies mechanical and electncal ir-f-W= consistent with the licensing basis for FNP. The FNP licensing basis only requires consideration of single failure coincidence with loss of offsite power in modes 1,2,3, or 4. In modes 5 and 6, the electrical

power TS requirements do not consider a single failure coincident with a loss of offsite power. The applicability of this TS is not mode Mt; however, no limiting condition of operation or surveillance requirement statement explicitly states that additional electrical power sources are l

required in modes 5 and 6. Therefore, reliance on TS 3.8.1.2 for the electrical power sources n

required in modes 5 and 6 must be assumed. Review of the applicable accident analyses show that a single PRF system is capable of ensuring that 10 CFR 100 limits of offsite dose are not reached j

in the event the worst case assumed dropped fuel assembly event occurs.

i TS 3.9.13 LCO also rr.akes reference to TS 3.7.8. This reference is required to clearly designate which PRF systems are required to support and meet fuel storage pool ventilation requirements.

Without this reference the licensee could conceivably meet this requirement with other than intended filtration systems It is not intended to imply that modes I,2,3, or 4 requirements are required for the PRF system anytune TS 3.9.13 applies.

Improved Techmcal Specifications (ITS) (NUREG 1431) clarifies this condition. In the new LCO for the PRF system the term i.Mt is e imiawai. He PRF LCO requires that two PRF i

trams shall be OPERABLE. De ITS definition of OPERABLE is hig=i to ensure that the specified safe function is met. It states that normal or emergency electrical power be available.

De ITS AC mwces requirements in modes 5 or 6 are consistent with the existing FNP requirements The ITS "AC Sources - Shutdown" bases (3B.3.8.2) state that for modes 5, 6, and during movement ofirradiated fuel assemblies, adequate AC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident. It states the followmg

i "In general, when the u.iit is shutdown, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite poweris not required."

Furthennore the ITS bases state:

"In the event of an accident during shutdown, this LCO ensures the capability to support systems necessary to avoid imnwhate difficulty, assuming either a loss of all offsite power or a loss of all onsite diesel generator (DG) power."

The applicable accident analyses as described in the FNP FSAR are consistent with this basis and show that tim intent of PRF operability during movement of fuel or loads over fuel in the fuel

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storage area is met considering only modes 5 or 6 electrical distribution requirements.

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