ML20135C978

Provides Request for Notice of Enforcement Discretion Re TS 3/4.7.7.8 for Penetration Room Filtration Sys

ML20135C978
Person / Time
Site:	Farley
Issue date:	02/27/1997
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9703040369
Download: ML20135C978 (9)

Text

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Dne Morzy S:uthIrn Nnclxr Vice President Optratirg Company f arley Project P.O. Box 1295 Birmingham. Alabama 35201 Tel 205 932.5131 SOUTHERN COMPANY Energy to Serve YourWorld" Docket Nos.: 50-348 I

50-364 i

U.S. Nuclear Regulatory Commission ATTN: ' Document Control Desk Washington, DC 20. 55 Joseph M. Farley Nuclear Plant Control Room, Penetration Room, and Containment Purge Exhaust Filtration Systems

_R_gquest for Enforcement Discretion Ladies and Gentlemen:

Technical Specifications (TS) smveillance requirements 3/4.7.7 Control Room Emergency Filtration / Pressurization System (CREFS),3/4.7.8 Penetration Room Filtration System (PRF),

and 3/4.9.14 Containment Purge Exhaust Filter system (CPEF) have been determined to have not been adequately performed. ANSI N510-1980 section 5, 8, and 14 references made in TS surveillance requirements have not been completed in their entirety. No exceptions to ANSI N510-1980 testing requirements have been specifically allowed by the TS surveillance requirements.

FNP had interpreted that only applicable portions of ANSI N510-1980 sections 5, 8, and 14 were required to be performed. Based on discussions with the NRC, SNC understands that the NRC interpretation is that unless allowed by the TS, the FNP ventilation filter test program for the CREFS, PRF, and CPEF systems must fully comply with every detail of ANSI N510-1980 Sections 5,8, and 14. Although these systems are able to perform their intended safety functions, enforcement discretion is needed. As discussed per telephone conference with NRC i

staff on February 26,1997, enforcement discretion was requested and approved to allow I

continued operation of FNP Units 1 and 2 until approval and implementation of a license amendment. This amendment was submitted on February 24,1997. Attachment 1 provides the request for the Notice of Enforcement Discretion.

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U.S. Nuclear Regulatory Commission Page 2 If there are any questions, please advise.

Respectfully submitted,

$1 hu Dave Morey Sworn to andsubscribedbefore me thiso?9 day of 0 1997 WYD

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MJA/ cit: HVACNOE2. doc Attachments:

1. Request :%- Notice of Enforcement Discretion cc: Mr. L. A. Reyes, Region II Administrator Mr. J. I. Zimmennan, NRR Licensing Project Manager, NRR Mr. T. M. Ross, FNP Sr. Resident Inspector Dr. D. E. Williamson, State Department of Public Health l

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ATTACHMENT 1 Request for Enforcement Discretion

Rtquest for Enforcement Discretion 1.

The Technical Specification that will be violated.

Technical Specifications surveillance requirements (SRs) 3/4.7.7 Control Room Emergency Filtration / Pressurization System (CREFS),3/4.7.8 Penetration Room Filtration System (PRF), and 3/4.9.14 Containment Purge Exhaust Filter System (CPEF) have been determined to have not been adequately performed. ANSI N510 1980 sections 5, 8, and 14 references made in TS surveillance requirements have not been completed in their entirety. No exceptions to ANSI N510-1980 sections 5, 8, and 14 testing and inspection requirements have been specifically allowed by the TS surveillance requirements.

i 2.

Circumstances surrounding the situation, including root causes, the need for prompt action, and identification of any relevant historical events.

This situation was discovered because of questions asked during recent NRC inspections related to the design bases of the PRF system. FNP TS SRs currently reference ANSI N510-1980 for performing visual inspections (section 5), verifying system flow rate (section 8), and verifying heater power (section 14) for FNP ventilation and filtration systems. Specific sections within ANSI N510-1980 do not clearly differentiate between testing and inspection required for initial acceptance testing and testing and inspection required for periodic smveillances. In addition, some characteristics of the FNP system designs do not allow for complete application of the 1980 standard without major disassembly or significant breaching of pressure boundaries. The root cause of this event is that during 1984 when FNP TS were revised to incorporate latest industry standard testing requirements, FNP personnel assumed that the standards were provided for technical guidance as opposed to verbatim requirements. Some required steps were assumed to be applicable only as constmetion acceptance test, or only required to be performed after major system modification and repair. In addition, some tests and inspections could not be perfonned because of FNP specific system design or were selected to not be performed because they were not considered necessary or appropriate. Prompt action is needed to avoid undesirable transients potentially associated with unit shutdown due to 1

compliance for non-safety significant issues. This specific event has never occurred before at FNP.

3.

Safety basis for the request, including an evaluation of the sa ety significance and r

potential consequences of the proposed course of action.

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Request for Enforcement Discretion Safety Analysis SNC has performed a detailed review of site procedures for the CREFS, PRF, and CPEF systems and ANSI N510, sections 5,8, and 14. From this review it was determined that discrepancies between site testing procedures and ANSI N510-1980 sections 5,8, and 14 do not affect the abilities of the systems to perform their safety function. This is based on the following:

Some of the discrepancies cannot be tested because they are not applicable to the FNP design. The design of the system has been accepted by the NRC and is described in the FNP FSAR.

Many of the discrepancies are verified through other means than those described in the ANSI N510-1980 sections 5,8, and 14.

Several of the discrepancies are considered acceptance testing by ANSI N510-1980 Table I but are not specifically called out as such in section 5,8, and 14. Acceptance tr.st refers to testing after initial construction and after major system modification or repair.

Some discrepancies are minor in nature.

SNC believes this is a compliance issue and that the current testing performed on these systems is sufficient to ensure that the systems are capable of performing their design safety functions.

Therefore, the safety significance of these discrepancies is low and there are no adverse consequences of continued plant operation. As procedures are revised and plant conditions allow, additional testing will be performed. Should any problems that affect the ability of these systems to perform their intended safety function occur, SNC will notify the hTC.

4.

The basis for the conclusion that the noncompliance will not be of potential detriment to the public health and safety and that neither an unreviewed safety question nor a significant hazard consideration is involved.

Since the CREFS, PRF, and CPEF systems are capable of performing their intended safety functions without strict compliance with ANSI N510-1980 testing requirements, there is no detriment to the public health and safety and neither an unreviewed safety question nor a significant hazard consideration is involved. A significant hazards evaluation is provided below:

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2 f-Request for Enforcement Discretion Significant Hazards Evaluation FNP TS SRs for CREFS and PRF systems currently reference ANSI N510-1980 for performing visual inspections (section 5), verifying system flow rate (section 8), and verifying heater power (section 14) for FNP ventilation and filtration systems. FNP TS SRs for the CPEF system currently reference ANSI N510-1980 for performing visual inspections (section 5). Specific sections within ANSI N510-1980 do not clearly differentiate between testing required for initial acceptance testing and testing required for periodic surveillances. In addition some characteristics of the FNP system designs do not allow for complete application of the 1980 standard without major disassembly or significant breaching of pressure boundaries. As procedures are revised and plant conditions allow, additional testing will be performed. Should any problems that affect the ability of these systems to perform their

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intended safety fimetion occur, SNC will notify the NRC.

ANALYSIS

. Operation of the plant as described above in regards to standards for a determination of no significant hazard as defined in 10 CFR 50.92 (three factor test) is shown in the following:

1. Operation of the Farley Nuclear Plant Units 1 and 2 without fully complying to ANSI N510-1980 sections 5, 8, and 14 does not involve a significant increase in the probability or consequences of an accident previously evaluated. Operation of the Farley Nuclear Plant Units 1 and 2 without fully complying to ANSI N510-1980 sections 5,8, and 14 does not affect the probability of any accident occurring. The consequences of any accident will not be affected since the testing that is being performed is sufficient to ensure l

that the CREFS, PRF, and CPEF ventilation fihration systems will perform their intended safety functions.

Therefore, operation of the Farley Nuclear Plant Units 1 and 2 without fully complying to ANSI N510-1980 sections 5, 8, and 14 does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Operation of the Farley Nuclear Plant Units 1 and 2 without fully complying to ANSI N510-1980 sections 5, 8, and 14 does not create the possibility of a new or different kind of accident from any accident previously evaluated. Testing differences between site procedures and ANSI N510-1980 sections 5,8, and 14 have been evaluated by SNC and none of the discrepancies have the potential to create an accident at FNP. No new system design or testing configuration has resulted from not fully complying to ANSI N510-1980 sections 5, 8, and 14 for testing that could create the possibility of any new or different kind of accident from any accident previously evaluated.

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Request for Enforcement Discretion l

Therefore, operation of the Farley Nuclear Plant Units I and 2 without fully complying to ANSI N510-1980 sections 5,8, and 14 does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. The operation of the Farley Nuclear Plant Units I and 2 without fully complying to ANSI N510-1980 sections 5, 8, and 14 does not involve a significant reduction in a margin of safety. Current testing performed does ensure that the CREFS, PRF, and CPEF filter ventilation systems will perform their intended safety functions. As a result, no significant reduction of margin with respect to plant safety as defined in the Final Safety Analysis Report or the bases of the FNP technical specifications will occur.

Therefore, operation of the Farley Nuclear Plant Units 1 and 2 without fully complying to ANSI N510-1980 sections 5,8, and 14 does not involve a significant reduction in a margin ofsafety.

CONCLUSION Based on the preceding analysis, it is concluded that operation of the Farley Nuclear Plant in accordance with the proposed amendment does not involve a significant hazards consideration as defined in 10 CFR 50.92.

5.

The basis for the conclusion that the noncompliance will not involve adverse consequences to the environment.

The proposed amendment request does not affect normal operation of the units and does not alter any accident analysis results. Therefore, this will not involve any significant change in the types or amounts of effluents that may be released offsite and no increase in the individual or cumulative occupational radiation exposure. Therefore, this request for enforcement discretion does not involve any adverse environmental consequences.

6.

Proposed compensatory measures.

Some testing required by the ANSI N510-1980 can not be performed either because the FNP specific design features do not exist, major disassembly is required, or significant breaching of required pressure boundaries is necessary. As procedures are revised and plant conditions allow, additional testing will be performed. Should any Al-4

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Request for Enforcement Discretion

'i problems that affect the ability of these systems to perform their intended safety function occur, SNC will notify the NRC. SNC has performed detailed evaluations that have determined that the CREFS, PRF, and CPEF filter ventilation systems can perform their intended safety functions. A Technical Specification change request has l

been submitted to correct and clarify this situation.

7.

Justification for the duration of the noncompliance.

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Thejustification for the duration of this noncompliance is that the CREFS, PRF, and CPEF filter ventilation systems are capable of performirg their intended functions.

SNC has performed detailed evaluations using the guidmee provided in GL 91-18 for nonconforming conditions as a guideline, and failure to meet strict compliance to ANSI N510-1980 for minor elements of testing and inspection does not affect the ability of these systems to perform their safety functions. SNC has performed a detailed review of site procedures for the above filter ventilation systems and ANSI N510-1980 sections 5, 8, and 14. From this review it was determined that discrepancies between site testing procedures and ANSI N510-1980 sections 5, 8, and 14 do not affect the operability of these systems, and SNC has taken prompt action to resolve this issue by

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submitting a TS change and performing additional testing and inspections where possible. This condition will be fully corrected following NRC approval of the submitted TS and SNC implementation.

Currently SNC is performing modifications to the B Train of Control Room Air Conditioning in accordance with amendments 119 and 111 of Units 1 and 2 respectively. This amendment allowed for inc*allation of new control room air conditioning units. Testing of A Train CREFS at this time would pose incressed risk for operability due to these modifications.

8.

Review by the Plant Operations Review Committee.

This request for enforcement di.,cretion has been reviewed and approval has been recommended by the organizaticn tasked to advise the General Manager - Nuclear Plant on all matters related to nuclear safety at Farley Nuclear Plant, i.e., the Plant Operations Review Committee.

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4 Request for Enforcement Discretion 9.

Satisfaction of NOED criteria.

This NOED is intended to avoid undesirable transients as a result of compliance with a license condition and, thus, minimizing potential safety consequences and operational risks. The CREFS, PRF, and CPEF systems are fully capable of performing their safety functions. Consequently, to shutdown the plant and test these systems beyond what has already been performed will not provide any additional margin of safety; however, it will result in unnecessary operational transients without any benefit. Southern Nuclear believes that it has met the criteria for NOED as provided in NRC Inspection Manual Part 9900: 10 CFR Part 2 Appendix C Enforcement Discretion section B (1).

e 10.

Marked-up Technical Specification pages showing the proposed changes.

The proposed changes have already been submitted under separate letter transmittal.

11.

Prior adoption of approved line-item improvements to the technical specifications of the improved technical specifications would not have obviated the need for the NOED request.

SNC has previously committed to adopt improved technical specifications to address this issue. Our package development is well underway with full submittal of the ITS j

conversion package schedule in the April /May time frame.

12.

Additional information requested by NRC Staff.

At this time no additional information has been requested by the staff.

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