ML20138E944

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Discusses 960208 Guidance Issued to All Project Managers Re Review of Plant Specific Licensing Basis Requirements W/Respect to SFP Cooling & Core Offload Activities
ML20138E944
Person / Time
Issue date: 03/01/1996
From: Stolz J
NRC (Affiliation Not Assigned)
To:
NRC (Affiliation Not Assigned)
Shared Package
ML20137R957 List:
References
FOIA-96-485 NUDOCS 9603110370
Download: ML20138E944 (13)
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Text

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UNITED STATES

., j gn neong'o,'~

NUCLEAR REGULATORY COMMISSION f, ,

a. T REGION 11 d o 8

101 MARIETTA STREET, N.W., SUITE 2000 ATLANTA, GEOMGIA 303234190 C

C March 1, 1996 ,

%> . . . . . lE .

I MEMORANDUM T0: I All NRR Project Managers and Project Directors FROM: John F. Stolz, Director -

Project Directorate I-2 Division of Reactor Projects - I/II i

SUBJECT:

SPENT FUEL P00L LICENSING BASIS REVIEW GUIDANCE, REVISION AND CLARIFICATION

.By memo dated February'8, 1996, guidance was issued to all project managers regarding a review of plant specific licensing basis requirements with respect to spent-fuel pool cooling and core offload activities. The memo provided background information as well as detailed guidance on how to extract specific licensing requirements from various licensing documents. The inemo also provided guidance on how to document your review. j Subsequent to issuing the February 8, 1996 guidance, the staff had cause to l revisit the Standard Review Plan Section 9.1.3 on spent fuel pool cooling l system design. Based on the this re-review, new interpretations of the SRP 9.1.3 guidance regarding single failure capability during refueling operation have been formulated. l l

In addition, project manager experience since the start of the licensing basis ]

review in January 1996 confirms wide variance in licensing basis documentation '

between plants and confirms that most plant licensing basis differ from the stylized presentation in SRP 9.1.3.

Because of the recently revised technical position on single failure applicability and because of the wide variation in licensing bases among the '

plants, it is not possible to develop generic guidance by which a plant PM can efficiently determine the licensing requirements and ensure a consistent  :

review for all of the plants. Therefore, the project review process is being i revised as discussed below: ,

1 (1) Project Managers should compile the licensing basis documents for their plants regarding spent fuel pool cooling systems. These documents should include: (1) relevant TS pages, (2) FSAR sections on spent fuel pool cooling, (3) most recent rerack amendments (if applicable); (4) licensee submittal for most recent rerack amendment (if applicable), (5) any other license amendment documents that are concerned with spent fuel pool decay heat removal or refueling activities.

Project managers should provide copies of these documents to the lead PM in accordance with the attached schedule.

CONTACT: Joe Shea, NRR 415-1428 h oano.Bao-W D '

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-(2) The _ technical staff, with assistance from DRP; will determine and.

. document the applicable licensing basis requirements in regard to -l spent fuel pool decay heat removal and refueling activities.. This~ a activity equates to Part B of the sample spent. fuel. pool CLB; review i provided in the February 8;.1996 guidance document, but will now include the current interpretation of the guidance in SRP 9.1.3. A 4

. summary of the licensing basis requirements will be returned to the  !

plant-project manager in accordance with the attached schedule.

L(3) Project managers will then need to complete a review of how the  !

licensee operates within the licensing requirements set forth in .(2) 1 above. _

It'is recognized that many project managers, alone or in conjunction l with regional staff, have completed their onsite reviews already. .

These PMs should evaluate whether the procedures and practices reviewed during their onsite visit are sufficient to confirm .

compliance with the licensing basis requirements prepared by the  !

technical staff. ~If not, project managers should coordinate with '

residents to augment the project manager's onsite review. j For project managers who have not performed their onsite reviews, use the licensing basis requirements summary provided by the i technical staff in (2) above as the basis for your review. Document  !

how the licensee demonstrates compliance with each requirement.

If there are instances where the licensee's practice does not '

conform to the licensing basis requirements, these should be immediately discussed with the respective project director, the lead l project manager and the Plant Systems Branch. l l

'If it is determined that corrective measures are needed,"

communication with the licensee will be conducted promptly to preclude non-conformance with the licensing basis for.an upcoming reload. ,

(4) Upon completion of the compliance review, project managers should i assemble a plant specific project report similar to the sample  !

provided in the February 8, 1996 guidance. The spent fuel pool ~ 1 cooling / core offload licensing review report should consist.of a i brief system description, the licensing basis requirements summary  ;

prepared in (2) above, a' documentation of tt.e compliance review . -

performed in (3) above' and the design data table as originally issued in the February 8, 1996 guidance.  ;

Project managers should complete the entire report in accordance

. with the schedule. attached. Note that the completion time for all reports has slipped slightly to April 9,1996, in order to allow for .

somelloss of schedule caused by this revised guidance. All data j

. tables should also be completed by April 9,1996.  ;

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- - . . .,~ _ . . . . -- . . - . . .-.. -

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i Project managers should forward their completed' reports to their project directors and should provide copies to the lead PM, Joe Shea, by April 9,.1996, and to the resident inspectors and the ,

regional DRP branch chief. j Your. continued support for this significant regulatory activity is -

appreciated. .

Attachment:

Schedule for Completion of Spent. Fuel Pool Licensing Review .

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SCHEDULE FOR COMPLETION OF SPENT FUEL P0OL LICENSING REVIEW Activity dates'are provided by plant groupings. Plant / group number reference is on next page. Group assignments are approximately related to. plant outage schedule.- ,

(1). Provide current licensing basis source documents to Lead PM (including j

FSAR sections, rerack documents, relevant TS pages, and other relevant g license amendment documents as applicable)
j PLANT GROUPING DATE TO PROVIDE SOURCE DOCUMENTS TO LEAD PM 1 3/6/96 2 3/8/96 3 3/13/96.

4 3/13/96 5 3/13/96 (2) Plant systems branch to provide licensing basis requirements summary document back to plant PM:

PLANT GROUPING' DATE SPLB TO PROVIDE ,

RE0VIREMENTS

SUMMARY

TO PM  !

1 3/8/96 2 3/13/96 3 3/18/96 4 3/21/96 1 5 3/26/96 i (3) PMs complete compliance reviews and data table:

PLANT GROUPING DATE PM TO PROVIDE CLB REVIEW DOCUMENTATION 1 4/9/96 2 4/9/96  :

3 4/9/96 4 4/9/96 5 4/9/96 i

i 1

l REVISED' SPENT FUEL POOL LICENSING. REVIEW PROJECT

< PLANT PRIORITY GROUP LISTING.  ;

GROUP (1)

Turkey' Point Beaver Valley Oconee Point Beach ,

, Calvert Cliffs Browns Ferry Diablo Canyon Palo Verde Hatch Byron Braidwood 'DC Cook Ginna ,

GROUP (2)

River Band Limerick Perry Vogtle  ;

Big Rock Point North Anna Brunswick

  • Prairie Island Commanche Peak Wolf Creek '

LaSalle Crystal River Quad Cities

'l GROUP (3)

J' . South Texas Sequoyah Robinson Zion  !

McGuire St. Lucie Susquehanna , Surry  !

Davis Besse Oyster Creek Grand Gulf Summer Monticello Catawba Peach Bottom

{ WNP-2 Vermont Yankee Dresden 4-

GROUP (4)

Indian Point 3 Callaway SONGS NMP-2 Kewaunee Duane Arnold Palisades Farley

, Ft'Calhoun Clinton NMP-1 ANO-1 Haddam Neck FitzPatrick ANO-2 Fermi a

GROUP (5)

Pilgrim Millstone 3 Seabrook Cooper Shearon Harris Maine Yankee Salem McGuire

. Waterford Millstone 2 Millstone 1 TMI Indian Point 2 Watts Bar Hope Creek j

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ITEM DETAIL REPORTS .

IFS . INSPECTION FOLLOW-UP SYSTEM - 'DATE: 02/23/% :

iST LUCIE OPEN ITEMS LIST - REPORT BY SITE TIME: 12:01:01--

PAGE: 2 SITE:-.STL ST LUCIE.

. UNIT 'RPT/IF5/ SEO-ND' ITEM REF NBR / SEVERiiY .5 ALP REPORT / STS CREATE CLOSEOUT -CLSOUT: CLSOUT UPDATIE .

ABBR' EA/ NBR NOV-ID TYPE EA-NBR SUPLMNT AREA EVENT DT. DATE- PRJ/ACT* ORG NO EMP INSPECTION REPORT 5

. STL2 '..I 93-025 01 IFI. .

12/01/93 0 12/07/93 2350  :

TIRE: REVIEW OPERABILITV 0F UNIT 2 MOV MV-08-13 DURIE THE COP 9fENTS: REVIEW OPERABILITY OF UNIT 2 MOV MV-08-13 DURING THE PERIOD -

JULY 20 TO OCTOBER 19. 1993.'

STL1 :I 94-008 03 URI EE 04/08/94- 0 04/13/94 -2310 JVL

_ TITLE: QUALITY LEVEL OF PORV AND SRV DISCHARGE PIPIE

-STL1 1 94-010 01 VIO 4/1 EE 04/28/94 0 05/03/94 2310- BRC' t TIRE: - FAILURE TO MEET WELD PREP DIMENSIONAL TOLERANCES ON I COMMENTS: CONTPARY TO 10 CFR 5. APPEWIX R. CRITERION V AND XI. ON ,

APRIL'7. 1994. ACTIVITIES AFFECTING OUALITY WERE NOT +

ACCOMPLISHED IN ACCORDANCE WITH PRESCRIBED PROCEDURES r A2 THE PROGPAM FOR INSPECTION OF ACTIVITIES AFFECTING i OUALITY WAS NOT EXECUTED TO VERIFY CONFORMANCE WITH

' DOCUMENTED PROCEDURES IN THAT. THE J-WELD PREP BEVEL ANGLES WERE GROUND TO 50 52 DEGREES FOR N0ZZLE ~C' AW 38 - 45 DEGREES FOR N0ZZLE ~B' THE PREP 5 WERE INSPECTED AND ACCEPTED BY OC.

t' STL1'- I 94-011' 01 VIO 4/1 ENG 06/02/94 0 06/08/94-- 2350 TIRE: INADEQUATE CORRECTIVE ACTION FOR MOV5 WHICH STALLED i STL1 1 94-011 02 IFI ENG 06/02/94 0 06/08/94 2350 TITLE: INADEOUATE RECOGNITION OF MOV TEST PRESSURE AND FLOW

^

STL1 I 94 011 03 IFI ENG 06/02/94 0 06/08/94 2350 I TITLE: LACK OF INSTRUCTIONS OR GUIDANCE FOR TRE @ LNG

- STL1 I 94-019 02 URI OPS 10/20/94 0 10/21/94 2330 'i TITLE: ACCEPTABILITY OF MAINTAINING AN SRO A5 AN RO IN RE0L q CCMMENTSi DETERMINATION OF ACCEPTABILITY OF MAINTAINING LICENSED SRO '

IN REQUALIFICATION TRAINING AS AN RO.

SR2. I 94-019 02 URI OPS 10/20/94 0 10/21/94 2330 SR1 . I 94-019 03 IFI OPS 10/20/94 0 10/21/94 2330 TITLE: CONFLICTING PROCEDURAL GUIDANCE FOR ACTIVE LICENSES  ;

COMMENTS: CONFLIrTING PROCEDUPAL GUIDANCE CONCERNING MAINTAINIE THE LICENSE STATUS OF THE OPERATIONS SUPERVISOR.

STL2 I 94-019 03 IFI OPS 10/20/94 0 10/21/94 2330 STL1 . I 94-300 01 IFI OPS 11/17/94 0 11/28/94 2330 l TITLE: PROCEDUPAL GUIDANCE FOR REMOVAL OF RCPS PRIOR TO 500

.I INFORMATION ON THIS FAGE 15 FOR ' OFFICIAL USE ONLf i y

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  • ,_ b .a p b 1 ITEM DETAIL REPORTS -IFS'. INSPECTION FOLLOW-UP SYSTEN -

DATE: 02/23/96 W - "5T LUCIE OPEN ITEMS LIST + REPORT BY SITE - TIME: 12:01:01--

PAGE: . 3: 2 7 ~ SITE; ~ STLl ; ST, LUCIE - - -

s -UNITi RPT/IF5/.SE0-NO ITEM REF NBR / SEVERITY SALP REPORT / STS CREATE CLOSE00TCLSOUT CL500T . . UPDATING . -

m. ABBRJ EA/ NBR NOV.ID TYPE- EA-NBR SLSLMNT AREA EVENT DT DATE PRJ/ACT*; ORG N0i EMP- INSPECTION REPORT 5;

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T COP 9fENi5: PROCEDURAL GUIDANCE IS LAC (ING FOR REMOVAL OF AN RCP FROM -

, ' SERVICE PRIOR TO RC5 TEMPERATURE DECREASING BELOW 500 DEGREES

FAHRENHEIT. PLANT PARAMETERS CAN CHANGE FAST ENDUGH SUCH- - 6 y cTHAT PROCEDURAL GUIDANCE 15 NOT OBTAINED UNTIL AFTER THE RCS = '

TEMPERATURE HAS DECREASED BELOW THE 500 DEGREES FAHRENHEIT.

J ISTL2 . . N 94-332 . LER- 94-006-01 07/I4/94 0 10/11/94 2230 g g g _ g W b N g y M

  • LTITLEt TRIP. CIRCUIT BREAKER FAILURE DUE TO A BROKEN PIECE OF.

' iSTL11 N 94 376' LER 94-00B-00 11/04/94 0 12/15/94' 2230 -

TITLE:. INADVERTENT CONTAlfmENT ISOLATION SIGNAL COPMENTS:. ' INADVERTENT CONTAlfetENT' ISOLATION SIGNAL (CIS) CAUSED BY FAILURE

'b1W 1'T$ M

OF THE B INSTR' MENTJ INVERTER CONCURRENT WITH CHANNEL D CIS IN TRIPPED CGCITION. '

.I 95-001 01- 02/23/95 0 03/06/95 STL1 -

TITLE:

VIO 4/1 OPS FAILURE TO PERFORM T5-REQUIRED SAMPLING OF THE IAI SIT 2230 -$3d D22 . -

STL2 -I 95-001 02 - VIO 4/1 MAINT 02/23/95 0 03/06/95 2230 TITLE: FAILURE TO FOLLOW PROCEDURE 2-LOI-T-89 -

STL1 . N 95-004 LER 94-010-00 11/24/94 0 01/04/95 2230

,_ TITLE: . INADVERTENT B TRAIN ENGINEERED SAFEGUARDS FEATURES ACTU n COPMENTS:- IMADVERTENT B TRAIN ENGINEERED SAFEGUARDS FEATURES ACTUATION C(yyy q f.og

' SIGML (ESFAS) DUE TO A DEFICIENT INSTRUMENT AND CONTROL TEST

-PROCEDURE. .

-STL1 .

N 95-005 LER 94-009-00 11/22/94 0 01[04/95 2230 TITLE: INADVERFENT SAFETY. INJECTION ACTUATION SIGNAL /CONTAINME C-.bo Q c{ p O b.

COMMENTS: INADVERTENT SAFETY INJECTION ACTUATION SIGNAL / CONTAINMENT

  • ISOLATION SIGNAL DUE TO AN INVALID HIGH PRESSURIZER PRESSURE SIGMAL.
STL2 . I.95-005 OI VIO 4/1 ENG 06/05/95 0 06/19/95 2320 95-005 TITLE
FAILURE TO IMPLEMENT DESIGN REQUIREMENT SPECIFIED IN PC/M 039-29 COMMENTS: CONTRARY TO 10 CFR 50.' APPEPOIX B. CRITERIA III AND V A5 0F APRI.

L 26.1995. DESIGN CHANGE ACTIVITES WERE NOT PERFORMED IN ACCORDAL '

  • NCE WITH REQUIREMENTS IN THAT OVERLOAD HEATERS MODEL NO. 123F104.

.C WERE INSTALLED IN MCC 2A. COMPARTMENT NO. DR3 FOR BATTERY CHAR. -.[

GED 2AA. INSTEAD OF THE REQUIRED MODEL NO. 123F114C. THE INSTALL '

-ED OVERLQoD HEATERS WERE LESS CONSERVATIVE THAN WERE FOUND TO BE- -

LESS CONSERVATIVE THAT THE MODEL SPECIFIED BY THE PC/M. '

4 .,

INFORMATION ON THIS PAGE-15 FOR 0FFICIAL USE'ONLY t b

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ITEM DETAIL REPORTS IFS - INSPECTION FOLLOW-UP SYSTEM OATE: 02/23/% .

.5T LUCIE OPEN ITEMS LIST REPORT BY SITE TIME: 12:01:01 PAGE: 4

. SITE: STL ST LUCIE '

UNIT PPT /IF5/ SEQ-NO ITEM 'REF NBR / SEVERITY SALP REPORT / STS CREATE CLOSE00T CLSOUT CL50VT UPDATING ASBR EA/ NBR NOV-ID TYPE EA-NBR SlPLMNT AREA EVENT DT DATE PRJ/ACT* OHG NO EMP INSPECTION REPORTS-STL1 .

I 95-005 02- URI ENG 06/05/95 0 06/19/95 2320 95-005 TITLE: POWER SUPPLY UPGRADE FOR THE EXISTING STEAM GENERATOR WIDE RANGE STL2 I 95-005 02 URI ENG 06/05/95 0 06/19/95 2320 95-005 STL1 I 95-015 01 VIO 4/1 OPS 10/16/95 'O 10/24/95 2230 95-015 clog %*72.-

. TITLE: FAILURE TO FOLLOW PROCEDURES AND BLOCK MSIS ACTUATION COMMENTS: .THE FAILURE OF THE DESK RCD TO PERFORM STEP 8.21 0F OP 1-0030127 STL1 TITLE:

I 95-015 02 VIO TWO EXAMPLES OF FAILURE TO FOLLOW PROCEDURES DURING RCP 4/1 OPS 10/16/95 0 10/24/95 2230 95-015 Q(,ord 4EU-COMMENTS: (1)THE FAILURE OF THE LICENSEE TO ADHERE TO INITIAL CONDITIONS SPECIFIED IN OP-1-0120020. (2)THE LICENSEE'S FAILURE TO ALIGN SEAL DLIECTION FLOW AS REQUIRED BY PROCEDURE.

STL1 I 95-015- 03 VIO 4/1 OPS 10/16/95 0 10/24/95 2230 95-015 TITLE: FAILURE TO FOLLOW PROCEDURE AND DOCUMENT ADNORMAL VALVE COMMENTS: THE FAILURE TO ENTER THE4 VALVES CLOSED STATUS INTO THE VALVE DEVIATION LOG.

STL1 I 95-015 04 VIO 4/1 OPS 10/16/95 0 10/24/95 2230 95-015 d o.k d k TITLE: FAILURE TO FOLLOW PROCEDURES DURING ALIGNMENT OF SHUTDOWN COMMENTS: FAILURE OF OPERATOR TO FOLLOW PROCEDURE OP 1-410022 DURING ALIGNMENT OF SHUTDOWN COOLING SYSTEM.

STL1 I 95-015 05 h!O 4/1 OPS 10/16/95 0 10/24/95 2230 95-015 TITLE: FAILURE TO FOLLOW PROCEDURE AND DOCUMENT A DEFICIENCY ON COMMENTS: ON CONTAINMENT SDRAY VALVE SURVEILLANCE TEST. THE FAILURE TO DOCUMENT FINDINGS & THE STAR PROCESS.

STL1 I 95-015 06 VIO 4/1 MAINT 10/16/95 0 10/24/95 2230 95-015 ( J,.o3cf,.. % D TITLE: ' FAILURE TO INITIAL MAINTENANCE PROCEDURE STEPS AS COMMENTS: FAILURE TO INITIAL STEPS A5 WORK / STEP WAS COMPLETED.

WAS COMPLETED.

STL1 I 95-015 07 VIO 4/1 OPS 10/16/95 0 10/24/95 2230 95-015 TITLE- FAILURE TO FOLLOW PROCEDURES DURING VENTING OF ECCS COMMENTS: THE FAILURE TO INCLUDE APPROPRIATE INITIAL CONDITIONS IN OP 1 0430060.

.5TL1 I 95-016 01 EEI 95-180 /1 09/08/95 0 09/13/95 2230 TITLE: LTOP INOPEPABILITY DUE TO PORV FAILURE STL2 I 95 016 01 EEI 95-180 /1 09/08/95 0 09/13/95 2230 INFORMATION ON THIS PAGE 15 FOR 0FFICIAL USE DNLY

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ITEM DETAIL REPORTS IFS - INSPECTION FOLLOW-UP SYSTEM DATE: 02/23/ %

ST LUCIE OPEN ITEMS LIST REPORT BY SITE TIME: 12:01:01 PAGE: 5

~ SITE: STL ST LUCIE UNIT RPT/IF5/ SEO-NO ITEM REF NBR / SEVERITY SALP REPORT / STS CREATE CLOSE0VT CLSOUT CLSOUT UPDATING ABBR EA/ NBR NOV.1D TYPE EA-NBR SUPLMNT AREA EVENT DT DATE PRJ/ACT* ORG NO EMP INSPECTION REPORTS STL1 'I 95-017 01 VIO 4/1 EPG 01/05/ % 0 01/11/ % 2320 TITLE: FAILURE TO FOLLOW PROCEDURES FOR MATERIAL CONTROLS-3 EXAMPLES COMMENTS: EXAMDLE 1-FAILURE TO PERFORM COMMERCIAL GRADE DEDICATION TEST.

EXAMPLE 2-FAILURE TO INCORPORATE SHELF LIFE MAINTE RNCE REQUIRE MENT INTO IN-STORAGE MAINTENANCE PROGRAM.

EXAMPLE 3-FAILURE TO DISPOSITION A SUPPLIER DEVIATION AS DIRECTE BY THE ASSOCIATED ENGINEERING EVALUATION.

STL2 1 95-017 01 VIO 4/1 ENG 01/05/ % 0 01/11/96 2320 STL1 I 95 018 01 VIO 4/1 OPS 11/28/95 0 12/07/95 2230 95-018 TITLE: FAILURE TO FOLLOW PROCEDURES AND MAINTAIN CURRENT COMMENT 5: CONTRARY TO THE ABOVE ON SEPTEMBER 15. 1995. D'JRING THE CLEANING OF UNIT 2 CONDENSER WATER BOXES. THE 282 WATERBOX MANWAY WAS REMOVED TO REPLACE A LEAKING GASKET WITHOUT IMPLEMENTING A CLEARANCE. WHEN THE MAINTENANCE FOREMAN AND MECHANIC ATTEMPTED TO REMOVE THE MANWAY COVER. THE NEGATIVE PRESSURE THAT EXISTED ACROSS THE MANWAY SUCKED THE COVER BACK ON THE WATERBOX AND SEVERED A PORTION OF THE MECHANICS FINGER.

STL1 I 95-018 02 VIO 4/1 OPS 11/28/95 0 12/07/95 2230 95 018 TITLE: FAILURE TO FOLLOW CLEARANCE PROCEDURES.

COMMENTS: CONTRARY TO THE ABOVE. THE LICENSEE IMPLEMENTED A UNIT 2 EMERGEN CY DIESEL GENERATOR (EDG) CONTROL LOGIC DESIGN T M T DID NOT TRIP THE EDG OUTPUT BREAKER ON RECEIPT OF A CSAS OR CIAS SIGNAL WHEN PARALLELLED WITH OFFSITE POWER. THIS INADE0'JATE DESIGN RESULTED IN SHIFT!NG THE WiERNOR TO THE 150CHRONOUS MODE. BYPASSING -

ALL PT<0TEGIVE RELAYS EXCEPT OVERSPEED AND DIFFERENTIAL CURRENT DURING INTEGRATED SAFEGUARDS TESTING ON OCTOBER 12. 1995.

THIS RESULTED IN OPERATING THE EDG A5 A SYNCHRONOUS MOTOR FOR APPROX. 45 SECOND5 UNTIL THE CIAS SIGNAL WAS RESET. OPERATION IN THE 150CHRONOUS MODE WHILE PARALLELED WITH OFFSITE POWER COULO EXPOSE THE ENGIENE AND GENERATOR TO EXCESSIVE MECHANICAL STRESS OR ELECTRICAL OVERCURRENT CONDITIONS.

STL2 I 95 018 03 VIO 4/1 MAINT 11/28/95 0 12/07/95 2230 95-018 TITLE: FAILURE TO ADEQUATELY DESIGN AND TEST THE EMERGENCY STL1 I 95-020 01 EEI 95-222 /1 EN'G 10/26/95 0 11/16/95 2230 95-020 TITLE: FAILURE TO TAKE PROMPT CORRECTIVE ACTIONS FOR RELIEF COMMENTS: VALVE DEFICIENCIES.

'STL2 I 95-020. 01 EEI 95-222 /1 ENG 10/26/95 0 11/16/95 2230 95-020 INFORMATION ON THIS PAGE IS FOR 0FFICIAL U S E- 0NLY

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151TES 1STL ST LUCIE UNIT' :RPT/IF5/ SEO-NO ITEM REF NBR / SEVERITY SALP REPORT / STS CREATE CLOSE0VT CL50UT CL50U1- ' UPDATING . .

ABBR- EA/ NBR ?NOV.ID TYPE EA-NBR SUPLMNT AREA EVENT DT DATE. PRJ/ACT* ORG NO - EMP -' INSPECTION REPORTS..

STL2- I 95-021 01 VIO 4/1 OPS 12/08/95 0 '12/2B/95 2230- '95-021 TIREi .. --FAILURE TO FOLLOW CLEARANCE PROCEDURE'S .

,: COMMENT 5! . CONTRARY TO THE ABOVE. ON NOVEMBER 11. 1995.. EQUIPMENT CLEARANCE '

ORDER 2-95-11 128 WAS ISSUED REQUIRING NO INDEPENDENT VERIFICATI -

N THAT THE 125 VDC POWER SUOPPLY BREAKER TO BLOCK VALVE MOV-08-1 7 FOR ATMOSPHERIC DUMP MV-08-198 WAS IN THE REQUIRED POSITION OF F; ~AN OUT-OF-5ERVICE LOG ENTRY ON NOVEMBER 5. IDENTIFIED MV 17 AS TECH SPEC. EQUIPMENT REQUIRED PRIOR TO M00E 1 A5 "OUT ON CLEARANCE.*

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STL2- !I95-021~02 VIO . 4/1 OPS 12/08/95 0 12/28/95- 2230- 95-021-TITLE:

~

C0 MENT CONTRARY 5:. .' FAILURE TO FOLLOW TO THE ABOVE. THE ON NOVEMBER EQUIPMENT

20. 1995 CLEARANCE V09120 ISOLATION VAL ORDER PROCEDURE VE FOR AFO PUMP 2A TO STEM GENERATOR 2A FEEDWATER INLET SPECIFI-CIED ON EQUIPMENT CLEARANCE ORDER 2-95-09-062 TAG #13 ISSUED NOVEMBER 17 WAS FOUND IN THE CLOSED INSTEAD OF REQUIRED LOCKED C

'LOSED POSTITION. THis VALVE ALSO REQUIRED IE EPENDENT VERIFI-CATION.

5TL2' 1 95-021 :03 VIO 5 4/1 MAINT 12/08/95 0 12/28/95 2230 95-021 TITLEi FAILURE TO PERFORM RL7 SYSTEM BORON SURVEILLANCE-

~

C0rt1ENTS: ~ CONTRARY TO THE ABOVE. UNIT 2 ENTERED MODE 5 AT 3:10 AM ON NOV.

27. 1995 WHICH REQUIRED THAT THE SAMPLING PERIODICITY BE IN-CREASED TO EVERY EIGHT HRS. SINCE THE PAST PREVIOUS SAMPLE WAS

-AT 1:00 AM ON OCTOBER 27. THE NEXT SAMPLE WAS DUE AT 9:00 AM AND EVERY EIGHT HR5 THEREAFTER. AT 11:45 PM WERATORS DISCOVERED

'THAT Int SAMPLING HAD NOT BEEN ACCOMPLISHED AT THE REQUIRED TIME ON THE DAY AND PEAK SHIFT. CHEMISTRY WAS NOTIFIED AND THE SAMPLE WAS TAKEN AND ANALYZED AT 12:00 PM ON NOVEMBER 27.

STL1 I 95-022 01 IFI 01/09/ % 0 01/17/ % 2320 TITLE: ' COMPLETION OF CERTIFICATION PROGRAM FOR OVALIFIED SAFETY STL2 I 95-022 01 IFI 01/09/ % 0 01/17/ % 2320-

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STL1 N 95-061 LER 95-001-00 02/16/95 0 03/21/95 2230 C.M #{ q pgt -

TITLE: 1A3 4160 VOLT BUS LOAD SHED DURING REPLACEMENT OF.FAILE COMMENTS:- 1A3 4160 VOLT BUS LOAD SHED DURING REPLACEMENT OF FAILED 2X-5 RELAY DUE TO PROCEDURAL DEFICIENCY.

STL2 N 95-080' LER 95-002-00 02/21/95 0 03/31/95 2230 <

TITLE: AUTOMATIC REACTOR TRIP ON LOW STEAM GENERATOR WATER INFORMATION ON THIS PAGE 15 FOR 0FFICIAL' U S E' O N'l Y-

e -

ITEM DETAIL REPORTS IF5 - INSPECTION FOLLOW-UP SYSTEM DATE: 02/23/ %

ST LUCIE OPEN ITEMS LIST REPORT Bf SITE TIME: 12:01:01 FME: 7 SITE; STL ST LUCIE

. UNIT RPT/IF5/ SEO-NO ITEM REF NBR / SEVERITY 5 ALP REPORT / STS~ CREATE CLOSEOUT CL50UT CLSOUT UPDATIE ABBR EA/ NBR NOV-ID TYPE EA-NBR SUPLMNT AREA EVENT DT DATE PRJ/ACT* ORG NO EMP -INSPECTION REPORTS COMMENTS: AUTOMATIC REACTOR TRIP ON LOW STEAM GENERATOR WATER LEVEL DUE TO A FAILED LEVEL TRANSMITTER.

STL2 N 95-081 LER 95-001-00 02/21/95 0 03/31/95 2230 TITLE: 10W PRESSURE SAFETY 10ECTION PUMP FOUND TO BE INOP COMMENTS: LOW PRESSURE SAFETY 10 ECTION PUMP FOUND TO BE INOPERABLE DURING ASME QUARTERLY CODE RUN DUE TO AIR BINDING.

STL2 TITLE:

COMMENTS:

N 95-127 . LER 95-0C3-00 04/10/95 0 06/08/95 MISSED TECHNICAL SPECIFICATION SCHEDULED SURVEILLANCE DUE TO DUE TO PROCEDURAL DEFICIENCY.

2230 kh NN STL1 N 95-150 LER 95-002-00 05/26/95 0 06/27/95 2230 95-002LC OJ d D'2 l' TITLE: MISSED EMEEENCY DIESEL GENERATOR SURVEILLANCE COMMENTS: DUE TO PROCEDURAL DEFICIENCY.

STL1 N 95 181 LER 95-003-00 07/08/95 0 08/10/95 2230 95-003 TITLE: AUTOMATIC REACTOR TRIP DURING TURBINE OVERSPEED SURVEILLANCE COMMENTS: SURVEILLANCE TESTING DUE TO PERSONNEL ERROR.

STL1 N 95-195 LER 95.u05-00 08/09/95 0 08/28/95 2230 TITLE: PRE 55URIZER POWER OPERATED RELIEF VALVES (PORV)

COMMENTS: INOPERABLE DUE TO PERSONNEL ERROR.

STL1 N 95-196 LER 95-006-00 08/10/95 0 08/28/95 2340 TITLE: LOSS OF REACTOR CD')LANT INVENTORY THROUGH A SHUTDOWN COMMENTS: COOLING RELIEF VALVE DUE TO LACK OF DESIGN MARGIN.

STL1- N 95-205 LER 95-007-00 08/17/95 0 08/31/95 2230 TITLE: INMVERTENT CONTAINMENT SPRAY VIA 1A LOW PRESSURE COMMENTS: SAFETY 10ECTION PUMP WHILE VENTING THE EMEEENCY CORE COOLING SYSTEM DURING STARTUP DUE TO INADEQUATE PROCEDURE.

STL1 N 95-206 LER 95-004-00 08/01/95 0 08/31/95 2230 TITLE: HURRICANE ERIN AT ST. LUCIE STL1 N 95 231 LER 95-003-01 07/08/95 0 10/17/95 2230 TITLE: AUTOMATIC REACTOR TRIP DURING TURBINE OVERSPEED COMMENTS: SURVEILLANCE TESTING DUE TO PERSONNEL ERROR.

STL1 N 95-233 LER 95-008-00 08/28/95 0 10/19/95 2230 TITLE: HIGH PRESSURE SAFETY INJECTION PUMP OPERATION DURING INFORMATION ON THIS P M E IS FOR 0FFICIAL USE ONLY

--.--x - - . - --. .-. - . _ - __---_ . --- --- -- -._ --

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.n ITEM DETAIL REPORTS _ -IF5 . INSPECTION FOLLOW-UP SYSTEM'

. ~ DATE:'02/23/96

.5T LUCIE OPEN ITEMS LIST- REPORT BY SITE- 1TIMEc12:01:01 PMEr. '8 51TE: ;5TL ST LUCIE

~

~

c DNIT. -'- :RPT/IF5/ SEO.NO ITEM. REF NBR / SEVERITY SALP REPORT / STS CREATE CLOSEOUT CLSOUT CL500T . UPDATING - . ,

ABBR : SUPLMNT- AREA EVENT DT DATE PRJ/ACT* . ' OM NO . EMP '- INSPECTION REPORTS'

. :EA/ NBR--NOV-ID TYPE EA-NBR t ...................................................... ................................ ............ 4..................................

COMMENTS: PLANT COPOITIONS NOT ALLOWED BY TECHNICAL SPECIFICATIONS

. DUE TO PERSONNEL ERROR.-

- STL2 -- .N 95-254 LER- 95-004-00 10/10/95 0-11/07/95 2230

-TITLE: REACTOR COOLANT SYSTEM INSTRUMENT N0ZZLE LEAKME CAUSED v COPMENT5s BT PRIMARY WATER STRESS CORROSION CRACKING.

' STL1 N 95-268 . LER 95-009-00 10/19/95 0 11/24/95 2230 TITLE: MISSED TECHNICAL SPECIFICATION SCHEDL4ED SURVEILLANCE COPMENTS: DUE TO PERSONNEL ERROR.

, STL1 - . N 95-297 LER 95-010-00 11/16/95 0~ 12/19/95 2230 TITLE: MANUALLLL REACTOR TRIP DUE TO LOW STEAM GENERATOR WATER COPMENTS:. LEVEL CAUSED BY MAIN FEEDWAER REGULATING VALVE CLOSURE.

STL2- N 96 001 'LER 95-005-00 11/20/95 0 01/03/ % 2230.

TITLE: 2A EMERENCY DIESEL GENERATOR RELAY SOCKET FAILURES DUE COPMENTS:- TO HIGH CYCLE FATIGUE.

NOTE: DEFINITION FOR CHARACTER PRECEEDING REPORT NO: I = INSPECTION REPORT' NUMBER. E = EA NUMBER (ENFORCEMENT / NOV ITEM)~

N = IFS NUMBER. NUMBER USED TO IDENTIFY NON-INSPECTION ITEMS TOTAL OPEN ITEMS -n 57 *IF ITEM 15 OPEN. PRa3ECTED CLOSEOUT DATE 15 REPORTED TOTAL OPEN REPORT SEQUENCES = = " - 50 IF ITEM 15 CLOSED. ACTUAL'CLOSEGUT.DATE 15 REPORTED INFORMATION ON THIS P M E 15 FOR 0 F F I C'I A L USE ~0NLY-

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. paaso g UNITED STATES , y f 4 NUCLEAR REGULATORY COMMISSION '

O 1 REGION 11

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MEMORANDUM TO: All NRR Project Managers i and Project Directors FROM: John F. Stolz, Director Project Directorate I-2 Division of Reactor Projects - I/II

SUBJECT:

REVIEW 0F SPENT FUEL P0OL PRACTICES AND CURRENT LICENSING BASIS Since 1992, the staff has been reviewing licensing and design issues associated with spent fuel storage pool . safety at operating nuclear power plants. The staff has an action plan in place, sponsored by the Division of Systems Safety and Analysis (DSSA), which provides'for a thorough and methodical review of spent fuel storage pool safety issues. Upon completion of the action plan, the staff will determine if any new regulatory requirements need to be implemented and will pursue backfit activities as appropriate.

The issues under review include the reliability of spent fuel decay heat removal systems under a variety of normal and off-normal plant conditions.

The inclusion of these issues in the action plan stems from the staff's review of a.10 CFR Part 21 report filed in November 1992 which detailed potential deficiencies in the design of spent fuel pool cooling systems at the Susquehanna Steam Electric Station.

In addition, the staff is reviewing core offload practices and irradiated fuel decay heat management during refueling outages. Concerns in this area stem from a number of design and licensing problems discovered at the Millstone Unit I nuclear power plant in the fall of 1995. The problems found at Millstone 1 triggered increased concern about whether all operating reactors were conducting refueling core offload activities in a manner that was consistent with the design assumptions described in the current licensing basis for the facility.

To facilitate completion of the DSSA Action Plan and to address concerns about refueling practices highlighted by the Millstone review, project managers of all operating facilities are tasked via this memorandum to survey the design and licensing basis for the facility as it pertains to spent fuel storage pools. This project requires that project managers perform a detailed review of the plants current licensing basis (CLB) and design basis. In addition, project managers will need to determine, through site visits and interaction with the resident inspector and regional staff, how the licensee ensures that its operating practice is consistent with the CLB. Project managers are expected to pursue resolution of discrepancies between operating practices and CONTACT: Joe Shea, NRR \q1) 415-14;8 v

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licensing basis requirements. Any concerns about the adequacy of the existing licensing basis will be addressed by DSSA as part of the action plan.

Detailed guidance on the scope and depth of the review and documentation requirements is attached.

The time table for completing this project is stringent. The review must be completed by April 1, 1996, for all facilities. Further, for facilities that will enter a refueling outage prior to April 1, 1996, the review must be completed prior to the beginning of the outage. Project managers and project directors should start the required actions in the near term so as to allow efficient coordination of site visits and interactions with the regional

. staff. If project managers anticipate difficulty meeting the April 1, 1996

' deadline, these problems should be addressed through the corresponding project director, Some project managers, namely those with refueling outages commencing prior to February 28, 1996, have already started the review project using interim guidance. These project managers should review the work they have performed to date against the attached guidance and perform any additional work as may be needed to complete all required actions. The attached guidance was developed so as to build on the interim guidance. The primary additional activity which these project managers must perform is completion of the spent fuel pool design data table included in the attached guidance and research of recent license amendments. .

Attachment:

" Project Manager Guidance, Spent Fuel Pool /

Core Offload Practice Licensing and Design Basis Review Project," Revision 0, February 8, 1996 h

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PROJECT MANAGER GUIDANCE l SPENT FUEL POOL / CORE OFFLOAD PRACTICE LICENSING AND DESIGN BASIS REVIEW PROJECT REVISION O I i

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. 1. INTRODUCTION

2. [ VALUATING LICENSING BASIS REQUIREMENTS /

LICENSEE COMPLIANCE

3. CupFLETING DESIGN BA$15 DATA TA8LE j
4. DOCUENTATION REQUIREMENTS 1
5. SCHEDULE l
6. ADMINISTRATIVE 1

Issue Date FEBRUARY 8. 1996 Prepared By: J. Shea Approved: J. Stolz Project Director Project Directorate I-2 Attachment Q D $ 6 % ] - f_ {,3p;f

4 SPENT FUEL P00L/ CORE.0FFLOAD PRACTICE ,

LICENSING AND DESIGN BASIS REVIEW PROJECT

1. INTRODUCTI0l4  ;

.This paper provides guidance to NRR project managers for conducting a review and evaluation of the current licensing basis (CLB) and design basis for their facility as it pertains to spent fuel storage pool safety and refueling outage core offload practices. Project managers will determine the CLB for their facility.in this matter and will work with the NRC resident inspectors and.

regional staff to ensure that licensee operating practice is consistent with the CLB. In addition, the guidance is provided for collecting detailed design data for the spent fuel storage pool systems at each facility. All project '

manager actions are to be completed by April 1,1996 or, for outages beginning before April 1,1996, prior to the beginning of the next. scheduled refueling Loutage, in order to meet schedular commitments made to the NRC Chairman.

This paper provides detailed instruction on how to identify specific licensing 2

basis requirements in various licensing documents and how tu evaluate licensee compliance with licensing basis requirements (Attachments I and 2).

Instruction is also provided for collecting detailed design information on spent fuel storage pool systems (Attachments 3 and 4). Background information to allow project managers to understand the scope of the project as well as ,

the underlying reasons for conducting the project is provided in Attachment 5.

Finally, information is provided regarding the administration of the project  !

including project manager reporting requirements, RITS information and  !

schedule requirements.

2. EVALUATING LICENSING BASIS RE0VIREMENTS/ LICENSEE COMPLIANCE In order to determine the licensing basis requirements in the area of spent fuel pool cooling and core offload operating practices, project managers will '

need to review current licensing basis documents. Project managers will need to understand the system design information contained in these documents; then project managers will need to make judgements regarding what operating restrictions and limitations are contained within the licensing basis.

Once the project manager determines what are the applicable licensing basis q requirements and limitations for their facility, the project manager must

review the licensee's operating practice to ensure it is in compliance with those requirements. Project managers should work closely with resident ,

' inspectors and regional staff to obtain and review licensee procedures' and analyses to determine how the licensee ensures compliance. A memorandum from ,

the NRR Associate Director for Projects will be issued concurrently with these instructions requesting that resident and regional' staff assist project managers. Project managers are encouraged to perform some of the compliance review themselves during onsite visits.

A step-by-step outline on how to review the CLB, how to judge operating limitations and.how to evaluate compliance is contained in Attachment 1. A sample licensing basis and compliance review is documented in Attachment 2.

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-Additional background information regarding Standard Review Plan guidance on

spent fuel pool cooling and recent licensing problems in this area is contained in Attachment 5.
3. COMPLETING DESIGN BASIS DATA TABLE >

i In addition to performing the licensing basis determination and compliance review, project managers are tasked to be the focal point in compiling a detailed design basis data table for their facility (included as Attachment 3). -The data from the table will be used by DSSA in evaluating potential backfits as part of the ongoing Task Action Plan for Spent Fuel Storage Safety. Information for the data table will be located, for the most part, in the FSAR, TS and Bases and rerack amendment documents. Information not available in these documents may be located in design-basis documents on site  ;

and can be researched by the project manager or regional staff as is most ,

efficient. A sample design basis data table, completed by the Plant Systems .

Branch (SPLB) staff for Commanche Peak, is included as Attachment 4 ad should be used as a guide regarding references and level of detail.

4. DOCUMENTATION RE0VIREMENTS It is important that the project be strongly and consistently documented for 4 all plants. Project managers are requested to use the format provided in the sample in Attachment 2.

Completed reviews should be forwarded from the project manager to the lead

project manager (Joe Shea, 415-1428, JWS1) via the respective project director. All reviews should be forwarded in an electronic format.

The lead project manager will screen the reviews and provide the information as appropriate to DSSA and NRR management.

5. SCHEDULE l All licensing basis reviews and compliance evaluations need to be completed prior to the start of the next planned refueling outage for each unit and no later than April 1, 1996. The design basis data table for each plant must be completed prior to April 1, 1996. Project managers are encouraged to conduct l the review as early as possible in order to efficiently use resources.  :

Completion of project manager reviews will facilitate review by DSSA and NRR l management to permit issuing a final report package to the EDO by May 1, 1996, )

the committed date for completion of the project.  !

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6. ' ADMINISTRATIVE INFORMATION ,

RITS Information: All project manager time for this effort should be charged to TAC 94480.

Lead project manager: The lead project manager for this effort is Joe.

Shea at 415-1428. The'1ead SES for this effort is John Stolz at 415-1430. ,

Any questions or concerns about the project may be directed to them..

Attachments: 1. Determining Spent Fuel Pool / Core Offload Licensing Basis

2. Sample Spent Fuel Pool CLB Review Format
3. Spent Fuel Storage Data Table
4. Completed Sample Spent Fuel Storage Data Table
5. Spent Fuel Pool Decay Heat Background Reviews ,

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1 DETERMINING SPENT FUEL POOL / CORE OFFLOAD LICENSING BASIS STEP 1: Review Spent Fuel Systems Basic Design Description Review UFSAR Section on spent fuel nool and spent fuel pool f cooling systems for design information. Review most recent spent fuel. pool rerack application and amendment for additional design detail. Become familiar with following system basic parameters ,

- Number of trains

- components in train

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- redundancy  ;

- interfaces '

- water makeup sources

- electrical power sources and backups

- alternate cooling paths (e.g. RHR system)

- source of cooling water for SFP cooling system STEP 2: Review Spent Fuel Pool Cooling Heat Load Analyses t

Review spent fuel pool cooling heat load analysis in UFSAR and rerack amendments. Become familiar with different heat load scenarios analyzed. Understand the assumptions (fraction of core assumed in pool, pool inventory and exposure history, time after shutdown,'etc) used in each scenario analysis. Become familiar with maximum heat load analyzed for each scenario. Become

- familiar with temperature limits used in the analysis and the pool cooling system configuration assumed to meet these limits (e.g.

all trains assumed operating, or augmented capability from RHR required, or failure of one train assumed). See attachment 2 for additional discussion of heat load analyses Document key licensing basis assumptions with regard to spent fuel pool heat load, heat removal capability, and core offload practice. See the Sample Spent Fuel Pool CLB Compliance Summary in Attachment 3 for additional detail. .

STEP 3: Review Technical Specifications i

Review Technical Specifications and License Conditions for

  • explicit controls on spent fuel pool operation and refueling operation. Common, but not universal, technical specifications are implemented for spent fuel pool level, and temperature. In addition license conditions and TS imposing limitations on fuel movement (time after shutdown) 1 common. Less common are TS on spent fuel pool cooling system operation.

Document technical specification requirements.

Attachment 1 ,

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STEP 4: Evaluating' Compliance For technical specifications requirements identified in Step 3, project managirs should examine surveillance procedures, administrative. procedures and system operating procedures to

, ensure that specific TS requirements and' pertinent Bases information are appropriately controlled.

For other. licensing basis requirements identified in Step 2,

. contained in such documents such as the FSAR or most recent rerack amendment, project managers should ensure that the licensee,  ;

through a combination of administrative procedures,.one-time or 4

recurring (e.g. prior to refueling outages) safety analyses and system operating procedures, maintains facility operation within the licensing requirements. Key controls and issues to look for include:  ;

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  • Prerequisites (any non-normal modifications or alignments)
  • Time after shutdown for refueling to begin for i specific cases
  • Maximum SFP temperatures for specific cases
  • Redundancy of available SFP cooling capacity and makeup water sources
  • Lineup for alternate water makeup sources
  • Verification of_ SFP cooling flowpaths (e.g. valves / pumps)
  • Normal and backup electrical lineup Additional information on licenser management of these issues can likely be found by reviewing the ;icensee's Industry Operating Experience Review unit's (this unit or group may have a different designation at various sites) disposition of NRC Information Notice 95-54: " DECAY HEAT MANAGEMENT PRACTICES DURING REFUELING OUTAGES."

STEP 5: Dispositioning Discrepancies:

Project managers should work with the resident inspectors to ,

document discrepancies in routine resident inspection reports. l The SAMPLE SPENT FUEL POOL CLB COMPLIANCE

SUMMARY

in Attachment 3 contains examples of discrepancies.

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' SAMPLE SPENT FUEL POOL CLB REVIEW FORMAT j EXAMPLE NUCLEAR POWER PLANT l A. SYSTEM DESIGN: _

Thre'e 50% capacity non-safety related pumps and three 50% capacity heat l exchangers are provided for each spent fuel pool. .

One_of the three installed pumps per unit is powered from a Class IE on-site power supply. i l

The fuel pool heat exchangers are cooled by service water which transfer l the heat to the UHS. Reactor building closed cooling water back connections exist, .however, use of this system to cool the heat exchangers requires installation of spool pieces. i l

One train of the residual heat removal system can be aligned, after installation of spool pieces, to the spent fuel pool.to provide spent fuel poo1~ decay heat removal. Use of the RHR system in this mode ,

precludes use of the RHR system in the reactor vessel shutdown cooling  !

mode. Use of the RHR system in the SFP cooling mode does not preclude )

use of the remaining RHR train for Torus Cooling.

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t SAMPLE SPENT FUEL POOL CLB REVIEW FORMAT Attachment 2 I

.o SAMPLE SPENT FUEL POOL CLB REVIEW FORMAT B.

SUMMARY

OF CLB REQUIREMENTS RE: SPENT FUEL POOL DECAY HEAT REMOVAL / REFUELING OFFLOAD PRACTICES (1) Technical Specification limits are provided on spent fuel pool level (20 feet above top of fuel). No other TS are in place regarding spent fuel pool operation or fuel movement activities. No license conditions exist for these areas. (e.g. TS 3.10.X)

(2) Maximum heat load in the pool is under refueling outage conditions is limited to design analysis input value of-26 MBTU/hr (e.g. UFSAR Chapter X)

(3) Fuel pool temperature is limited to 150F for all planned refueling outages. This temperature limit applies for core offloads up to and including a full core offload. For outages in which a full core. offload

.is planned, the licensee need not maintain a single failure spent fuel pool cooling system operation for the duration of the outage. (e.g.

UFSAR Chapter X)

Under true emergency conditions, such unplanned emergent situations in l which the full core must be offloaded into the pool and for which l cooling system availability is_not sufficient to maintain temperature '

below 150 F, fuel temperature rise up to the boiling point has been analyzed and found acceptable. (e.g. Rerack Amendment SE dated ....)

4) The RHR can be made available to dissipate the heat associated with a full core discharge if the three installed SFPC pumps and heat exchangers are not available. Because the three installed SFPC trains were found acceptable to dissipate the heat associated with a full core offload without a single failure, the licensee need not demonstrate that it can initiate RHR cooling prior to exceeding 150F, rather, the licensee must be able to demonstrate that system operating procedures and analyses support operation of the RHR system in this mode. e.g.

(UFSAR Chapter X)

5) Maximum pool temperature during non-refueling outage operation is 150 F and represents the CLB controlling parameter for non-refueling outage conditions. During non-outage operation, the licensee should have controls that assure that spent fuel pool heat load is maintained below the analyzed design value of 13.14 MBTV/hr for which the spent fuel pool ,

cooling system is analyzed as being able to maintain the spent fuel pool temperature below 150 F while assuming the design basis single failure.

.(e.g. UFSAR X).

(6) A delay time before fuel transfer of 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> is assumed for all fuel transferred to the fuel pool.

SAMPLE SPENT FUEL POOL CLB REVIEW FORMAT

  1. ) I SAMPLE SPENT FUEL POOL CLB REVIEW FORMAT (6)(cont) Licensee should have procedural controls that reflect this assumption or.should have outage specific analyses that demonstrate that for the specifically planned outage schedule, the resulting heat load does not exceed the 26 MBTV/hr established as the bounding case in item 1 above. i (e.g. Rerack License amendment application dated June X, 1985) l (7) No other implicit or explicit prohibitions exist within the CLB against l performing a full core offload for any given refueling outage.

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i SAMPLE SPENT FUEL POOL CLB REVIEW FORMAT ,

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L SAMPLE SPENT FUEL P00L'CLB REVIEW. FORMAT. ,

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SUMMARY

OF COMPLIANCE-.WITH CLB REQUIREMENTS AND COMMITMENTS i h l(This action has not been performed for this facility, therefore, sample  !

-guidance below is hypothetical. It is not intended to set any specific l

expectation. A variety of. procedural controls and analyses could be used by a licensee-to demonstrate compliance. -You should try to address compliance with i

-each of the key. point identified in your Part 8, " Summary of CLB. '

Requirements")-

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.'( 1) - Licensee X performed engineering analysis XX-XXX and.YY-YYY prior to the

.most-recent refueling outages.R010 and R011. The analysis showed that, ,

for the projected-fuel movement schedule, the spent fuel pool heat load-  !

i would not exceed ZZ MBTU/hr. The staff concluded this was within the.  !

]_ ,

licensing basis limit of 26 MBTU/hr described in CLB Summary item 1 L(2) Licensee X Refueling Outage plan XXXXX identified the need to maintain .!

all three spent pool cooling trains in operation and not perform ,

maintenance that jeopardized the operation of all three trains.

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, (3) Licensee X did have procedures in place to operate the RHR system in the

' fuel pool cooling mode. The RHR system has never actually been operated ,

/since preoperational_ testing days in this mode and the licensee was not

. able to demonstrate that existing procedures established the conditions l 1 Lnecessary to successfully operate the system. This item was provided to ,

the resident inspectors for followup as-an unresolved item q

4 (4) During the resident inspectors review, the licensee verified that the  !

existing spent. fuel pool inventory, with the unit at power, was within  ;

the 13.14 MBTV/hr analyzed limit. t

. i l (5) The licensee acknowledged that they have moved prior to the 120 hour0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />

point described in the CLB. However, the licensee stated that they have t analyzed the' anticipated heat load for each outage consistent with the i . outage specific fuel movement plans and have maintained the pool heat  ;

. load under the 26 MBTU/hr maximum analyzed limit for each refueling ,

4 outage. The licensee committed to revise the FSAR to make clear that t'

the delay time will be analyzed on an outage specific basis and may vary >

'from outage to outage. The licensee's commitment to revise the FSAR-

! will be documented in a routine resident inspector report. .

(6) Licensee X has surveillance procedure ST X-Y-Z which is used to demonstrate compliance with TS 3.10.X -l:

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SAMPLE SPENT FUEL POOL CLB REVIEW FORMAT l r  !

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e SPENT FUEL STORAGE DATA TABLE l

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  • e SPENT FUEL STORAGE DATA TABLE Foollity Names Unit Number (s):

9 Licensee's SFP Name: Phone Contact SFP Related Parameter (s): [ Licensed Thermal Power, Limiting value or Condition:

Tech. Specs. SFP Level, SFP Temp., In-vessel Decay flee SFP Fuel Assembly Inventory, SFP Cooling System Avail., SFP Baron Conc., ,

and Fuel Storage Zones!

SFP Structure Locatient (Above/Below Grade, Setamio Classification of SFP Structure Reactor / Aux./ Fuel Buildinal and Bu11 dias:

Volume of SFP(s): [ f t*] SFP Temperature for Stress Analysis (Usually in Structural Design Section of FSAR]

Leak age Liner Typer Leakage Monitoring: [ Leak Collection Collection Chases; N oitoring Sumpe; SFP Elevated Such That Leakage Would be Collected in Building Sump]

Dralpage Location of Botteen Drains: {Kone in SFP; Elevation of Gate Bottom Relative to Prevention Drains in Reactor Cavity / Transfer Stored Fuel: [Above/Below Top of Stored <

Canal / Cask Pit] Fuell Siphon Lowest Elevation of Connected Piping Anti-Siphon Devices: [ Drilled Boles; Check )

Prevention Relative to Fuel: (Above/Below Top of Valves; Siphon-Break Pipe; Vacums Breaker) l Stored Fuel]

Make up Safety-Related Source: Seismic Classification and Quality Group:

Capability Normal Source:

Reactivity Limits on k.,,and Enrichment: Soluble Baron Credit for Accidents:

Reactivity Solid Neutron Poisons: [Borefies; Boral; No. of Fuel Storage Zones:

Control Clad Boron Carbide; Gadolinium Pins) (One/Two/Three; Based on Burnup/Enrictament)

Shared or Spilt No. of SFP(s): [ Total for Unita Listed] No of SFPs Receiving Discharge from a SFPs Single Unit:

STP Design Normal: Emergency / Abnormal:

Inventory cases SFP Design Beat Normal Emergency / Abnormal:

Load (M TU/Rr) and Temperature

(*F)

SFP Cooling No. of Trains: Licensed to Withstand Single Active Systaan Component Failure:

No. of SFPs Served by Each Train: Qualification: (Seismic Classificatimi; Quality Group)

Electrical Qualification and Independence of Power Load Shed initiators: [Undervoltage/SI Supply to SFP Supply: Signal, Coincident / Separate)

Cooling System Pumpe Backup SFP System Name Quattrication:

Carlins:

SFP Beat Systen Name Qualification:

Estbanger Cooling Water

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'I j Fee 111ty Eme: Unit Nieber(s):

M ay System Nemme Qualificaties:

I 4- Cos11as Weter -

}- Lamp (if applieeble)

. Witarete Boat' Type [Notural er Man made Pand, River, UES Dosism Tamperature i, Siak or Ocean]

EFF Coolias Dosism Best Capacity: Typer (Plate er m ell & Tube) a System Best -

] Esehemser gyy side Flow (1b/br or OfM): Coolias Water Flow (1b/br er GRs):

r Perfeemamee .

" SFF Temperature: Coolias Water Zalet Temps j gg4

, =eb.as. if .es Coolias Wet.or Outlet Temps 1 gg,,gg. g3 EFF Coollas Loop Retusa Temp i .

I i Paramet.or(s): (las/high level, bish Betpoints EFF Belated . J C.mt.e1 - te.p, to. fi . to. ,i.m,dischers. 1 Alasms pressure, high leakase flow, high radietien: Commmon Alarm or separete)

. Leestiam of SFF Level: (SFF Coo 11as System Famel, SFF Temperatures (5FF Coolias Systeun

!' Indieetians 5FF Gese, Control team, Redmaste Penel) Piping, SFF Gese, Centeel Boem, Raesest,e a Fame 1] 1

, . l 3 8FF Coolias Parameter (s): (SFF Level, Surse Tank t', '--e (Separate lastreammat for  !

System Amt m etic Level, Suction Pressurel Each Ptay, Co mme Instriminatatism for All )

F w Trips Pumps]  !

  • j SFF Sellias Staff Acceptance of non-Belemic SFF Off site Consequameos of EFF Bellias j Coe11as System Based on Selenic Category Evaluated: I 1 SFF Ventilation Systam:

If Tee, Was Filtration credit.ed:

SFF/ Reactor Separation of SFF Operatins Floor from Separation of Units at Multi-Unit Sitas:

Systeun . - Portico of Auz or React.or Bids. that (Shared / Separate SFF Operatias Fleers.

5eparetten. Contains Reactor Safety Syst es Shared / Separate Teatilat,lom Systems) .

(NOTE: The (5FF Area Campistely Enclosed /open Faths l paarpose of this Allow Commmmicetion Between SFF Area and I item is to Areas Containing React.or Safety Syst,ams, l det, ermine how Noresal or Emersemey Vent,11ation Systems l ses11y boat,and. Are Present, that, Mix SFF Area Atmosphere i water vapor free wit,h Areas Containins Reactor Safety )

4 -

a bellins SFF Systems) ,

{- seuld propesete j to aroes  ;

  • - contaimias j 1 reacter safety systems and if  ;

sush an event

i. eemld effect i maaltiple imite.)

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Beavy lead SFF Area Crane Quellfled to Single Routine Spent Fuel Assembly Transfer to ,

Bandlims- Failure Fauof St.andard IAN BRElBG-0612 ISF51 or Alteswete Wet Storage 1meetian '

and/or EUREG-0554:

4, . ..

l- Operatias Adudalstrative Coet,rol Limit (s) for SFF Administ.rative Cent.rol Limite for SFF Freetices Tempersture durins Refuellast Coo 11as.Bretam " " h y and SFF 9take-up g,, g >2___

g 4

Freguemey of Full-Core Off-loads: (>903 Administrative Centrola em Irradiated Final of Outesees >SOE of Outases; <=503 of Decay Time prior to frameter frems Reestar Outaseel Vessel t.o SFF

. e -,,#. . - - . , . , . . - , _ . , . c. e-.w., .,r-. , - - ., , . . . . .m.., .

..w.5. . U..,m.

. _ . .~. . . .. . ._._ .._ _ .. ~ . _ . _ . . ~ . . . ~ . - . . . . - . . . . - . - .

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j i Feeility Eme: Unit ihmber(s):

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Type of Off-load Performed during feast For Units with Planned Refuellas Outeses  ;

Rosent Refuellas [pertiel/ full core; if Scheduled to Begin Before April 30, 1996,  !

partial, estimate core traction in SFF) Type of Off-load Flammed for Best F Refuellas and Flammed Shutdemn Date:

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. COMPLETED SAMPLE SPENT FUEL STORAGE DATA TABLE I l

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I ATTACHMENT 4'

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COMPLETED SAMPLE SPENT FUEL STORAGE DATA TABLE Facility Name: Comanche Peak Unit Number (s): 1&2 Liseasee's BFP Name: David Fuller Phone: (817) 897-66$1 Centeet EFF Related Parameter (s): Limiting Value or Condition: ,

4 Tech. Specs. Licensed Thenmal Power 3411 MWt {

SFP Level >23 ft above stored fuel SFP Baron Concentrataon 2400 ppe Decay time in Reactor Vessel 100 hrs EFF Structure Location:' Bottom of pool below grade in Seismic Classification of SFP Structure ,

shared Fuel Handling Building and Building: Category I l s

Volume of SFP(s): 43,580 ft' for Each SFP Temperature for Stress Analysis:

Pool ,

Leakase Liner Typet Stainless Steel Leakage Monitoring: Leak Collection Chase )

Cellection with Telltale Drains

{

Drainase Location of Bottom Drains: None in Elevation of Gate Botton Relative to

Prevention SFPs. ' Drains in transfer canal and Stored Fuel
Bottaa of sete to transfer j 4 reactor cavity, canal above top of stored fuel. I 1

i Siphom Lowest Elevation of Connected Piping Anti-Siphon Devices: Drilled hole Prevention Relative to Fuel! 6 ft above stored fuel Make-up Safety Related Source: Reactor water Seismic Classification and Quality Group:

Capability make up tanks and pumps Seismic Categor} I and Quality Group C Normal Source: Domineralised water system Reactivity Limits on k, and Enrichment <0.95 3 Soluble Baron Credit for Accidents: Yes 2.91 U-235 Reactivity Solid Neutron Poisons: None No. of Fuel Storage Zones: 2

. Control i Shared or Split No. of SFP(s): Two shared between two No. of STPs Receiving Discharge from a j SFPs units Single Unit: One currently, both in the

, future to balance heat load SFP Deelse Normal: Emergency / Abnormal

' Inventory Cases Maximum Deslan Condition - The decay Abnormal Maximum Desian Condition - The l heat from a full core off-load decay heat from discharged fuel assemblies l 7 days after shutdown for one unit, the for two consecutive 45 day refueling i opposite unit's refueling discharge 52 outages on alternate units 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> after days after shutdown of that unit, and the end of the second outage period, an the discharged fuel assemblies from a emergency full core off-load 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> maximum number of previous refuelings at after shutdown from the unit completing 18 month intervals while maintaining at the earlier refueling outage, and the  !

least 193 vacant storage spaces, discharged fuel assemblies from a maximum number of previous refuelings at la month Maximum Summer Des tan Condition - The intervals. .

d decay heat from discharged fuel  !

assemblies for two' consecutive 45 day j refueling outages on alternate units at .

the end of the second outage period and i the discharged fuel assemblies from a l maximum number of previous refuelings at i is month intervals while maintaining at '!

least 193 vacant storage spaces.

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Facility Name: Comanche Peak Unit Number (s): 1&2 i l

SFF Destan Best Normal: Emergeney/ Abnormal: 48.0 MBTU/hr with SFP !

Lead (MBTU/Br) Maximum: 39.8*MBTU/hr with SFP temperature <212*F and both ecoling loops I and Tamperature temperature <150*F with two cooling operating 1

(*F) loops and <200*F with one cooling loop Maxienas Sumner: 12.7 MBTU/hr with SFP temperature <150*F with two cooling loops and (200'T with one cooling loop i i

SFF Cooling No. of Trains: Two Licensed to Withstand Single Active I system Component Failure: Yes No. of SFPs Served by Each Train: Both Electrical Qualification and Independence of Power Load Shed Initiators: Undervoltage or SI i Supply to SFP Supply: Fully Independent Class 1E Signal, Separately  !

Cooling System ,

Pumpo l 1

Backup SFP System Name: None Qualific ation : N/A Cooling:

SFP Beat Sys tem N ame : Component Cooling Water Qualification: Seismic Category I, Eachanger System (shared loop) Quality Group C Cooling Water Secondary System Name: Service Water System Qualification: Seismic Category I, Cooling Water Quality Group C Loop (if appliemble)

Ultimate Best Typer Man-made pond UHS Design Temperature: 102*F (94*F Sink September to May during refueling based on one shutdown unit and one unit at full  !

power) ]

SFP Cooling Design Heat Capacity: 13.6 MBTU/hr Type: Shell & Tube System Beat Eschanger SFF Side Flow (1b/hr or GPH): 1.8 Cooling Water Flow (1b/hr or GPM):

Performance M1b/hr 2.0 M1b/hr (51sbest capability Beat SFP Temperature: 120*F Cooling Water Inlet Temp: 105'T Enebangne if not Identig al)

STP Cooling Loop Return Temp: 112.5 Cooling Water Outlet Temp: 111.8*T SFP Related Parameter (s): Common Control Room Alarm- Satpoint; control Roam low /high level 1 f t band around normal level

Alarna high temp 150*F low pump discharge pressure 80 PS10  ;

Loestion of SFP Level: Alarm on STP Coolang System SFP Temperature: SFP Cooling System Panel Indientions Penel and Piping, Computer points STP Cooling Parameter (s): None Independence: N/A System Automatic Pump Tripe SFP Boiling Staff Acceptance of non-Seismic SFP Off-site Consequences of STP Boiling Cooling System Based on Sessmic Category Evaluated: No I SFP Venttistion System: N/A If Yes, Was Filtration Credited:

SFP/Reestor Separation of SFP Operating Floor from Separation of Units at Multi-Unit Sites:

System Portiun of Aux. or Reactor Bldg. that Shared STP operating floor with redundant, Separation Contains Reactor Safety Systems: SFPs shared ventilation trains discharging to located in a separate and independent common filtration units in the auxiliary fuel building that does not house building reactor safety system components

b Pasility Nemer Comanche Peak Unit Nuncer(s): 1&2 Seevy Load SFP Area Crane Qualified to Single Routine Spent Fuel Assembly Transfer to Failure Proof Standard 1AW NUREG-0612 ISTSI or Alternate Wet Storage Location:

Baad11as and/or NUREG-0554: 'Yes No Operatias Administrative Control Limit (s) for SFP Administrative Control Limits for SFP Practices Temperature durins Refueling: 140*F Cooling System Redundancy and SFP Hake-up System Redundancy: No restrictions on +

redundancy during refuelins, Frequency of Full-Core Off-loads: All Administrative Controls on Irradiated Fuel prior outages Decay Time prior to Transfer from Reactor Vessel to SFP: 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> by TS Type of Off load Performed durins Host For Units with Planned Refueling Outages Recent Refuelins: Full Core Scheduled to Begin Before April 30, 1996, Type of off-load Planned for Next-Refuelins and Planned shutdown Dates Full Core 4

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s SPENT FUEL POOL DECAY HEAT BACKGROUND REVIEWS

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1.0 PLANT HISTORIES Since October 1992, the staff has been evaluating a series of issues associated with the spent fuel storage pool safety at nuclear power plants.  !

The staff effort was prompted by several events including: (1) a report filed pursuant to 10 CFR Part 21 which detailed numerous potential design deficiencies in spent fuel storage related systems at the Susquehanna Steam  !

Electric Station, (2) a potential for spent fuel pool draindown at Dresden '

Unit 1 in January 1994 and (3) a license amendment application regarding spent fuel pool controls and refueling outage practices at Millstone Unit 1.  ;

1.1 Susquehanna Part 21 Report The staff conducted an extensive evaluation of the Susquehanna Part 21 report and issued a final safety evaluation in June 1995. The Part 21 report ,

described how a sustained loss of spent fuel pool cooling could degrade safety i system performance during various design basis events and could ultimately I lead to core damage and severe offsite consequences. In its safety evaluation, the staff concluded that the risk posed by the concerns outlined in the Part 21 report were low. However, the staff noted that the Susquehanna licensee had made certain changes in the design and operation of the facility during the course of the staff review. These changes made a quantifiable improvement in r4 6 from spent fuel pool loss of co'oling events. Because spent fuel pool cooiing system designs vary significantly from plant to plant and because the modifications made by the Susquehanna licensee had made quantifiable risk improvements, the staff initiated a generic action plan to evaluate the applicability of the Part 21 report concerns at all operating reactors.

The staff is nearing completion of the generic action plan. In order to have sufficient information to perform regulatory analyses during potential backfit proceedings, the staff has identified the need to have detailed design information regarding the spent fuel pool and its cooling and containment systems. One element of the SFP CLB project will be the gathering of this detailed design information into a design data base described in Section 5.

1.2 Dresden Potential Draindown Event On January 25, 1994, the licensee for the Dresden Nuclear Power Plant, Unit I discovered approximately 55,000 gallons of service water in the basement of the unheated Unit I containment. Dresden I has been permanently shutdown since October 31, 1978. The water originated from a rupture of the service water system piping inside the containment that had been caused by freeze damage to the system. The licensee investigated the circumstances further and found that there was a potential for a portion of the spent fuel pool system inside the containment to fail in a similar manner and result in a partial draindown of the spent fuel pool, which contained 660 spent fuel assemblies.

Attachment 5

The staff issued NRC Bulfetin 94-01, " Potential Fuel Pool Draindown Caused by Inadequate Maintenance Practices at Dresden Unit 1" requesting that permanently shutdown facilities address the p:tential for draining the spent fuel pool coolant level below the top of the spent fuel assemblies. As part of the generic action plan described previously, the staff is examining the potential for problems similar to those found at Dresden Unit I to exist at operating re.ctors. The detailed design information gathered as part of the this project will assist the staff in closing this issue.

1.3 Millstone Unit 1 Refueling Practices In July 1995, llortheast Utilities submitted a license amendment package for Millstone Ur.it 1 in which the licensee requested that the staff approve a full core of.hd as a normal refueling practice, approve certain new decay heat analysis methods and approve certain new technical specification (TS) requirements. In subsequent correspondence however, the licensee concluded that the license amendment was not necessary and that the associated ,

conservative TS rer'rictions could have been implemented pursuant to l 10 CFR 50.59. The ticensee stated that it was requesting the amendment, "not because we had determined it was required, but as a conservative approach which had as its purpose the removal of any ambiguity regarding our refueling practice."

The staff conducted an extensive review of the Millstone application. In l conducting the review, the staff examined a number of design issues, operating l and administrative procedural issues and licensing basis issues. As a result  !

of the review, the staff concluded that the licensing basis for Millstone i regarding the practice of conducting a full core offload contained some )

ambiguities that were likely to be found in the licensing bases for other  !

nuclear power plants. Separate from the licensing basis review, the staff I also concluded that there were a number of weaknesses in design control and j procedure development as it pertained to refueling outage practice and refueling outage decay heat removal.  ;

The staff subsequently examined refueling outage licensing issues at Cooper and concluded that ambiguities existed in the Cooper licensing documents as ,

they pertained to refueling offload practice as well. In order to preclude confusion on the interpretation of the Cooper licensing basis, the Cooper  !

licensee clarified the ambiguities by changing the affected Final Safety Analysis Report (FSAR) passages pursuant to 50.59.

Both the Cooper review and the Millstone 1 review were done shortly before or after the start of a scheduled refueling outage. The SfP CLB review project described in Section 3. and 4. is designed to ensure that the staff recognizes the CLB regarding core offload practices and understands licensee compliance ,

with those requirements prior to the next scheduled refueling outage for each l facility.

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. 2.0 CORE OFFLOAD PRACTICE In the recent past, the practice of performing a full core offload as part of refueling outage has become common at nuclear power plants. This i

practiceintroduces a greater decay heat load into the spent fuel pool than I would be introduced with a one-third core offload (core shuffle). Nuclear power plants have systems installed to remove the decay heat associated with l irradiated fuel and these systems include shutdown cooling systems, residual '

heat removal systems and spent fuel pool cooling systems. At some plants however, the spent fuel pool cooling system may not be sized sufficiently, by >

f tself, to remove the decay heat from a recent full core offload and still maintain spent fuel pool temperatures within design limits. Such plants can address this issue in one of several ways, including (1) delaying transfer of the full core to the spent fuel pool until the decay heat from the core has  ;

decreased to an appropriate level or (2) using other installed systems, such '

as the residual heat removal system, in an assist capacity to remove irradiated fuel decay heat in excess of that which can be removed by the spent fuel pool cooling system alone.

Licensing basis documents, including FSARs, Operating License Safety Evaluation Rep 0rts (0L-SER) and spent fuel pool rerack amendment documents, provide a discussion of the design capability of the spent fuel pool cooling system. These system descriptions typically mirror the structure and language of NUREG-0800, " Standard Review Plan for Nuclear Power Plants" (SRP), Section 9.1.3 on Spent Fuel Pool Cooling Systems. The system discusrions describe the spent fuel pool temperature limits which can be maintained by the spent fuel pool cooling (SFPC) systems for several different decay heat loads in the pool.  ;

i Typically, SFPC systems, functioning by themselves, can maintain a specified  !

. temperature limit for heat loads up to and including a heat load associated i with a one third core offload (including the historical inventory of spent fuel already in the pool). Generally, SFPCs can maintain these limits even 1 under postulated single failure events. In addition, spent fuel pool cooling systems can maintain a higher specified spent fuel pool temperature limit for higher heat loads, up to and including those associated with a full core offload. For certain facilities, additional cooling capabilities, such as RHR assist mode operation, would be necessary to maintain the higher temperature limits under the higher postulated heat loads. Additionally, it may not be  ;

possible to meet temperature limits while maintaining single failure '

capability under these higher postulated heat load conditions. The spent fuel pool cooling system limitations under these higher heat load conditions are  ;

recognized in the SRP and these limitations were found acceptable by the staff  ;

for many nuclear power plants.

The SRP introduces two terms, " normal" and " abnormal" in referring to the

- two different design heat loads described above. The SRP states in part.  ;

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For the maximum normal heat load with normal cooling systems in operation, and assuming a single active failure, th1 temperature of-the pool should be kept at or below 140 F and the liquid level in the pool should be maintained. For the abnormal maximum heat load (full core offload) the temperature of the pool water should be kept below boiling and the liquid level maintained with normal systems in operation. A single active failure need not be ,

considered for the abnormal case.

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In the Millstone and Cooper cases, there was confusion about whether the use of the term " abnormal"(or in some cases " emergency") in referencing decay heat ~ >

load, represented an assumption or limitation on the actual practice of conducting a full core offload during refueling outages. The staff concluded that there was no such explicit or implicit restriction introduced by the use of this terminology. However, when a full core offload is conducted as part of a planned refueling outage, the temperature limits associated with the analysis of the normal case applies.

Project managers should review the portions of the FSAR for their facility '

which describes spent fuel pool cooling systems. Project managers should become familiar with the systems descriptions and the terminology used in those descriptions. Project managers are encouraged to discuss the FSAR commitments on spent fuel pool cooling with their rbsident and regional inspector counterparts. Licensee's can be encouraged to revise potentially ambiguous FSAR passages pursuant to 10 CFR 50.59..

3.0 DECAY HEAT REMOVAL PRACTICE AND LICENSING BASES:

1 Although no specific restrictions on offload practice should be inferred from the . typical FSAR description of the spent fuel pool cooling system, the removal of decay heat from the spent fuel pool is an important safety  ;

function. As such, it is important that licensee's adequately plan the decay heat removal function for all phases of the outage including those where the fresh full core is in the vessel, those where the full core is in the spent fuel pool and those where the fresh core is in transition. Examples of potential issues for review by PMs and inspector counterparts include are discussed in the following paragraphs.

FSAR descriptions of SFP cooling systems often discuss the decay heat loads imposed on the spent fuel pool cooling system in terms of full or partial core offloads, time after shutdown before fuel is transferred and historic inventory in the spent fuel pool. These parameters can be combined to represent an assumed heat load, in BTV/hr, for the purpose of analyzing the spent fuel pool cooling system capacity. None of these parameters by themselves represent a licensing limit or restriction, but it is incumbent upon the licensee to assure that the heat load in the spent fuel pool is not greater than t!.at which the spent fuel pool cooling system (alone or in combination with various assist systems) can reject and still meet FSAR temperature commitments. PMs, in conjunction with their regional and resident inspector counterparts,- can review whether licensee's have adequately

t evalusted the decay heat removal issues for the various phases of a refueling ,

outage, i As discussed above, systems such as shutdown cooling systems and RHR systems ,

may be designed with the ability to provide spent fuel pool decay heat removalcapacity over and above that provided by the spent fuel pool cooling system. At many facilities, this mode of SDC or RHR operation is rarely used.

4 Inherent or planned delays in the transfer of fuel from the reactor to the ,

spent fuel pool may allow decay heat levels to decrease to within the capacity of the spent fuel pool cooling system. Alternatively, operation of the SDC or RHR system, in a normal shutdown cooling mode (i.e. lined up to the reactor vessel) may provide a decay heat removal capacity from the fuel pool if the i reactor cavity is flooded and the gates to the spent . fuel pool are open.  !

Licensees with the potential to use RHR or SDC systems in a direct fuel pool cooling assist mode should have procedures and training to accomplish this t function. In recent cases reviewed by the staff, licensee procedures in this  !

area were weak.

In other cases in the recent past, licensees have planned spent fuel pool  ;

system maintenance during a refueling outage. In one case, a spent fuel pool  ;

cooling system train failed while the remaining train was out for maintenance 1 during a refueling outage. Although excessive heating of the spent fuel pool 4 was prevented by rapid reassembly of the train under maintenance, the licensee calculated that the fuel pool could have reached boiling in as little as four or five hours.  :

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