ML20148K742

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Application for Amends to Licenses NPF-2 & NPF-8,proposing Changes Found in Tech Specs 3/4.9.13, Storage Pool Ventilation (Fuel Movement)
ML20148K742
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 06/13/1997
From: Dennis Morey
SOUTHERN NUCLEAR OPERATING CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20148K748 List:
References
NUDOCS 9706180347
Download: ML20148K742 (8)
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,*. Deva M r:y S:utheraNucle r Vice Presdent Op;t: ting Ccmpany I

' ~ Farley Pmmt P.O. Box 1295 Bamingham. Alabama 35201 Tel 205 992.5131 June 13,1997 SOUTHERN COMPANY Energy to Serve Your%%" 7 Docket Nos.: 50-348 10 CFR 50.90 ,

50-364 U.S. Nuclear Regulatory Commissior.

ATTN: Document Control Desk Washington, DC 20555  :

Joseph M. Farley Nuclear Plant Request to Revise Technical Specifications and Associated Bases Storage Pool Ventilation (Fuel Movement) l Ladies and Gentlemen:

l In accordance with the provisions of 10 CFR 50.90, Southern Nuclear Operating Company (Southern Nuclear) proposes to amend the Joseph M. Farley Nuclear Plant Units 1 and 2 Technical Specifications (TSs). The proposed changes are found in TS 3/4.9.13, Storage Pool a

Ventilation (Fuel Movement), of the Unit I and Unit 2 TSs and the essociated Bases. The first ,

of these proposed changes will add a note in the TSs to specifically indicate that the normal or emergency power source may be inoperable in MODE 5 or 6 provided that the requirements of ,

TS 3.8.1.2 are satisfied. The second of these proposed changes will extend the TS 3.9.13 I completion time allowed for returning one out-of-service penetration room filtration system from 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to 7 days. The Bases will also be modified to provide additional detail concerning these changes. These TS changes are technically consistent with the requirements 1 l ofNUREG-1431, Revision 1," Westinghouse Standard Technical Specifications," issued on  !

April 7,1995.

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The basis for the proposed TS changes is provided in Enclosure 1. The supporting significant hazards evaluation pursuant to 10 CFR 50.91 is provided in Enclosure 2. Based upon the

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l analysis provided, Southern Nuclear has determined that the proposed changes to the TS do

! not involve a significant hazards consideration as defined by 10 CFR 50.92. Sou has determined that the proposed license amendment will not significantly affect the quality of ,

the human environment.  ;

l The revised typed pages of the proposed TSs, including page change instructions, are included in Enclosure 3. The marked pages are provided in Enclosure 4.

The Plant Operations Review Committee has reviewed and recommended approval of these proposed changes. A copy of these proposed changes is being sent to Dr. Donald E.

Williamson, the Alabama State Designee, in accordance with 10 CFR 50.91(b)(1). l

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U.S.' Nuclear Regulatory Commission Page 2 Approval status of this amendment request will atTect the upcoming outage duration.

Therefore, NRC review and approval of these proposed changes is requested by October 1997, ,

to support planning efTorts for the Spring 1998 outage. j 1

If there are any questions, please advise j Respectfully submitted,  !

l SOUTilERN NUCLEAR OPERATING COMPANY -

$1 }7lpw l l Dave Morey

. Sworn to andsubscribed bgore me this /3 Y day o 199, as b

Notary Public  !

! My Commission Expires: /, Nb JMG/ cit:zzzprf. doc

Enclosures:

1. Basis for Change Request
2. 10 CFR 50.92 Evaluation
3. Page Change Instructions and Revised Pages
4. liand-Marked Pages cc: Mr. L. A. Reyes, Region 11 Administrator Mr. J.1. Zimmerman, NRR Project Manager Mr. T. M. Ross, Plant Sr. Resident inspector Dr. D. E. Williamson, State Department of Public Health l

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  • ENCLOSURE 1 l

Joseph M. Farley Nuclear Plant l Request to Revise Technical Specifications and Associated Bases Storage Pool Ventilation (Fuel Movement) 113 sis for Change Reques.1_

The first of the proposed changes will add a note in technical specification (TS) 3/4.9.13 to specifically indicate that the normal or emeigency power source may be inoperable in MODE 5 l or 6 provided that the requirements of TS 3.8.1.2 are satisfied. Currently, the TSs do not I specifically note that either the normal or emergency power sources may be inoperable during 1 MODE 5 or 6. The Farley Nuclear Plant (FNP) design basis for electrical sources during refueling (TS 3.8.1.2) requires at least one offsite circuit through the IE distribution system be ;

operable and at least one of the emergency diesels be operable. If the present TS 3/4.9.13 was read to require that both independent penetration room filtration systems be operable when it is aligned to the spent fuel room during refueling operations - using the definition of OPERABLE in the TSs - each system would have to have at least one offsite circuit through the 1E distribution system and at least one of the emergency diesels to be operable. This l interpretation would require that, for the Penetration Room Filtration sy', tem to be in an I operable status when it is aligned to the spent fuel room during refueling operations, at least two offsite circuits through separate 1E distribution systems and at least two emergency diesels must be operable. This requirement for diversity and redundancy during periods of refueling is beyond the required design basis of the plant. The associated Bases will also include a statement that, in Modes 5 and 6, the electrical power requirements do not require considering a single failure coincident with a loss of all offsite or all onsite power.

The note that is being proposed provides clarification relative to the electrical system requirements for the penetration room filtration system when it is aligned to the spent fuel pool room during refueling operations. This issue was suitably addressed when the Improved Westinghouse Standard Technical Specifications NUREG-1431, Revision 1 (ITS) were issued on April 7,1995. This change is technically consistent with the requirements of the ITS.

The second of these proposed changes will extend the TS 3.9.13 completion time allowed for returning one out-of-service penetration room filtration system from 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to 7 days. This specification is applicable during crane operation with loads over the fuel in the spent fuel pit and during fuel movement within the spent fuel pit. The 7 day completion time for this action is consistent with the existing TS 3.7.8, Penetration Room Filtration System (Modes 1-4). The 7 day completion time is based on the low likelihood of an event occurring during this time l

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Enclosure 1 Basis for Change Request l

l that would require this system to function, the fact that the remaining operable train is capable of automatically providing 100% of the required system function, and the capability exists to manually operate system components on the inoperable train, if required. This change will make the two TS requirements for this system (3.9.13 and 3.7.8) consistent and still provide a ,

sufficient restriction upon plant operation to avoid an undue rish to public health and safety. 1 This change is also technically consistent with the requirements of the ITS. The associated Bases will also include additional information regarding this change.

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ENCLOSURE 2 Joseph M. Farley Nuclear Plant Request to Revise Technical Specifications and Associated Bases Storage Pool Ventilation (Fuel Movement) i 1.0 CFR 50.92 Evaluation Pursuant to 10 CFR 50.92 each application for amendment to an operating license must be reviewed to determine if the proposed change involves a significant hazards consideration. l The amendment, as defined below, describing the Technical Specifications changes to the Storage Pool Ventilation during fuel movement requirements and the associated Bases, has been reviewed and deemed not to involve a significant hazards consideration. The basis for this determination follows.

BACKGROUND One of the purposes of the penetration room filtration system is to ensure that radioactive material released as a result of a fuel handling accident in the spent fuel pool room will be filtered through the HEPA filters and charcoal absorbers prior to discharge to the atmosphere.

Physically, for each unit, there are two systems which perform functions during normal operations and other functions during refueling operations. The governing specifications for these systems during normal operations in Modes 1-4 are TS 3/4.7.8, Penetration Room Filtration Systems. The governing specification during refueling operations is 3/4.9.12 and 3/4.9.13. The current specification, read literally -- using the definition of OPERABLE in the technical specification -- would require at least two offsite circuits through separate 1E distrib systems and at least two emergency diesels for the penetration room filtration system :., oe in an operable status when it is aligned to the spent fuel room during refueling operations.

Likewise, the completion time allowed for returning one out-of-service penetration room filtration system is 7 days during Modes 1-4 (TS 3.7.8). The current TS 3.9.13 requirement provides a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> allowed outage time for one out-of-service penetration room filtration system during crane operation with loads over the fuel in the spent fuel pit and during fuel movement within the spent fuel pit. There is a low likelihood of an event occurring during this time that would require this system to function. The remaining operable train is capable of automatically providing 100% of the required system function and capability exists to manually operate system components on the inoperable train, if required.

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' l l Enclosure 2 i 10 CFR 50.92 Evaluation l

DESCRIPTION OF CHANGE REOUEST The first proposed change will specifically note that the normal or emergency power source may be inoperable in MODE 5 or 6 provided that the requirements of TS 3.8.1.2 are satisfied.

Currently, the TSs do not specifically note that either the normal or emergency power sources may be inoperable during MODE 5 or 6. The Farley Nuclear Plant (FNP) design basis for electrical sources during refueling (TS 3.8.1.2) requires at least one offsite circuit through the l 1E distribution system be operable and at least one of the emergency diesels be: 4.:rable. The I placement of this proposed note will clarify any misconceptions relative to the required electrical power sources. The associated Bases will also be modified to state that, in Modes 5 and 6, the electrical power requirements do not require considering a single failure coincident with a loss of all offsite or all onsite power. This issue was also suitably addressed when the Improved Westinghouse Standard Technical Specifications NUREG-1431, Revision 1 (ITS) were issued on April 7,1995. This change is technically consistent with the requirements of the ITS.

The second proposed change will extend the TS 3.9.13 completion time allowed for returning l one out-of-service penetration room filtration system from 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to 7 days. This change will make the two TS requirements for this system (3.9.13 and 3.7.8) consistent and still provide a suflicient restriction upon plan: operation to avoid an undue risk to public health and safety. This change is also technically consistent with the requirements of the ITS. The associated Bases will also be revised to state that during this period, the remaining OPERABLE train is adequate to perform the penetration room filtration (PRF) function and that the 7 day completion time is based on the low risk of an event occurring requiring the inoperable PRF train, and the capability of the remaining PRF train to provide the required protection.

ANALYSIS Regarding the first proposed change, the allowance to have both penetration room filtration systems powered in accordance with TS 3.8.1.2, when they are aligned to the spent fuel pool room, is technically consistent with the FNP licensing basis. When a unit is shut down, TS 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 l

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10 CFR 50.92 Evaluation power is not required. This proposed change is technically consistent with the requirements of NUREG-1431, Revision 1 which has already received the requisite review and approval of the NRC stafT.

Regarding the second proposed change, extending the TS 3.9.13 completion time allowed for returning one out-of-service penetration room filtration system from 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to 7 days is

! consistent with the existing TS 3.7.8, Penetration Room Filtration System (Modes 1-4). The 7 day completion time is based on the low likelihood of an event occurring during this time that would require this system to function and the fact that the remaining operable train is capable of automatically providing 100% of the required system function. This change will make the two TS requirements for this system (3.9.13 and 3.7.8) consistent and still provide a sufficient restriction upon plant operation to avoid an undue risk to public health and safety. This change is technically consistent with the requirements of the ITS.

10 CFR 50.92 EVAL.UATION CONCLUSIONS Based on the preceding evaluation, the following conclusions are provided with respect to the criteria contained in 10 CFR 50.92.

(1) The proposed changes do not significantly increase the probability or consequences of an accident previously evaluated in the FSAR. The proposed changes have no impact on the probability of an accident. The storage pool ventilation system will continue to ensure that radioactive material released as a result of a fuel handling accident in the l spent fuel pool room will be filtered through the HEPA filters and charcoal absorbers l prior to discharge to the atmosphere. There is no change in the FNP design basis as a result of this change and, as a result, does not involve a significant increase in the consequences of an accident previously evaluated.

(2) The proposed changes to the TSs do not increase the possibility of a new or different  ;

kind of accident than any accident already evaluated in the FSAR. No new limiting single failure or accident scenario has been created or identified due to the proposed changes. 1 Safety-related systems will continue to perform as designed. The proposed changes do  !

not create the possibility of a new or different kind of accident from any previously evaluated.

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e Enclosure 2 10 CFR 50.92 Evaluation (3) The proposed changes do not involve a significant reduction in the margin of safety. As a result of these proposed changes, the penetration room filtration system, when it is  ;

aligned to the spent fuel pool room, will continue to require verification of operability.

There is no impact in the accident analyses. These proposed changes are technically consistent with the requirements of NUREG-1431, Revision I which has already received the requisite review and approval of the NRC staff. Thus the proposed changes j do not involve a significant reduction in the margin of safety. l Accordingly, Southern Nuclear has determined that the proposed changes with respect to the Storage Pool Ventilation during, fuel movement TSs do not involve a significant hazards consideration.

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