ML20217L894

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Discusses Issue Raised During 970418 Enforcement Conference Re Apparent Difference in Licensing Basis & Design Basis of Prf.Response to Listed Questions Requested within 30 Days of Ltr Date
ML20217L894
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 08/14/1997
From: Jacob Zimmerman
NRC (Affiliation Not Assigned)
To: Dennis Morey
SOUTHERN NUCLEAR OPERATING CO.
References
NUDOCS 9708190215
Download: ML20217L894 (4)


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August 14, 1997 Mr. D. N. Morey Vice President - Farley Project

- Southem Nuclear Operating Company, Inc.

Post Office Box 1295 Birmingham, Alabama 35201-1295

SUBJECT:

CURRENT DESIGN AND LICENSING BASES FOR PENETRATION ROOM FILTRATION SYSTEM, JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 Deer Mr. Morey:

During an enforcement conference on April 18,1997, for Farley, Units 1 and 2, an issue was raised concerning an apparent difference in the licensing basis and design basis of the

- penetration room filtration (PRF) system.

As a result, the NRC staff has bee:: reviewing the licensing basis and design basis for the PRF system. Specifically, Section 6.2.7 of the Farley, Units 1 and 2, Safety Evaluation Report (SER) dated May 2,1975, states that, "The fans will be designed to start automatically by a signal from the radiation monitor in the normal spent fuel ventilation system inlet duct and also by a safety injection signal." In addition, the system would need to be " manually aligned to the penetration rooms prior to start of recirculation of the ECCS [ emergency core cooling system]."

The staff has concluded that initiation on a safety injection signal would mean that PRF would be operational for allloss-of coolant accidents (LOCAs). However, the current system design, as found by the inspectors, and documented in NRC Inspection Report 50-348/97-04 and 50-364/97-04, does not initiate until a high-high containment pressure, and, thus, is unlikely to initiate on a small break LOCA. This is not consistent with the licensing basis or the conventional LOCA Design Basis Analysis (DBA). The guidance for analyzing the radiological consequences of a LOCA does not differentiate between large and small break LOCAs. The analysis starts with the assumption that a LOCA has occurred. This is generally thought of as a double-ended break since it would be the bounding case. However, if some of the engineered safety features (ESF) credited in the analysis do not function for selected LOCAs, the DBA, as analyzed, may not be bounding.

It appears that the Farley PRF design basis may have changed since licensed in 1975. The Farley Final Safety Analysis Report (FSAR) contains conflicting descriptions of the PRF design basis. A discussion in FSAR Section 6.2.3.4.2 indicates that the PRF system initiates on other than a safety injection signal. Other discussions in the FSAR imply that PRF initiates on a LOCA or phar,e A signal.

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~ Mr. D. N. Morey The staff has the following questions regarding the PRF system:

(1)

Please provide the original design basis for the PRF as described in the FSAR at the time of licensing.

(2)

If the original design basis has changed, please provide justification for the change.,

Please include any 10 CFR 50.59 evaluation that may have been done and/or any other analyses that may have been made to support the current design and operating philosphy.

Please respond to the staff's questions within 30 days from the date of this letter. If you have

- any questions, please call me at 301-415-2426.

Sincerely,

[ Jacob 1.

mmerman, Project Manager Project Directorate ll-2 Division of Reactor Projects - 1/ll Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364 cc: See next page

Mr. D. N. Morey August 14, 1997 The staff has the following questions regarding the PRF system:

(1)

Please provide the original design basis for the PRF as described in the FSAR at the time of licensing.

(2)

If the original design basis has changed, please provide justification for the change.

Please include any 10 CFR 50.59 evaluation that may have been done and/or any other analyses that may have been made to support the current design and operating philosphy.

Please respond to the staff's questions within 30 days from the date of this letter. If you have any questions, please call me at 301-415-2426.

Sincerely, ORIGINAL SIGNED BY:

Jacob 1, Zimmerman, Project Manager Project Directorate 11-2 Division of Reactor Projects - t/11 Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364 cc: See next page Distribution:

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Mr. R. D. Hill, Jr.

General Manager -

Southem Nuclear Operating Company Post Office Box 470

- Ashford, Alabama 36312 Mr. Mark Ajiuni, Licensing Mar.ager Southem Nuclear Operating Company t osi Office Box 1295 Birmingham, Alabama 35201-1295 Mr. M. Stanford Blanton

. Balch and Bingham Law Firm Post Office Box 306 1710 Sixth Avenue North Birmingham, Alabama 35201 Mr. J. D. Woodard Executive Vice President Southem Nuclear Operating Company Post Office Box 1295 Birmingham, Alabama 35201 State Health Officer Alabama Department of Public Health 434 Monroe Street Montgomery, Alabama 36130-1701 Chairman Houston County Commission I

Post Office Box 6406 Dothan, Alabama 36302 Regional Administrator, Region ll U.S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth Street, S.W.,- Suite 23T85 Atlanta, Georgia 30303 Resident inspector U.S. Nuclear Regulatory Commission 7388 N. State Highway 95 Columbia, Alabama 36319