ML20236M996

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Forwards Response to Questions Re Ventilation Specs for Farley
ML20236M996
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 03/27/1997
From: Charemagne Grimes
NRC
To: Linda Watson
NRC
Shared Package
ML20236J990 List: ... further results
References
FOIA-98-155 NUDOCS 9807140353
Download: ML20236M996 (4)
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  • gt3 Christopher Grimes From:

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Date:

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Subject:

Ferley TS question-Reply [

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It took us a while, but we finally assembled the attached reply to your questions concoming the ventilation specs. If you have any further questions, please contact Tom Dunning.

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QUESTIONS: When a licensee fails to meet a TS LCO and there is no action statement that covers the situation, is the licensee required by 50.36 to move a

into a condition where the TS is not applicable? If they do not, is there a TS LCO violation? Is the licensee required to report this situation under 50.73 as a condition prohibited by TSs?

l Recently, at Farley, a condition existed where both systems of the penetration room filtration system were inoperable. Two systems are required to be l

OPERABLE to meet the TS LCO. The action statement addresses inoperability of one system calling for the system to be placed back in service'within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or fuel movement must be stopped. The action statement also says that TS 3.0.3 is not applicable.

(The operators initially stopped fuel movement and at management direction resumed fuel movement based on a TS interpretation that concluded that one system was operable. The interpretation was submitted to NRC for review.

NRR's response to that separate issue was dated March 6, 1997 and concluded both systems were inoperable.)

Per 50.36.(c)(2) when a licensee cannot meet an LCO "the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met."

l

RESPONSE

l In general, we do not refer to the 150.36 requirements to place the plant in a condition in which the LCO does not apply. Rather, the technical specifications (TS) are constructed with requirements to shut down the reactor or follow any remedial action permitted by the TS until the condition can be met. For plant shut down conditions, where LCO 3.0.3 is moot, the TS usually include remedial actions to place the plant in a condition for which the LCO does not apply. Depending on the vintage of the license, these general principles may not be as clearly articulated as they are in the STS.

.I The Farley TS requirement for Penetration Room Filtration Systems during refueling operations, Specification 3.9.13, " Storage Pool Ventilation (Fuel Movement)," states:

Two independent penetration room filtration systems (Specification 3.7.8) shall be OPERABLE and aligned to the spent fule (sic) pool room:

l The Applicability is:

During crane operation with loads, over the fuel in the spent fuel pit l

and during fuel movement within the spent fuel pit.

The Actions are:

a.

With one penetration room filtration system inoperable return boths (sic) systems to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or suspend all i

movement of fuel and crane operation with loads over the spent fuel in the storage pool room.

b.

The provisions of Specification 3.0.3 and 3.0.4 are not applicable.

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With ene filtration sub-system inoperable, the licensee has 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to restore it to OPERABLE status or suspend movement of fuel and crane operation, in which case the LC0 would no longer apply. Because there is an exception to S> edification 3.0.4, the facility could initially be in a condition in which tse LCO does not apply and action is being taken restore an inoperable filtration system to OPERABLE status. The licensee could enter the conditions where the LCO applies (for example, crane operation), then the inoperable sub-system must be restored to OPERABLE status within the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />; otherwise, the licensee must suspend those operations to avoid a violation of the LCo.

When both sub-systems inoperable, Action "a" states that the action is to

'NW-- boths (sic) systems to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />" or take the action specified that would place the facility in a condition that the LCO no longer applies. The reference to both systems is misleading, but it appears clear that the intent is to restore redundant system function within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of discovering an inoperable sub-system. The Bases of the Farley TS do not provide substantial clarification. The Bases merely states that the limitations on the storage pool ventilation system ensure that all radioactive material released from an irradiated fuel assembly will be filtered through the HEPA filters and charcoal adsorber prior to discharge to the atmosphere.

Obviously, the release of radioactive material is only the consequence of an handling accident, since the remedial actions are to suspend operations that have the potential of causing such events.

The provisions of LCO 3.0.3 are not applicable to LCO 3.9.13 because the LCO is formulated for a plant shutdown condition, for which the LCO 3.0.3 shutdown requirements are not relevant. For plant operational MODES, the requirements of LCO 3.7.8 provide comparable requirements for.the ventilation system for which LCO 3.0.3 would apply with two sub-systems are inoperable.

The improved STS make it clear that such operations which defined the applicability of the LCO are to be suspended if a second system is inoperable.

1 The STS guidance for a plant specific basis, is that some plant TS may also require the applicability of LCO 3.0.3 shutdown requirements and extends the applicability to MODES 1 through 4.

The STS shows such requirements as typical / optional.

(Farley has a separate specification requirement that is applicable during these MODES.) This view argues in favor of the conservative interpretation of the Farley TS requirements, which it appears that the licensee does not dispute.

In sumary, for the specific situation described in the question, the licensee believed that one sub-system was operable and had 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. to restore the inoperable sub-system or exit the condition. When the licensee was informed on 3/6/g7 that both sub-systems were considered inoperable, they were in violation of the LC0 for until they exited the condition. The LCO provides for adequate ventilation to ensure that fuel can be moved safely. The TS provide remedial or compensatory actions that would allow for fuel movement with one train of ventilation. Without either train of ventilation, safe i

movement of fuel cannot be assured and, if fuel is moved in such a situation, the LCO has been violated.

Upon acknowledging that both subsystems of the filtration system are inoperable, we would expect that the licensee would find this condition i

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reportable under ene or more of the requirements of 50.73 (condition prohibited by TS, condition outside design basis, or condition not covered by plant operating and emergency procedures).

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