ML20135C651

Application for Amends to Licenses NPF-2 & NPF-8,requesting Revision & Clarification to Surveillance Requirements for Control Room Emergency Filtration Sys,Penetration Room Filtration Sys & Containment Purge Exhaust Filter

ML20135C651
Person / Time
Site:	Farley
Issue date:	02/24/1997
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20135C654	List: ML20135C651 ML20135C673
References
NUDOCS 9703040201
Download: ML20135C651 (9)

Text

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1 l D:ve Mor:y Sruthern Nacisar .

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Vice President Operating Company

, /arley Project P0. Box 1295

,a . Birmingham. Alabama 35201 Tel 205.992.5131 l

February 24,1997 SOUTHERN l COMPANY Energy to Serve YourWorld" i Docket Numbers: 50-348 10 CFR 50.90 50-364 U. S. Nuclear Regulatory Commission (

ATTN: Document Control Desk Washington, DC 20555 Joseph M. Farley Nuclear Plant Request For Technical Specification Changes Control Room, Penetration Room, and Containment Purge Filtration Systems .

Surveillance Reauirements ,

Ladies and Gentlemen:

In accordance with the provisions of 10 CFR 50.90, Southern Nuclear Operating Company (SNC) proposes to amend the Farley Nuclear Plant (FNP) Unit I and Unit 2 Technical Specifications (TS),

Appendix A to Operating Licenses NPF-2 and NPF-8. This amendment revises and clarifies surveillance requirements (SRs) for the Control Room Emergency Filtration System (CREFS), the Penetration Room Filtration System (PRFS), and the Containment Purge Exhaust Filter (CPEF).

On June 22,1984, the NRC approved TS Amendments No. 46 and 37 for FNP Units I and 2 respectively. These amendments, among other changes, clarified the testing requirements for the control room emergency ventilation system, the PRFS, and the CPEF by updating the references from ANSI N510-1975 to ANSI N510-1980 and by adding specific ANSI N510-1980 section numbers to certain SRs. This proposed amendment further clarifies the SRs by updating references to ANSI N510 sections 5,8, and 14 to a later version which is ASME N510-1989 " Testing of Nuclear Air Treatment Systems" with errata dated January 1991 and by adding a footnote which references the FNP Final Safety Analysis Report (FSAR) for relevant testing details. The FNP FSAR is being revised to include a detailed discussion of the applicability of ASME N510-1989 sections 5,8, and 14. Differences between ANSI N510-1980 and ASME N510-1989 have been reviewed by SNC, and conversion to ASME N510-1989 for sections 5,8, and 14 is considered to be an enhancement. In addition, ASME N510-1989 has been approved and endorsed by the NRC in NUREG 1431.

This amendment is required because of questions asked during recent NRC inspections related to the design bases of the PRF system. Historically, FNP has interpreted that only applicable portions of sections of ANSI N510-1980 referenced in the TS were required to be performed. Based on discussions with the NRC, SNC understands that the current NRC interpretation is that unless allowed by the TS, the l

FNP ventilation filter test program for the CREFS, PRF, and CPEF must fully comply with every detail l of ANSI N510-1980 Sections 5,8, and 14. Although these systems have been deemed operable and able to perform their intended safety functions, a TS change is requested.

9703040201 970224 PDR ADOCK 05000348 h@! .I p PDR n tnJ tj y

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U. S. Nuclear Regulatory Commission Page 2 Enclosure I provides a safety assessment for the proposed changes. Enclosure 2 provides the basis for a determination that the proposed changes do not involve significant hazards considerations pursuant to 10 CFR 50.92. Enclosure 3 provides the proposed changes to the Unit 1 Technical Specifications.

Enclosure 4 provides the proposed changes to the Unit 2 Technical Specifications. Enclosure 5 provides the Units I and 2 marked-up Technical Specification pages.

As denoted in 10 CFR 50.92(c), SNC has determined the proposed changes to the FNP Technical Specifications do not involve a significant hazards coinsideration. The basis for this evaluation is provided in Enclosure 2. SNC has also determined that the proposed changes will not significantly affect the quality of the human environment. A copy of the proposed changes has been sent to Dr. D. E.

Williams, the Alabama State Designee, in accordance with 10 CFR 50.91(b)(i).

SNC requests that the NRC review and approve the proposed TS changes on an expedited basis. SNC plans to implement the proposed changes within 30 days ofissuance by the NRC. In addition, SNC is continuing to review the current TS with regard to ventilation filter testing and will submit further changes separately or as part ofits improved Technical Specifications (ITS) submittal.

Mr. D. N. Morey states that he is a vice president of Southern Nuclear Operating Company, and is authorized to execute this oath on behalf of Southern Nuclear Operating Compauy and that, to the best of his knowledge and belief, the facts set forth in this letter and enclosures are true.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY

- Dave Morey hb&*y y ch!/prcreprl. doc SWORN TO AND SUBSCRIBED BEFORE ME

Enclosures:

THIS c DAY OF714Aa .1997

1. Safety Assessment

2. 10 CFR 50.92 Evaluation NN '

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3. Unit 1 Technical Specification Pages Notary Pufilic

4. Unit 2 Technical Specification Pages

5. Units 1 & 2 Marked-Up Technical MY COMMISSION EXPIRES: N/o//9'2 Specification Pages cc: U. S. Nuclear Reentatnry Commission Mr. L. A. Reyes, Regional Administrator Mr. J. I. Zimmerman, Licensing Project Manager, NRR Mr. T. M. Ross, Senior Resident inspector, Farley State Of Alahamn Dr. D. E. Williams

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Enclosure 1  :

Joseph M. Farley Nuclear Plant '

} Control Room, Penetration Room, and Containment Purge Filtration Systems

Surveillance Requirements i Technical Specification Changes  !

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Safety Assessment 7

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, . 1 Enclosure 1 Joseph M. Farley Nuclear Plant Control Room, Penetration Room, and Containment Purge Filtration Systems Surveillance Requirements Technical Specification Changes i Safety Assessment l

ne Farley Nuclear Plant (FNP) Technical Specifications (TS) surveillance requirements (SRs) for TS 3/4.7.7 Control Room Emergency Filtration System (CREFS), TS 3/4.7.8 Penetration Room Filtration '

System (PRFS), and TS 3/4.9.14 Containment Purge Exhaust Filter (CPEF) are proposed to be revised.

FNP TS SRs currently reference ANSI N510-1980 for performing visualinspections (section 5), verifying system flow rate (section 8), and verifying heater power for FNP ventilation and filtration systems (section 14). Specific sections within ANSI N510-1980 do not clearly differentiate beveen testing required for l initial acceptance testing and testing required for periodic surveillances. In addidon some charact~istics of the FNP system designs do not allow for complete application of the 1980 standard without ma.vr disassembly or significant breaching of pressure boundaries. He following is a summary of the proposed TS changes:

1. TS SRs that currently reference ANSI N510-1980 sections 5, 8, and 14 will be changed to make reference to ASME N510-1989.

2. Wherever ASME N510-1989 is used in the TS SRs a footnote will be added that states:

"The FNP Final Safety Analysis Report identifies the relevant surveillance testing requirements."

l It is the intent of the above proposed changes to clarify the requirements associated with FNP filtration i system testing. Conversion of the ANSI N510-1980 to ASME N510-1989 for section 5, 8, and 14 will '

bring FNP SRs closer to current industry standards. In addition similar changes have been previously approved by the NRC for other nuclear plants. He relocation of specific testing requirements to the l FSAR is consistent with guidance provided by NUREG 1431 Improved Standard Technical Specifications for Westinghouse Plants. FNP has committed to the NRC by a previous docketed letter to submit an ITS conversion package.

Differences between ANSI N510-1980 and ASME N510-1989 have been resiewed by SNC, and conversion to ASME N510-1989 for sections 5, 8, and 14 are considered to be an enhancement. In addition, ASME N510-1989 has been approved and endorsed by the NRC in NUREG 1431. Inclusion of the specific testing requirements in the FNP FSAR will ensure that any desiation to the testing requirements l of ASME N510-1989 will receive appropriate review through the 10 CFR 50.59 process for this change and any changes made in the future.

SNC also wishes to clarify that TS references to ANSI N510-1980 sections that internally reference ANSI N510 sections 5, 8, or 14 will be performed using the comparable ASME N510-1989 section 5, 8, or 14.

l His is acceptable since sections 5,8, and 14 between the 1980 and 1989 standards are comparable and will not affect the overall acceptability of required testing.

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Enclosure 2 l I

Joseph M. Farley Nuclear Plant i Control Room, Penetration Room, and Containment Purge Filtration Systems l 1

Surveillance Requirements Technical Specification Changes

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l 10 CFR 50.92 Evaluation '

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I e Enclosure 2 Joseph M. Farley Nuclear Plant Control Roosa, Penetration Room, and Containment Purge Filtration Systems Surveillance Requiresnents Technical Specification Changes 10 CFR 50.92 Evaluation Pursuant to 10 CFR 50.92, SNC has evaluated the proposed amendments and has deternuned that operation of the facility in accordance with the proposed ar.acndments would not involve a signi6 cant hazards consideration. 'the basis for this deternunaten is as follows:

1. The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

'Ihe proposed changes to convert from ANSI N510-1980 to ASME N510-1989 for specific FNP filtration surveillance testmg requirements do not a&ct the probability of any accident occurring. The consequences of any accident will not be affected since the proposed change will continue to ensure that appropriate and required surveillance testing for FNP filtration systems will be performed.

Relocatmg specific testing requirements to the FNP FSAR has no effect on the probability or consequences of any accident previously evaluated since required testmg will continue to be performed.

Therefore, the proposed TS changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. The proposed changes do not crea2 the possibility of a new or different kind of accident from any accident previously evaluated.

Testmg differences between ANSI N510-1980 and ASME N510-1989 have been evaluated by SNC and none of the proposed changes have the potential to create an accident at FNP. ANSI N510-1989 has been endorsed and approved by the NRC for licensee use in NUREG 1431. No new system design or testing configuration is being proposed that could create the possibility of any new or different kind of accident from any accident previously evaluated. Relocating specific testing requirements to the FSAR has no effect on the possibility of creatmg a new or different kind of accident from any accident previously evaluated since it is an administrative change in nature.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

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4 Enclosure 2 10CFR50.92 Evaluation

3. The proposed changes do not involve a significant reduction in a margin of safety. l Conversion from the testing requirements of ANSI N510-1980 sections 5,8, and 14 to ASME N510 '

1989 sections 5, 8, and 14 has been previously approved by the NRC at other nuclear facilities.

ASME N510-1989 has been approved and endorsed by the NRC in NUREG 1431. Relocating specific j_ testing requirements to the FSAR has no effect on the margin of plant safety since required testing will i i continue to be performed. Therefore, SNC concludes based on the above, that the proposed changes do 4 not result in a significant reduction of margin with respect to plant safety as defined in the Final Safety  ;

Analysis Report or the bases of the FNP technical specifications.

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Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Conclusion '

Based on the precedmg analysis, SNC has determmed that the proposed change to the Technical j Specifications will not significantly increase the probability or consequences of an accident previously i evaluated, create the possibility of a new or different kind of accident from any accident previously i evaluated, or involve a significant reduction in a margin of safety. SNC therefore concludes that the  !

proposed change meets the requirements of 10 CFR 50.92(c) and does not involve a significant hazards consideration.  ;

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i Enclosure 3 Joseph M. Farley Nuclear Plant j Control Room, Penetration Room, and Containment Purge Filtration Systems i Surveillance Requirements  ;

, Technical Specification Changes i

i Unit 1 Technical Soecification Pares I

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FNP Unit 1 1

Technical Specincations  !

Control Room, Penetration Room, and Contamment Purge Filtration Systems l

Surveillance Requirements i l

Channed Panes j Page# Instructions

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3/4 7-17a Replace ,

3/4 7-18 Replace 3/4719 Replace '

3/4 9-17 Replace t

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