ML20248B668

Forwards Supplemental Info Re 890320 Application for Amends to Licenses NPF-2 & NPF-8,per 890613 Telcon Concerning Combustible Gas Control.Revised Tech Specs Encl

ML20248B668
Person / Time
Site:	Farley
Issue date:	09/25/1989
From:	Hairston W ALABAMA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20248B672	List: ML20248B668 ML20248B681
References
NUDOCS 8910030261
Download: ML20248B668 (3)

Text

_ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ - - _ _ _ _ - ___ - _ __

. . .i Alabama Power Company i 40 inverness Center Parkway

• I Post Office Box 1295 Birminghem, Alabama 35201 Telephone 205 868-5581 W. G. Hairston, Ill Senior Vice President Nuclear Operations AlabamaPower September 25, 1989 the southern etectnc system 10CFR50.36 Docket Nos. 50-348 50-364 U.S. Nuclear Regulatory Commission j ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

Joseph M. Farley Nuclear Plant - Units-1 and 2 Supplement to Proposed Miscellaneous Technical Specification Changes By letter dated March 20, 1989, Alabama Power Company submitted several proposed miscellaneous and editorial technical specification changes.

During a telephone conversation held on June 13, 1989, the NRC requested  ;

supplemental information relating to the proposed change to specification i 3.6.4, combustible Gas control. In order to comply with this request Attachment 1 to this letter provides the information' requested. In addition, Attachraent 2 provides a proposed revision to technical specification Page B3/4 6-4 for both units which specifies the alternate means for monitoring containment hydrogen concentration.

Alabama Power Company considers this supplement to be a clarification of our previous submittal which does not affect the conclusions of the 10CFR50.92 significant hazards evaluations provided with the March 20, 1989 letter. The proposed changes are requested by December 1, 1989. A copy of this supplement has been sent to Dr. C. E. Fox, the Alabama State Designee, in accordance with 10CFR50.91(b)(1).

.If there are any questions, please advise.

Respectfully submitted, lb h W V. G. Hairston, III VGH,III/BHV md 9.17 Attachments SVORN TO AND SUBSCRIBED BEFORE ME cc: Mr. S. D. Ebneter -

i Mr. E. A. Reeves THIS 86 AY OF rw M~ , 1989 )

Mr. G. F. Maxwell / . l Dr. C. E. Fox /hef 6 Nn.u Nb Notary PubE c - '

COMSSION EXPRES CEC.15,1992 My Commission Expires:;.

AOO\

8910030261 890925 1 PDR ADOCK 05000348 ' \

P PNU l'

__ _ _ _______ _ __ _________ _ _ _ _ _ _ _ _ _ _ _ _ _ d

~

F . .

e O

Attachment 1 1 Response to NRC Request for Supplemental Information l Proposed Change to Specification 3.6.4 Combustible Gas Control Add a statement to Specification 3.6.4.1.a that disclaims the provisions of Specification 3.0.4 which requires that entry into an operational mode shall not be made unless the conditions of the limiting condition for operation are met without reservation. Provide for the ability to establish an alternate hydrogen sampling capability should a hydrogen analyzer become inoperable. In addition, the word monitor has been replaced by analyzer for Unit 2.

Supplemental Information Determination of containment hydrogen concentration during post-LOCA conditions is a required safety function. However, should a hydrogen analyzer become inoperable, there are other means available to determine the hydrogen concentration inside containment following an accident. As stated in Alabama Power Company's R.G.l.97 Compliance Report dated June 29, 1984, .

information obtained from the containment atmosphere post-accident sampling system can be used as an alternative to the hydrogen analyzers. With one hydrogen analyzer inoperable, the capability exists to measure hydrogen concentration in the containment by means of the redundant hydrogen analyzer and containment atmosphere post-accident sampling system. The required i safety function would continue to be performed and appropriate hydrogen control measures can be taken. Therefore, mode changes should not be prohibited per Specification 3.0.4. This conclusion is consistent with the NRC's position on Specification 3.0.4 as stated in Generic Letter 87-09.

Generic Letter 87-09 states:

" Specification 3.0.4 unduly restricts facility operation when conformance to the Action Requirements provides an acceptable f level of safety for continued operation. For an LC0 that has Action Requirements permitting continued operation for an unlimited period of time, entry into an operational mode or other specified condition of operation should be permitted in accordance with those Action Requirements. This is consistent with NRC's regulatory requirements for an LCO."

Alabama Power Company does not consider this an endorsement of plant operation with inoperable equipment; moreover, if appropriate provisions ,

are provided in the technical specification to ensure an acceptable level of safety for continued opera"on, then entry into an operational node should not be restricted.

I l

BHV:md 9.17

)

J

Attachment 2 l

.)

4 Proposed Changed Pages ,,

)

I l

l 1

Unit 1 Revision ,

l Page B 3/4 6-4 Replace l 1

l Unit 2 Revision Page B 3/4 6-4 Replace l

4 I

____ _ ______- - -