L-99-017, Forwards Responses to NRC RAI Questions for Chapters 3.1, 3.2,3.5,3.7 & 3.9 of Ts.Attached Pages Include Proposed Revs Previously Submitted LAR to Rais,Grouped by Chapters & RAI Numbers
| ML20206G994 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 04/30/1999 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20206G998 | List: |
| References | |
| NEL-99-0176, NEL-99-176, NUDOCS 9905110008 | |
| Download: ML20206G994 (35) | |
Text
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Dave Morey.
S uth:rn N1cle:r Vice Pre %nt Op: rating Company,Inc.
Farley Project Post Office Box 1295 Birmingham, Alabama ' 5201 s
Tel 205.992.5131 SOUTHERN
. April 30, 1999 COMPANY Energy ro Serve YourWorld" Docket Nos.:
50-348 NEI 994176 50-364 U. S. Nuclear Regulatory Commission A'lTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Response to Request for Additional Information Related to Conversion to the Improved Technical Specifications Chaoters 3.1. 3.2. 3.5. 3.7. and 3.9 Ladies and Gentlemen:
By letters dated March 12,1998 and April 24,1998, Southern Nuclear Operating Company (SNC) submitted the Farley Nuclear Plant (FNP) - specific Improved Technical Specifications (ITS) conversion documentation packages in accordance with 10 CFR 50.90. The April 24,1998 letter, which submitted the Clean-Typed copies of the FNP ITS, included an attachment which provided hard copies of changes to the original submittal to correct minor editorial errors and inconsistencies within the package. By letter dated August 20,1998, SNC submitted an electronic copy of the Discussion of Changes (DOCS) and Significant Hazards Evaluations (SHEs) associated with the ITS conversion. Included with that letter were hard copies of changes to the original submittal to correct additional minor editorial errors and inconsistencies within the package. By letter dated November 20,1998, SNC submitted responses to Requests for Additional Information (RAIs) for Chapters 3.6 and 5.0. Included with that letter were hard copics of changes to the original submittal to reflect the SNC responses to the RAI. By letter dated February 20,1999, SNC submitted responses to a RAI for Chapter 3.4. Included with that letter were hard copies of changes to the original submittal to reflect the SNC responses to the RAI. NRC E-mail dated December 14,1998 requested SNC provide additional information for Chapter 3.9. NRC E-mail dated December 22,1998, requested SNC provide additional information for Chapters 3.1 and 3.2. NRC E-mails dated January 29,1999 and March 3,1999 requested SNC provide additional information for Chapters 3.7 ar'd 3.5 respectively.
Attachment I provides the SNC responses to the NRC RAI questions for Chapters 3.1,3.2,3.5, 3.7 and 3.9. Meetings were held with the NRC on April 19-20,1999 to discuss the outstanding RAI questions. During those meetings, the Staff stated that it was not necessary to provide mark-ups of the Current Technical Specifications (CTS) in responses to RAIs. Therefore, the attached pages do not always include CTS mark-ups. Attachmmt IIincludes proposed revisions to the previously submitted license amendment request related to these RAls, grouped by Chapter and RAI number. Attachment III provides further revisions made to address editorial clamges, g
omissions, and inconsistencies in the package identified after the original submittal.
t 9905110008 990430
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PDR ADOCK 05000348 P
1 Page 2 U. S. Nuclear Regulatory Commission In response to these RAIs, some changes to the SHEs were required. As denoted in 10 CFR 50.92(c), SNC has determined the proposed changes to the FNP TS do not involve a significant hazards consideration. The revised SHEs are included in Attachment II. 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. Williamson, the Alabama State Designee, in accordance with 10 CFR 50.91(b)(i).
i Clean-typed ccpies of the affected ITS pages are not included. A complete clean-typed copy of the FNP ITS will be re-submitted at the end of the NRC review process.
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 Company and that, to the best of his knowledge and belief, the facts set forth in this letter and attachments are true.
If there are any questions, please advise.
Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY Dave Morcy Sworn to andsubscribed before this5 dayof 1999 Y']/axtdou 6W V
Notary Public YOW!
@ l, Ml My Commission Erpires:
WAS/maf: itsrai_4. doc Attachments:
I.
SNC Response to NRC Request for Additional Information Related to Conversion to the Improved Technical Specifications - Chapters 3.1, 3.2, 3.5, 3.7, and 3.9 II.
SNC Response to NRC Request for Additional Information Related to Conversion to the Improved Technical Specifications Chapters 3.1,3.2,3.5,3.7, and 3.9 - Associated Package Changes Grouped by Chapter and RAI Number III.
SNC Identified Editorial Changes - Associated Package Changes cc:
See next page.
Page 3 U. S. Nuclear Regulatory Commission cc:
Southem Nuclear Operatina Con $nany Mr. L. M. Stinson, General Manager - Farley U. S. Nuclear Reaulatory Commission. Washinnton. D. C.
Mr. J. L Zimmerman, Licensing Project Manager - Farley U. S. Nuclear Reaulatory Commission. Reaion II Mr. L. A. Reyes, Regional Administrator Mr. T. P. Johnson, Senior Resident Inspector - Farley Alabama Deoartment of Public Health Dr. D. E. Williamson, State Health Officer l
l ATTACHMENTI SNC Response to NRC Request for Additions!Information Related to Conversion to the Improved Technical Specifications Chapters 3.1,3.2,3.5,3.7, and 3.9 1
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$NC Response to NRC Request for Addit %:/ luformation Related to Conversion to the Improved Technical L,,tcifications - Chapter 3.1 4
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. SNC Response t2 NRC RAI Related to Chrpter 3.1 j
Section 3.1 - Resetivity Control Systems ITS 3.1.1 - SHITFDOWN MARGIN (SDM)
NRC Question:
3.1.1-1 ffS Bases B 3.1.1, page B 3.1-2 Margin Note Margin contains note,"Uprate impacts?" Comment: What is the meaning of this note? Does it have any effect on the Bases?
SNC Response:
His is an internal note that was inadvertently left on the submittal. During the creation of the Farley ITS, a parallel effort was in progress to gain NRC approval to uprate the thermal power of both Farley units. As part of the review of the ITS conve sion documentation, care was taken to ensure that impacts from the uprate effort were incorporated into the ITS submittal. As this
- review is complete, this note has no impact on the bases.
NRC Question:
3.1.1-2 ITS Bases B 3.1.1, page B 3.1-2 PSE Addition /EInput at top ofpage PSE addition states that,"An operating procedure (Ref 5) assumes sufficient operator action time for the mitigation of an uncontrolled boron dilution event (Ref 3) in MODE 5. His procedure is independent of SDM and uses the RHR system flowrate, and the calculated critical boron concentration." Comment: His paragraph appears to say that either CTS 3/4.1.2, " Boron Water Sources - Shutdown," should not be relocated, or that ITS 3.9.1, " Boron Concentration,"
should also be applicablein MODE 5.
SNC Response:
De above question quoted the note incorrectly in that the word " assures" in the first sentence was
. replaced by the word " assumes." The correct note states "An operating procedure (Ref 5) assures suf6cient operator action time for the mitigation of an uncontrolled boron dilution event (Ref 3) in MODE 5." This note is included in the Bases to reference plant controls to prevent approach to criticality due to a boron dilution event while on RHR. The controls require a minimum RCS boron concentration based on cycle burnup and bounds Mode 5 operation for all ranges of RHR
. flow to ensure SDM is maintained during the boron dilution event. Durmg Mode 5, the reactor vessel head is in place and separation exists between the RCS and the transfer canal. In addition, the transfer canal may be dry during Mode 5. Therefore, ITS 3.9.1 is not appropriate for Mode 5.
ITS specification 3.1.1 addresses the required shutdown margin for Modes Page 1 of 6 N
SNC Resp:sse ts NRC RAI Rel:ted to Chapter 3.1
. 2,3,4, and 5. Mode 6 boron concentration is specified by ITS 3.9.1.' He specified boron concentration is adequate to ensure a Keff of 0.95 or less. Herefore, controls to ensure adequate SDM are in place for all plant modes. The boron concentration required for RHR operation must be met prior to placing RHR in service. Therefore, no need exists for CfS 3/4.1.2, " Boron Water Sources - Shutdown" and the relocation is correct. SNC intends to leave the LCO as currently submitted.
kTS 3.1.3 - Moderator Temnerature Coefficient (MTC)
NRC Question:
3.1.3-1 ITS 3.1.3 ModeratorTemperature Coefficient (MTC)
JFD 2 He STS utilizes a graph to depict MTC vs RTP. The CTS and ITS present this information in the LCO without the use of a graph. Comment: A graph is easier for the operator to visualize and determine the value of MTC on the ramp part of the function; consider using a graph.
SNC Response:
He limit, as stated in the ITS, is consistent with the current statements in the CTS. Personnel are familiar with the current statement of the limit. SNC feels that a graph depicting the limit is more appropriately included in plant documents other than ITS. Therefore, SNC intends to leave the LCO as currently submitted.
NRC Question:
3.1.3 2 ITS 3.1.3 ModeratorTemperature Coefficient (MTC)
JFD 3 The LCO defines BOL as "beginning of cycle life," and EOL as "end of cycle life." The Bases Background defines BOL as "beginning oflife," and EOL as "end oflife." Comment: Use a consistent definition for the acronyms.
SNC Response:
ne Bases has been revised to be consistent with the statement of the LCO.
NRC Question:
3.1.3-3 ITS 3.1.3 ModeratorTemperature Coefficient (MTC)
JFD 3 & JFD 4 He LCO defines the MTC limits in terms of BOL, EOL, and maximum upper limit. The Condition statements are only in terms of BOL and EOL limits; there is no Condition for not within the maximum upper limit. Comment: ne STS presentation of Condition statements in terms of upper and lower limits appears to be better. As it is currently written, if the maximum upper limit is exceeded an LCO 3.0.3 entry would be required. Recommend revising TS 3.1.3.
Page 2 of 6
w SNC Resp:nse ts NRC RAI Relited to Chapter 3.1 SNC Response:
He maximum upper limit bounds the maximum allowed beginning of cycle life (BOL) MTC l
value. %e maximum allowed BOL MTC value may be less than or equal to the maximum upper limit but not more than the maximum upper limit. He maximum allowed BOL value is cycle specific and is specified in the COLR. STS Bases refer to the upper limit as the "BOC positive limit" and the lower limit as the "EOC negative limit." In the ITS, the FNP specific term "BOL" was substituted for "BOC" and "EOL" for "EOC." SNC does not agree that adopting the STS terminology provides clarification, and a change to this terminology would deviate from commonly used FNP terms. Herefore, SNC intends to leave the LCO as currently submitted.
NRC Question:
3:1.3-4.lTS 3.1.3 Moderator Temperature CoefHelent (MTC)
JFD 5 j
l STS Required Action B.1, placing the plant in Mode 2 with K.,< l.0, places the plant outside the Mode of Applicability. The ITS Required Action B.1, placing the plant in Mode 3 is not consistent with the Mode of Applicability.- Comment: Be consistent in entering and exiting the l
Mode of Applicability; recommend either changing the Applicability or the Required Action.
SNC Response:
Mode 2 with Keffless than 1.0 is not a point that is easily discernable to operations personnel.
Maintaining this condition would very likely involve leaving the control rods withdrawn to an l
intermediate position. It is more practical to define a condition that is well understood by operations personnel. Since placing the unit in mode 3 (vice mode 2 with Keffless than 1.0) is consistent with CTS, is conservative, does not place a thermal or hydraulic transient on the unit, and is a point more readily discernable, SNC intends to leave the LCO as currently submitted.
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NRC Question:
3.1.3-5 ITS 3.1.3 Moderator Temperature CoefHelent (MTC)
DOC 5-LA The DOC 5-LA deletes a special reporting requirement the licensee must make to the NRC when MTC is more positive than the beginning-of-life (BOL) limit. It is deleted since similar reporting requirements are required by (already exist in) 10 CFR 50.72 and 10 CFR 50.73. This is also reflected in Attachment 6 to the SNC conversion submittal letter. The SNC conversion submittal letter Attachment 1, the reviewers guide page Al-4, identifies LA requirements as those that are l
being relocated to the Bases, TRM, FSAR, or other licensee controlled document. His description does not include requirements that already exist in regulations.
Comment: Revise the submittal letter Attachment I to include this type of change in the l
definition of LA changes.
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SNC Resp:nse in NRC RAI ReIIted to Chrpter 3.1 SNC Response:
Attachment I to the SNC Farley ITS conversion submittal letter dated March 12,1998 has been revised to reflect this additional use for the change category LA.
ITS 3.1.4-Rod Group Alinnment Limits NRC Question 3.1.4-1 ITS Bases B 3.1.4,'page B 3.1-26 Margm Note Margin contains note,"FNP specific." Comment: What is the meaning of this note? Does it have any effect on the Bases?
SNC Respouse:
This is an internal note that was inadvertently left on the submittal. During the creation of the Farley ITS, care was taken to ensure that Bases were reviewed to verify that they were applicable to Farley or revised to make them FNP specific. As this review is complete, this note has no impact on the bases.
NRC Question:
3.1.4-2 ITS Bases B 3.1.4, page B 3.1-27 Margin Note Margin contains notes, "FNP specific" (twice), and " Provide FSAR Refif possible."
Comment: What are the meaning of these notes? Do they have any effect on the Bases?
SNC Response:
1 These are internal notes that were inadvertently left on the submittal. During the creation of the i
Farley ITS, care was taken to ensure that Bases were reviewed to verify that they were applicable' to Farley or revised to make them FNP specific. As this review is complete, these notes have no impact on the bases.
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SNC Respoise to NRC RAI Rel:ted ts Chhpter 3.1 ITS 3.1.7 - Rod Position Indication -
i NRC Question:
3.1.7-1 ITS 3.1.7 Rod Position Indication (RPI)
JFD 4 & JFD 1-STS and CTS allow one inoperable RPI. h ITS allows one or more RPI to be inoperable with the same required actions as one inoperable RPI. h STS permits 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (Required Action B.1) to verify rod position after 24 steps of rod movement, while the CTS has an immediate requirement. De ITS grants 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for this verification. Comment: The STS has recently been revised to allow more than one inoperable RPI, based upon approved similar Callaway and Wolf Creek RPI TS. The allowed Completion Time for verifying rod position after rod movement should bc.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Recommend revising ITS 3.1.7s on RPI, accordingly.
SNC Response:
The ITS requires that action be taken to initiate verification of rod position immediately as opposed to allowing a delay. His is consistent with the CTS and ensures that actions are taken in an expeditious manner. h allowance of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to complete the rod position verification ensures that appropriately trained engineering personnel are avadable and that the incore system is placed in service and sufficient analysis time is permitted. Engineering personnel are normally at the station only during the normal daytime workweek. brefore, a delay in response may occur. The incore system must be placed in service, energized, and warmed up prior to use.
Maintenance support is required to install tecporary recorders for the flux traces. Here could also be cases where incore thimble paths are blocked or detectors are failed, necessitating use of alternate mapping stategies and significantly increasing the time required to verify the affected RCCA position (s). SNC believes that 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> will not provide adequate time to perform this surveillance under certain circumstances, brefore, SNC intends to leave the LCO as currently submitted.
NRC Question:
3.1.7-2 ITS B 3.1.7 Rod Position Indication (RPI), Bases Page B 3.1-47 Margin Note
. Margin contains notes, "DRPI OPS-52201F 7/93" and "W TECH MANUAL U-260378."
' Comment: What are the meaning of these notes? Should they be included in the references?
SNC Response:
These are internal notes that were included as a historical reference on the markups to document the review of the Bases. They are references to documentation which describe the design of the DRPI system for Farley. During the creation of the Farley ITS, care was taken to ensure that Bases were reviewed to verify that they were applicable to Farley or revised to make them FNP specific. As this review is complete, these notes have no impact on the bases. They are not I
necessary as references for the Bases l
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SNC Resp:nse to NRC RAI Related to iChrpter 3.1 Section 3.1 Bases - Reactivity Control Systems - General Ouestion NRC Question:
B 3.1-1 STS MARKUP OF BASES SECTIONS B 3.1.1, B 3.1.3, B 3.1.4, B 3.1.5, B 3.1.6 Pages B 3.1-2, B 3.1-3, B 3.1-19, B 3.1-26, B 3.1-35, B 3.1-41 Margins contain note that appear to be procedure numbers. Comment: What is the purpose of these numbers in the submittal?
SNC Response:
These are internal notes that were included as a historical reference on the markups to document the review of the Bases. They are references to calculations related to safety analyses for Farley.
During the creation of the Farley ITS, care was taken to ensure that Bases were reviewed to verify that they were applicable to Farley or revised to nuke them FNP specific. As this review is complete, these notes have no impact on the bases. They are not necessary as references for the Bases.
Addendum NRC Question:
3.1.2-1 ffS 3.1.2 Core Reactivity Applicability TSTF-141 "Ihe ITS incorporated proposed TSTF-141. Comment: In the review and approval process for TSTF-141 the WOG determined that TSTF-141 was not applicable to Westinghouse plants. 'Ibc safety analysis does not permit the exclusion of MODE 2 from the applicability. 'Iherefore, TSTF-141 needs to be removed from the ITS.
SNC Response:
At the time SNC submitted the ITS conversion package for Farley, TSTF-141, Rev. O had been approved by the NRC for use in Westinghouse plants. 'Ihe subsequent revision deleted the applicability of the TSTF to the Westinghouse NUREG (1431). In discussions with Westinghouse personnel it was confirmed that the changes made by the TSTF are not applicable to Farley. Therefore, TSTF-14I has been deleted from the FNP ITS.
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i SNC Response to NRC Request for AdditionalInformation Related to j
Conversion to the Improved Technical Specifications - Chapter 3.2 j
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SNC Resp =se ts NRC RAI Reinted ta Chnpter 3.2 Section 3.2 - Power Distribution Limits ITS 3.2.1 - Heat Flux Hot Channel Factor (FO(Z))
NRC Question:
l 3.2.1-1 ITS 3.2.1 Heat Flux Hot Channel Factor, FoZ Method ITS Presentation & Terminology DOC 2-A, DOC 9-A, and DOC 11-A JFD 1 He ITS presents the TS limits in terms of steady state and transients limits. The DOC justifies this change by stating it is in accordance with the STS.
Comment: Neither the CTS nor the STS refer to steady state and transients limits, as indicated by SNC's inclusion of this change to the list of beyond scope changes. Correct the DOC and provide dinussion and justification for presenting the TS limits in terms of steady state and transients limits.
SNC Response:
SNC disagrees that the DOC is incorrect. It is our opinion dat the change is adequately dL=leH andjustified. In addition, the above statement "The DOCjustifies this change by stating it is in accordance with the STS' is incorrect. DOC 2-A describes the changes as " consistent with the STS." He STS and the FNP ITS are consistent in (nat they both specify two limits for Fo(Z).
However, the terminology used in STS for the tnnsient and steady states limits (Fo*(Z) and C
Fo (Z), respectively) is not used at FNP. Intrcduction of this terminology would require changes i
to plant surveillance procedures and create r.nced for additional personnel training. The STS 1
terminology is also inconsistent with the terminology used in the INCORE computer code
(" steady state" and " transient"). In addition, SNC utilizes a common core analysis group for l
I support of both Farley and Vogtle (where this change in terminology is accepted and in use in the TS). Utilizing different terminology at Vogtle as compared to Farley would introduce needless 1
confusion. It is felt that the use of the terminology " steady state" and " transient" to replace the l
STS terminology is fully acceptable and is an administrative change. Therefore, SNC intends to leave the LCO as currently submitted.'
NRC Question:
3.2.12 ITS 3.2.1 Heat Flux Hot Channel Factor, FoZ Method DOC 10-L -
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' hours. Comment: The correct CT requirement, as a result of TSTF-99, is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Correct DOC 10-L.-
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m SNC Resptase to NRC RAI Rel:ted to Chapter 3.2 SNC Response:
This error was discovered by SNC during the review of the package submitted on March 12, 1998, while preparing the electronic copy of the DOCS and the SHEs. He electronic copy of the DOCS and the SHEs was submitted to the NRC by SNC letter dated August 20,1998. He third paragraph of that letter stated the following: "During SNC review of the submitted package for the creation of this electronic copy of the DOCS and the SHEs, some changes were made to correct minor editorial errors and inconsistencies within the package (e.g., punctuation, capitalization, reference, or grammatical errors). Rese changes have not affected the conclusions of the associated SHEs. Therefore, the previously submitted SHEs still apply. %c previously submitted pages should be replaced with the corrected DOC pages included in the attachment to correct minor errors in the package." He attachment to that letter included the above requested correction, which was reflected on the CD.
NRC Question:
3.2.1-3 ITS 3.2.1 Heat Flux Hot Channel Factor, FoZ Method JFD 2 ITS Bases B 3.2.1, page B 3.2-16 PSC change He ITS changes the STS peaking factor SR frequencies from " prior to Hermal Power exceeding 75%" to "aAer achieving equilibrium conditions at any power level > 50%," and the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> cap on performing the SRs has been deleted. His is based upon CLB/ CTS. He rationale for this change discusses why the SRs should be performed above 50% RTP but does not address the why reason for doing them prior to 75% RTP is unimportant; the STS Bases discussion is merely deleted, ne 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> frequency deletions arejustified by other existing TS requirements.
Comment: De differences from the STS are not adequatelyjustified.
SNC Response:
SNC has reviewed the plant practice for performance of surveillance for Fo(Z). He surveillance is normally performed prior to 75% power following a refueling outage. SNC agrees to revise ITS 3.2.1 to reflect this approach. The appropriate changes are attached.
ITS 3.2.2 - Nuclear Enthalov Rise Hot Channel Factor (FMI-D
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NRC Question:
'3.2.2-1 ITS 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor, Fm" DOC 8-A DOC 8-A adds the STS requirement to restore Fm" to within limits within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
Comment: SNC added this requirement because it is in the STS. His is an unnecessary, superfluous requirement, similar to requirements that have been removed from other TS.
Consider deleting this requirement and submitting a TSTF to correct the STS.
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SNC Respinse is NRC RAI Retrted to Ch:pter 3.2 i
SNC Response:
His statement was added to the CTS during a previous amendment. His was done due to confusion as to the permissibility of exiting the Required Action if QPTR were restored to limits during the Completion Time. In addition, the statement is consistent with both the CTS and STS.
Herefore, SNC intends to leave the LCO as currently submitted.
ITS 3.2.4 - Ouadrant Power Tilt Ratio (OPTR)
NRC Question:
3.2.4-1 ITS 3.2.4 Quadrant Power Tilt Ratio (QPTR)
DOC 4a-A and JFD 1 he CTS and STS Required Action A.1 wording has been revised from " Reduce... from" to
" Limit... below". His is done to allow entry into LCO applicability with QPTR in excess of 1.02. Comment: This rewording alone would not permit entry into LCO applicability. An explicit LCO 3.0.4 exception would be reqaired in either case. Change from STS is unnecessary.
SNC Response:
f SNC agrees that the difference in the wording from the STS does not allow entry into applicability. However, STS and ITS 3.0.4 allow entry into the applicability "when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition for an unhmited period of time." He ITS Required Actions associated with QPTR being above the limit meet this criteria; therefore, no LCO 3.0.4 exception is required, ne change in wording for Action A.1 reduces confusion as to the intent of the specification.
Some people queried indicated confusion as to the number of power reductions required using the STS wording. SNC believes that the wording in the ITS required Action A.1 should be retained as submitted, and the DOC and Justification wording revised to delete implied allowance into applicability due to the wording change. He proposed changes to DOC 4a-A and JFD 1 are attached.
NRC Question:
3.2,4-2 ITS 3.2.4 Quadrant Power Tilt Ratio (QPTR)
DOC 6-L and JFD 3 ITS provides time to achieve " equilibrium conditions" prior to performing peaking factor surveillances; time that is not provided by either the CTS or STS. Comment: What is the status of WOG-95? He CTS allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to perform a flux map, versus the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> the STS allows to perform peaking factor SRs. The 24-hour CT was thought to be sufficient; what would SNC consider an appropnate CT?
Page 3 of 5
SNC Resp:nse to NRC RAI Related to Chrpter 3.2 SNC Response:
WOG-95 became TSTF-241, Rev. 4, which has now been approved by the NRC. SNC believes that the appropriate Completion Time for the Action is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after equilibrium conditions are achieved. His is considered to be sufficient time to perform the peaking factor SRs. His time,
- including the allowance to achieve equilibrium conditions, is consistent with the STS as modified by TSTF-241, Rev. 4.
NRC Question:
3.2.4-3 ITS 3.2.4 Quadrant Power Tilt Ratio (QPTR)
JFD5 ITS changes required action to " Calibrate excore detectors..." to " Normalize excore detectors...".
This change is proposed by WOG-95. Comment: What is status of WOG-95?
SNC Response:
WOG-95 became TSTF-241, Rev. 4, of which has now been approved by the NRC.
NRC Question:
1 3.2.4-4 ITS 3.2.4 Quadrant Power Tilt Ratio (QPTR)
JFD 7 ITS rewords SR 3.2.4.2 from " Verify QPTR..." to " Confirm that the normalized symmetric power distribution is consistent with QPTR." Comment: Submit TSTF traveler to change STS.
SNC Response:
As described in DOC 11-A, DOC 12-LA, and JFD #7, SR 3.2.4.2 and the associated Bases are revised consistent with the FNP CTS. Therefore, this is a plant specific change to the STS to reflect the CTS terminology and requirements and the methodology employed by the R4 CORE code for Farley. He Farley submittal may be reviewed on that basis without requiring a generic -
change.
Section 3.2 Bases - Power Distribution Limits - General Ouestion 4
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NRC Question:
B 3.2-1 STS MARKUP OF BASES SECTIONS B 3.2.1, B 3.2.2, B 3.2.3, B 3.2.4 Pages B 3.2-12, B 3.2-13, B 3.2-17, B 3.2-22, B 3.2-23, B 3.2-24, B 3.2-43, and B 3.2-44 i
l Margins contain notes that appear to be procedure numbers and references to analyses.
Comment: What are the purposes of these numbers and references in the submittal?
Page 4 of 5
r - --
l SNC Resp:nse to NRC RAI Reitted ts Chapter 3.2 I
SNC Response:
These are internal notes that were included as a historical reference on the markups to document the review of the Bases. Hey are references to calculations related to safety analyses for Farley.
l During the creation of the Farley ITS, care was taken to ensure that Bases were reviewed to verify l
that they were applicable to Farley or revised to make them FNP specific. As this review is complete, these notes have no impact on the Bases.
NRC Question:
E 3.2-2 Bases B 3.2.3, page B 3.2-39 Margin Note Margin contains note to " Verify Ref. 2." Comment: Has Ref. 2 been verified?
SNC Response:
Yes. He reference was revised to reflect the correct revision applicable to Farley, as shown in the markup on page B 3.2-41.
i 1
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Page 5 of 5
c-SNC Response to NRC Request for Additional Information Related to Conversion to the Improved Technical Specifications - Chapter 3.5 l
m SNC Resprnse to NRC RAI Rel:ted to Chrpter 3.5 3.5.1 Accumulators NRC Question:
3.5.1-1 CTS 3.5.1, Applicability and Footnote
- DOC 12-M ITS 3.5.1 ApplicabilityNote JD 1 i
De Applicability of CTS 3.5.1 is Modes 1,2, and 3 with pressurizer pressure above the P-11
- setpoint (2000 psig). b ITS 3.5.1 Applicability is revised to Modes 1,2, and 3, with RCS pressure > 1000 psig. In addition, a Note has been added to the Applicability for ITS 3.5.1 which states that, in Mode 3, above 1000 psig, the accumulators may be isolated for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for the purpose ofisolation valve testing per SR 3.4.14.1. DOC 6-M and JD 1 both state that the Note is necessitated by the adoption of the 1000 psig applicability limit.
Comment: h staffdoes not recall seeing the exception outlined in the ITS Applicability Note proposed in any previous amendment requests for conversions to the Westinghouse STS. Please describe the plant-specific conditions and methods for testing the accumulator isolation valves in accordance with SR 3.4.14.1 that require the proposed exception. What is unique about Farley's testing of these isolation valves that requires an exception to the Applicability that no other Westinghouse licensee has requested to date?
If you conclude and the staff agrees, based on the additional information you provide, that the Note is necessary, the staff suggests that it be revised to read, "In Mode 3, with pressurizer pressure > 1000 psig, the accumulators may be isolated for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to perform pressure isolation valve testing per SR 3.4.14.1." The staff suggests this revision of the Note to: (1) clarify what is meant by "above 1000 psig," and (2) make the wording of the note consistent with a similar note in ITS 3.5.2.
SNC Response:
He valves nearer the RCS (inboard) are tested by using RCS pressure to seat the valves. Those nearer the accumulators (outboard) are tested by using one of the accumulators as a pressure source via si test piping arrangement. Testing is normally scheduled for performance at about 1600 psig RCS pressure following outages.
Page 1 of 7
7 SNC Resp:nse to NRC RAI Rel:ted to Chapter 3.5 Farley accumulators discharge check valves are 12 inches in diameter, have a vertical metal to metal seating arrangement and are manufactured by Copes Vulcan. Accumulator isolation valve testing at FNP has shown these valves to require a relatively high differential pressure to consistently fully seat.
Operational considerations require that valve leakage be extremely low to prevent accumulator level increase and boron dilution. He plant design is such that accumulator level and boron concentration change control is very limited. Attempts to test these valves at less than 1000 psi RCS pressure have had mixed results while testing at higher pressures has typically been more successful. To perform this test to the level required for operational considerations the exception is needed. Although a formal survey of other utilitics has not been done, indications are that the model of accumulator discharge check valve used at FNP is not commonly used for this application.
The wording of the note has been changed to be consistent with the intent of the Staff suggestion.
The references to pressurizer pressure in LCO 3.5.1 are revised to indicate RCS pressure. His deviation to the STS is required because the FNP pressurizer pressure narrow range instrumentation range is 1700 to 2500 psig. The RCS wide-range 0 to 3000 psig pressure instruments are used for monitoring system pressure below approximately 1700 psig. Tbc appropriate changes to the package are attached.
. NRC Question:
3.5.1 2 CTS 4.5.1.1.b DOC 13-A ITS SR 3.5.1.4 JD 2 De wording of the second Frequency for STS SR 3.5.1.4 was revised from, "Once within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after each solution volume increase of 2 [ ]% ofindicated level..." to "Once within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />
- after each solution volume increase of 12% oflevel, indicated....." The justification in JD 2 states that this change was made to clarify that it is speaking of an indicated level change of 12%
vs. a change of 12% of the previously indicated level. In addition, you revised the STS Bases for this SR. He STS Bases stated, " Sampling the affected accumulator within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after a 1%
volume increase...." Your proposed revision states, " Sampling the affected accumulator within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after a 12% level, indicated, increase....
Comment: He staff believes that the wording of this SR in the STS is clear. You have indicated that you believe the proposed ITS wording is clearer to your operators. If you do not want to adopt the STS wording of this SR and Bases, then the staff believes that additional explanation in the Bases is needed to clearly define the increase in level that is equivalent to a 1%
volume increase. He staff does not believe the meaning of a "12% !cvel, indicated, increase" is immediately apparent. Please provide additional explanation of this phrase in the Bases for SR 3.5.1.1 if you do not choose to adopt the STS wording.
SNC Response:
The current wording could be interpreted to mean a percentage increase of the solution volume.
Therefore, wording is added to the Bases to indicate that a 12% indicated level increase is approximately equivalent to a 1% tank volume increase. The appropriate change to the ITS Bases submittalis attached.
Page 2 of 7
{
SNC Resp =se in NRC RAI Rel ted to Chrpter 3.5 3.5.2 ECCS - Operating NRC Question:
3.5.2-1 CTS 4.5.2.a, Footnote
- DOC 9-A ITS SR 3.5.2.1 Note JD 4 Footnote
- to CTS 4.5.2.a has been translated into a Note to ITS SR 3.5.2.1 which reads, "For valves 8132A and 8132B only, this SR is only required to be performed when Charging Pump A is inoperable. This surveillance is applicable to valves 8884,8886, and 8889 at all times while in the Applicability of LCO 3.5.2.
Comment: The staff requests that the second sentence of this Note be deleted. It is superfluous since SR 3.0.1 requires that SRs be met during the Modes or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. It is contrary to the format of the STS to restate such requirements in Notes. In addition, the staffrequests that the first sentence be revised to read, "Only required to be performed for valves 8132A and 8132B when Charging Pump A is inopemble," to be consistent with similar notes in the STS (e.g., SR 3.4.3.1, 3.4.16.2, 3.7.1.1).
SNC Response:
SNC y,rees that the second sentence is redundant and it has been deleted. The suggested change has been made to the first sentence. 'Ihe appropriate changes to the submittal are =~M NRC Question:
3.5.2-2 CTS 4.5.2.e.2 and 4.5.2.h DOC 15-LA ITS SR 3.5.2.6 '
CTS 4.5.2.h requires verification that the meclianical stops on low head safety injection valves RHR-HV 603 A/B are intact prior to entry into Mode 3 from Mode 4. You have proposed to move this requirement to the TRM in the ITS conversion. In addition, a requirement has been added in ITS SR 3.5.2.6 to verify the correct position for the position stops on valves RHR-HV 603 A/B every 18 months. However, the Bases for ITS SR 3.5.2.6 state that the required verification for the RHR valves,603 A/B, consists of confirming the stops are intact. Both of these changes are described in DOC 15-LA.
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SNC Resp:nse is NRC RAI Reisted ta Chrpter 3.5 Comment: It appears that the Bases for SR 3.5.2.6 modify the requirement stated in the actual SR for the RHR valves. The SR states that the requirement is to verify the position stops are in the correct position. De Bases state that the requirement is to verify the stops are intact. The Bases sanagt modify the requirements of the specification. Please explain the difference between verifying correct position of the stops and verifying the stops are intact. The ITS needs to be modified to either (1) accept the requirement in SR 3.5.2.6 to ver fy correct position of the RHR stops and modify the Bases accordingly; or (2) write a separate surveillance requirement for the RHR position stops to reflect the CTS requirements. Ifyou choose to accept the requirement in SR 3.5.2.6 to verify correct position of the RHR stops, then this change should be recategorized as a separate more restrictive change and should not bejustified unde: DOC 15-LA.
SNC Response:
SNC agrees to accept the requirement in SR 3.5.2.6 to verify correct position of the RHR stops and modify the Bases accordingly.
NRC Question:
3.5.2-3 CTS 4.5.2.i DOC 16-LA ITS 3.5.2 Bases -LCO Section CTS 4.5.2.i requires performance of a flow balance test following completion of modifications to the ECCS subsystems that alter the subsystem flow characteristics and verification of flow rates for the HPSI System of 2.193 gpm for each injection leg and for the LPSI System of 2 3981 gpm total injection. DOC 16-LA states that the specific flows required for the ECC5 subsystems are moved in the TS LCO Bases discussion of an operable ECCS system.
Comment: The markup of the STS Bases for LCO 3.5.2 contains an insert which states, "Each centrifugal charging pump must inject 2 495.6 gpm and each RHR pump must inject 2 3402 gym.
These flow numbers do not appear consistent with the CTS numbers. Please explain the basis of the numbers in the proposed ITS Bases and how they relate to the flow numbers in the CfS.
SNC Response:
The numbers provided in the STS Bases submittal are for minimum ECCS injection assuming the RCS is experiencing'a LOCA and is at 40 psig and are for information. Additional information 3
has been added to the Bases to provide clarification. DOC 16-LA incorrectly identified that the j
CTS flow numbers were moved to the Bases. The flow numbers were moved to the TRM along 1
with the associated surveillance test requirement. The submittal has been revised to reflect this I
correction.
Page 4 of 7 I
SNC Resp 2:se to NRC RAI Rel:ted to Chipter 3,5 3.5.3 ECCS - Shutdown i
NRC Question:
3.5.3-1 CTS 3.5.3, Action a DOC 6-A ITS 3.5.3, Actions C & D JD 3 CTS 3.5.3, Action a, requhus that, with no ECCS subsystem operable because of the inoperability of the centrifugal charging subsystem, at least one ECCS subsystem be restored to operable status within I hour or the unit be placed in Cold Shutdown within the next 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> if at least one RHR loop is operable. In the ITS, these requhements are transferred to Actions C & D of LCO 3.5.3.
Action C requires that, with the required ECCS centrifugal charging subsystem inoperable, the subsystem be restored to operable status in I hour. Action D is entered when the Required Action and associated Completion Time of Condition C are not met. Required Action D.1 requires placing the unit in Mode 5 in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The requirement in CTS 3.5.3, Action a, concerning at least one operable RHR loop is transferred to a Note to the Completion Time for Required Action
. D.1 which states, "If this Condition is entered with no RHR subsystem OPERABLE, the Completion Time does not begin until one RHR subsystem is capable of supporting cooldown to and operation in Mode 5."
Comment: The proposed use of this Note to the Completion Time for Required Action D.1 does not appear to be consistent with the format of Notes in the STS. The staff suggests that the Note be deleted and Condition D be modified to read:
Required Action and associated Completion Thne of Condition B or C not met.
AND i
At least one RHR subsystem OPERABLE.
The staff believes that this is more consistent with the wording of the CTS Action and more consistent with :he STS format. 'Ihe Bases should be revised accordingly, b staff suggests that wording similar to the last paragraph in the Bases for Action A.1 could be added to the discussion
. for Action D.1.
SNC Response:
SNC agrees that the proposed revision to condition D is appropriate and has modified the submittal accordingly.
Page 5 of 7
F; SNC Resps:se is NRC RAI Rel:ted t2 Chrpter 3.5 NRC Question:
3.5.3-2 CTS 3.5.3, Actions DOC 4a-L -
ITS 3.5.3, Action B JD 2 You have proposed adding a new Action to ITS 3.5.3 that is not contained in your CTS. ffS 3.5.3, Action B, provides actions for the condition of the required ECCS centrifugal charging subsystem inoperable and at least 100% of the ECCS flow equivalent to a single operable ECCS train available. Required Action B.1 requires restoring the subsystem to operable status in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This change is justified under DOC 4a-L.
?-
Comment: His change has been identified as a beyond scope issue and is being reviewed by the NRC technical staff. Any questions concerning this specific change will be forwarded separately.
No action is required at this time.
SNC Response:
)
i SNC acknowledges that this change is under review by the NRC tecimical staff.
3.5.4 Refueling Water Storage Tank (RWST)
No Comments.
3.5.5 SealInjection Flow NRC Question:
3.5.5-1 CTS 3.4.7.2.c DOCS 1-LA & 4-M ITS Bases Figure B 3.5.5-1 JD 1 CTS 3.4.7.2.e requires that RCS Controlled Leakage (scal water flow to the RCP seals) be limited to 31 gpm at an RCS pressure of 2235 psig 20 psig. This requirement is transferred to the ITS as a limit on RCP seal injection flow in LCO 3.5.5. ITS LCO 3.5.5 requires that RCP seal injection flow be within limits. The limits are located in the Bases for ITS 3.5.5 in Figure B 3.5.5-1.
Comment: ne change from a point value limit on seal injection flow in the CTS to a limit based on Figure B 3.5.5-1 in the ITS has been identified as a beyond scope issue a.nd is being reviewed by the NRC technical staff. Any questions concerning this specific change will be forwarded separately. However, the staffis concerned about the location of the figure, ifit is eventually found acceptable for use in the ITS. The typical STS format for LCOs containing " limits"is that the limits are either directly referenced in the LCO or they are contained in the surveillance requirements. h is not appropriate to locate TS limits in the Bases, since the Bases should not contain actual requirements. In addition, the staff believes that such limits or acceptance criteria Page 6 of 7
SNC Respase to NRC RAI Related to Chrpter 3.,5 are more appropriately controlled in the technical specifications than under the Bases Control Program. Therefore, the staff requests that you revise the ITS to locate the Figure B 3.5.5-1 directly in the specification.
SNC Response:
SNC believes that the location of the graph is appropriate. There are other examples in the STS oflimits not located in the surveillance requirement such as STS SR 3.5.2.4 (ITS SR 3.5.2.3) where the surveillance requirement references the required developed head. 'Ihe actual limit for the required developed head is contained in the IST program. SNC does not believe that this item warrants action. This change to the STS is currently being developed on a generic basis as WOG-137. Maintaining the graph in the Bases is also consistent with the location of this information for Vogtle and therefore maintains consistency within SNC, 3.5.6 ECCS Recirculation Fluid pH Control System No Comments.
1 Page 7 of 7
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SNC Response to NRC Request for Additional Information Related to Conversion to the Improved Technical Specifications - Chapter 3.7
T SNC Respase to NRC RAI Reitted to Chapter 3.7 Section 3.7 - Plant Systems 3.7.1, Main Steam Safety Valves (MSSVs) 3.7.1.1 ITS LCO 3.7.1 i
DOC 4 Land 4aL NRC Comment:
In the licensee's submittal, these changes are identified as a beyond-scope change. 'Ihc licensee should review approved TSTF-235 Rev. I and revise, as appropriate, the ITS and the Bases before review of this issue is pursued as a beyond-scope change.
[
SNC Response:
SNC has adopted TSTF-235, Rev.1, in the Farley ITS. Associated changes to the package are j
- attuhed, i
l 3.7.5, Auxiliary Feedwater (AFW) System l'
3.7.5-1 TTS SR 3.7.5.2 l
DOC 16 L NRC Comment:
The STS contains the same allowed outage time for a single pump as the proposed ITS (72 l
hours). However, the proposed ITS has a 72-hour limit on testing the turbine driven pump while the STS has a 24-hour limit for testing. While writing up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> may be acceptable, what plant-specific reason necessitates waiting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> longer than the STS before testing?
SNC Response:
SNC has adopted the STS notes for SR 3.7.5.2 and SR 3.7.5.4 in the Farley ITS, incorporating an FNP-specific value for steam generator pressure. Associated changes to the package are attached.
l Page1of1
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l SNC Response to NRC Request for Additional Information Related to Conversion to the Improved Technical Specifications - Chapter 3.9 I
I
w SNC Resp =se to NRC RAI Rel:ted ta Ch:pter 3.9 Section 3.9 - Refueline Operations ITS 3.9.1 Boron Concentration -
There are no comments on LCO 3.9.1 ITS 3.9.2 NuclearInstrumentation j
There are no comments on LCO 3.9.2 ITS 3.9.3
- Containment Penetrations e
NRC Question:
1.
CTS 4.9.4 requires deternuning that each required containment building penetration is closed or isolated or capable of being closed by an OPERABLE autcmatic containment purge and exhaust isolation valve within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to the start of and at least once per 7 days during Core Alterations or movement ofirrmaated fuel in the containment building. ITS 3.9.3 does not include the requirement for determining that each required containment building penetration is closed or isolated or capable of being closed by an OPERABLE automatic containment purge and exhaust isolation valve within 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to the start of Core Alterations or movement ofirraAaw fuel in the containment building. The deletion of this CTS requirement is based on the general rules requiring performing the surveillance within 7 days prior to entering the Mode of applicability.
hjustification for changing the surveillance frequency from 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> to 168 houn (7 days) states that there is no significant difference between 100 and 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />. 'Ihc difference is nearly 3 days. While this change is acceptable, change DOC 9 L to discuss why the 7 days is acceptable. Reference is also made to redundancy to the general rules.
Explain what is meant by this statement.
SNC Response:
DOC 9-L for CTS 3/4.9.4 states "Ihe general rules for the use and application of surveillance requirements in the technical specifications (i.e., SR 3.0.4) require the surveillance to be successfully performed and current prior to entering the Mode of applicability." h requirement to perform this surveillance 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to the start of Core Alterations or movement of irradiated fuel in the containment building is redundant to the above general rule for the use and application of surveillance re Qements. In both cases, whether performed 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to the start of Core Alterations or t s e ment ofirradiated fuel in the containment building or within 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> of the start of such evoluuons, the surveillance must be met prior to entry into the Mode of applicability; the LCO must be met at the time the (volutions occur. In addition, once the status
' of the penetrations is verified, they remain under administrative control. Any changes to their status will be tracked to ensure that the requirements of the LCO (and associated SR) are met prior to entering the Mode of applicability. Similar wording has been added to DOC 9-L.
Page 1 of 3 u
I SNC Respmse to NRC RAI Rel:ted ts Chapter 3.9 NRC Question:
1 l
2.
CTS 4.9.4.b requires testing the automatic containment purge and exhaust system l
isolation function every 7 days. ITS SR 3.9.3.2 requires this testing every 18 months.
L
'Ihe [18] is bracketed, thereby requiring insertion of the CTS number. The change is an extension of a Surveillance Frequency and must have Tech Branch review.
SNC Response:
i As stated in DOC 9-L, "This change is consistent with the standard requiremerts for actuation testing of other ESFAS components. This change is reasonable considering the other existmg t.: sting that is required for the containment purge and exhaust isolation function. 'Ihe remaining surveillance requirements are adequate to ensure the operability of the contamment purge and exhaust isolation function. The surveillance requirements that are still applicable to this function l
are consistent with the surveillances required for ESFAS type functions and are therefore i
appropriate for the containment purge and exhaust isolation function." Bracketed numbers may be replaced with the associated CfS number orjustified in the documentation as has been done in this case. SNC acknowledges that this change will be reviewed by the Tech Branch.
ITS 3.9.4 Residual Heat Removal (RHR) and Coolant Circulation - High Water Level l
NRC Question:
3.
STS 3.9.5, ACTION, A.4 requires closing all containment penetrations providing direct I
access from contamment atmosphere to outside atmosphere within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> when RHR l
loop requirements are not met. ITS 3.9.4, ACTION, A.4 requires placing containment penetrations in the status described in LCO 3.9.3 " Containment Penetrations" within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, under the same conditions. TSTF-197 was rejected and has been superseded by TSTF 197, Rev.1. Revise ACTION A.4 Accordingly.
SNC Response:
TSTF-197, Rev.1, has been incorporated into the Farley ITS conversion package.
ITS 3.9.5 Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level NRC Question:
4.
Same comment as above for TSTF 197.
l Page 2 of 3 l
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SNC Respor.se to NRC RAI R: lated ts Ch:pter 3.9 j
(
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SNC Response:
TSTF-197, Rev.1, has been incorporated into the Farley ITS conversion package.
. ITS 3.9.6 Refuelina Cavity Water Level There are no comments on LCO 3.9.6 1
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Page 3 of 3
ATTACHMENTII SNC Response to NRC Request for AdditionalInformation Related to Conversion to the Improved Technical Specifications Chapters 3.I,3.2,3.5,3.7, and 3.9 Associated Package Changes Grouped by Chapter and RAI Number h
e-l Associated Package Changes for Chapter 3.1 O
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Associated Package Changes for RAI-3,1,3 2 6
I e-