ML100570035

Issuance of Amendments 184 & 178 to Clarify Technical Specification for P-11 and P-12 Interlocks

ML100570035
Person / Time
Site:	Farley
Issue date:	03/11/2010
From:	Martin R Plant Licensing Branch II
To:	Ajluni M Southern Nuclear Operating Co
Martin R, NRR/DORL, 415-1493
References
TAC ME2247, TAC ME2248
Download: ML100570035 (17)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 11,2010 Mr. Mark J. Ajluni Manager, Nuclear Licensing Southern Nuclear Operating Company, Inc.

40 Inverness Center Parkway P.O. Box 1295 Birmingham, Alabama 35201

SUBJECT:

JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 RE: ISSUANCE OF AMENDMENTS TO CLARIFY TECHNICAL SPECIFICATION FOR P-11 AND P-12 INTERLOCKS (TAC NOS. ME2247 AND ME2248) .

Dear Mr. Ajluni:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 184 to Renewed Facility Operating License No. NPF-2 and Amendment No. 178 to Renewed Facility Operating License No. NPF-8 for the Joseph M. Farley Nuclear Plant, Units 1 and 2. The amendments consist of changes to the Technical Specifications (TS) in response to your application dated September 15, 2009, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML092590164).

The amendments revise the TS to clarify the application of TS 3.3.2, Condition K, which is applicable to the P-11 and P-12 permissive/interlock functions of the engineered safety feature actuation system. In addition, an editorial change is proposed for TS 5.6.8 to correct the citation of a condition requiring a report for the postaccident monitoring instrumentation.

A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

.Lt,t;v7 j) )~'Y-v~(;"v Robert E. Martin, Stnior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364

Enclosures:

1. Amendment No. 184 to NPF-2

2. Amendment No. 178 to NPF-8

3. Safety Evaluation cc w/encls: Distribution via ListServ

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

ALABAMA POWER COMPANY DOCKET NO. 50-348 JOSEPH M. FARLEY NUCLEAR PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 184 Renewed License No. NPF-2

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Southern Nuclear Operating Company, Inc.

(Southern Nuclear), dated September 15, 2009, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment; and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-2 is hereby amended to read as follows:

-2 (2) Technical Specifications The Technical Spp.cifications contained in Appendices A and B, as revised through Amendment No. 184, are hereby incorporated in the license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION (9/c......--.-

Gloria Kulesa, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance:March 11, 2010

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

ALABAMA POWER COMPANY DOCKET NO. 50-364 JOSEPH M. FARLEY NUCLEAR PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 178 Renewed License No. NPF-8

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Southern Nuclear Operating Company, Inc.

(Southern Nuclear), dated September 15, 2009, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment; and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-8 is hereby amended to read as follows:

-2 (2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment NO.178 are hereby incorporated in the license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION (Ltc.. _ ./

Gloria Kulesa, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: M3rch 11, 2010

ATTACHMENT TO LICENSE AMENDMENT NO. 184 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-2 DOCKET NO. 50-348, AND ATTACHMENT TO LICENSE AMENDMENT NO. 178 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-8 DOCKET NO. 50-364 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert License Pages License Pages NPF-2 page 4 NPF-2 page 4 NPF-8 page 3 NPF-8 page 3 TS Pages TS Pages 3.3.2-5 3.3.2-5 5.6-5 5.6-5 83.3.2-40 83.3.2-40

-4 (2) Technical Specifications The Technical SD~iCations contained. In Appeildlx A, u r.vised.thr6ugh Amendment No 1841. are hereby Incorporated In the renewed 1cInse.

Southern Nuclear snail oPe.rale the faclllly In Eiccordance with th8 Technical SpecificatIOns.

(3) AddWonalCond~on8 The ma~erl specified In the Iallowlng candlti.ons IhaII be completed to the satisfaction of the Commlaslon wI1hln the stated tlml PQrJods '.

following the issuance pf the renewed license or wlthln.__ opera~l restrictions Indicated. The removal of these co~ 1ha!1. be mad. by .

an amendment to the renewed license supported by alIVOrable ..'

evaluation by the CommissJoli.

. a. . Southern NuClear sHall not ope~te tile rNetor In Operational Modes 1 and 2 with leas than three reactor coollll'lt pumps in operation; . . .

b. Deleted per Amendment 13 c, Deleted per Am~ment 2

d. Deleted per Amendment 2

e. Deleted per Am~dment 152 Deleted per Amendment 2 .

f. Deleted per Amendment 158 . -."

g. Southern Nuclear shall maintain a secondary water ch.e~ .

monitoring program to Inhibit steam generator tube deg~on: .'

This program shallnclUde: .

1) Identification of a sampling schedule 'or the critical parameters and contrOl points for these parameters;

2) ldentillcation 01 the procedur~ ~ to quantify parameters that are cri1icall~ control poin~;

3) Identlfi~t1on ot process sampling points:

4) A procedure for the recording and managBment o'dala:

Farley' Unit 1 Renewed Ueense Nri'NPF-2 A~endmentN~. ~84

'" *****  ::. I' * .'

~ 3 (2) Alabama Power Company, puI'Ilant to section 1~ or the Ad IIId 10 CFR Part 50, iouceMing of ProductIon and U1IIlzatlon Faclltlee: to possess but not operate lheflClty at the detignated localon in Houlton Couilty, Alabama In acccrdllnce with te proc8durH and IIrnltaIiona 58t forth In this renewed lcenstr.

(3) Southern Nuclear, puteuant to the Act aOO10 CFA Part 70, to I"lICCivll, p()8SeSS a'nd use at any'me lpeClal raiclear material ** reaclDr fu8I;1n accordance with the ~1Ia1lo1'llS tor storage and,amourN required tOt reactor operallon, as des<:rlbld In the Final Safety Analy. Report, u supplemenled and arnendecl:

14) Southam Nuclear, pUl'lUlnt to tile Act and 10 CFR Part8 30, 40 and 70, to receive, POseess, and use at eriy time any byprodud, IIOUrce and spec:ial nuclear material u ualld neutron iources for reactor 1t8~,

. ~ea'ed sources-for reilatOllnaJrumenlatlon and-ra:liallcrrmorV!orinli "

equipment calibration, .ner** n.1Ion detectors In amountl as r&quirld; (5) SouJhern Nuclear, pursuant to the Ad and 10 CFR Parts 30,40 and 7D, to receive, POSies, and use In amounts II required ai1y byproduct, .

source or Ipeclal nuclear mat_rilII without retrtrlCllon 10 c;hemical or' physical form, 10; sample analysll or Instrument c:alintion or associated with radloe.ctlve apparatus or ~ts; end (6) Southern Nuclear, pursUlint to the Act and 10 CFR Parts 30, 40 and 70,

. .to posless, but not separate, luch byjlfoc1Jc:t and special nUclellr materials a~ may be'produced by tne operation of the facilItY.

C. This renewed license shall be deemed to contain and II .ubje'ct to the CCln~

specified In the CornrniaIons'. regulatlona.t for1h in 10 eFR Chapter l elY:! ls sLbJect to aU app6cable,ptOvlsiona of the Act and the /\lIes, regulations. and orders of the Commission now or hel'8IIfter In eJleet; and Is lubject to*the additional condillons specified or Incorporated below:

(1)' Maximum,Power Level Southern Nucleer illluthorized to operatelh81acillty at r..ctor ClOI'a power levels not in excesl of 2ns megawatts thenl'llli.

(2) Technical S'pecilicalion§

'The' Technical Sp8l':ifll;atlonl. contained In Appendix A. al revlHd through Amendme~t No. 178 . are herBby Incorporated In the ren8W8d Iic~ru. ,I Southern Nucloar snaU. opera.. the facility in accordance vvith the Technical Specifications.

Farley'. Unit 2 Renewed Lletn! NI). NPF-U'

, Amendment No '. **178

ESFAS Instrumentation 3.3.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME I. One channel inoperable. 1.1 -----------NOTE------------

The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing of other channels.

Place channel in trip. 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OR 1.2 Be in MODE 3. 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> J. One or more Main J.1 Restore channel(s) to Prior to next required Feedwater Pump trip OPERABLE status. TADOT channels inoperable on one or more Main Feedwater Pumps, K. One or more channels K.1 Verify interlock is in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable. required state for existing unit condition.

OR K.2.1 Be in MODE 3. 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> AND K.2.2 Be in MODE 4. 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> L. One train inoperable. L.1 Verify interlock is in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> required state for existing unit condition.

OR (continued)

Farley Units 1 and 2 Amendment No. 184 (Unit 1)

Amendment No. 178 (Unit 2)

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as 8DM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

5.6.6 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)

a. The reactor coolant system pressure and temperature limits, including heatup and cooldown rates, shall be established and documented in the PTLR for LCO 3.4.3.

b. The analytical methods used to determine the RCS pressure and temperature limits shall be those previously reviewed and approved by the NRC, specifically those described in the NRC letters dated March 31, 1998 and April 3, 1998.

c. The PTLR shall be provided to the NRC upon issuance for each reactor fluence period and for any revision or supplement thereto.

5.6.7 EDG Failure Report If an individual emergency diesel generator (EDG) experiences four or more valid failures in the last 25 demands, these failures shall be reported within 30 days.

Reports on EDG failures shall include a description of the failures, underlying causes, and corrective actions taken per the Emergency Diesel Generator Reliability Monitoring Program.

5.6.8 PAM Report When a report is reqUired by Condition B or F of LCO 3.3.3, "Post Accident Monitoring (PAM) Instrumentation:' a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

(continued)

Farley Units 1 and 2 5.6-5 Amendment No. 184 (Unit 1)

Amendment No. 178 (Unit 2)

ESFAS Instrumentation B 3.3.2 BASES ACTIONS g (continued) to be lost and the associated Completion Time of prior to the next required TAD aT surveillance are acceptable based on the backup nature of this function. This function is not relied on as the primary actuation signal for AFW auto-start in any DBA analysis.

K.1, K.2.1. and K.2.2 Condition K applies to the P-11 and P-12 interlocks. This Condition is applicable when the interlock is inoperable to the extent that an ESFAS function which should not be blocked in the current MODE is blocked.

With one or more channels inoperable, the operator must verify that the interlock is in the required state for the existing unit condition.

This action manually accomplishes the function of the interlock.

Determination must be made within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is equal to the time allowed by LCO 3.0.3 to initiate shutdown actions in the event of a complete loss of ESFAS function. If the interlock is not in the required state (or placed in the required state) for the eXisting unit condition, the unit must be placed in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 4 within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

Placing the unit in MODE 4 removes all requirements for OPERABILITY of these interlocks.

l.1! l.2, l.3.1, and l.3.2 Condition L applies to the automatic actuation logic and actuation relays for the P-4, P-11 and P-12 interlocks. This Condition is applicable when the interlock is inoperable to the extent that an ESFAS function which should not be blocked in the current MODE is blocked.

With one train inoperable, the operator must verify that the interlock is in the required state for the existing unit condition. This action manually accomplishes the function of the interlock. Determination must be made within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. If the interlock is not in the required state (or placed in the required state) for the existing unit condition, the interlock must be restored to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or the unit must be placed in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and (continued)

Farley Units 1 and 2 B 3.3.2-40 Revision ftrrendrrent t\b. 184 (Lhi t 1)

JIlTendrrent t\b. 178 (Lhit 2)

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 184 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-2 AND AMENDMENT NO. 178 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-8 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-348 AND 50-364

1.0 INTRODUCTION

By application dated September 15, 2009, (ADAMS ML092590164) to the U.S. Nuclear Regulatory Commission (NRC, the Commission), Southern Nuclear Operating Company (SNC, the licensee) submitted a license amendment request (LAR) requesting changes to the Technical Specifications (TSs) for Joseph M. Farley Nuclear Plant, Units 1 and 2 (FNP) in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.90, "Application for Amendment of License, Construction Permit, or Early Site Permit." The licensee's proposed changes revise TS to clarify the application of TS 3.3.2, Condition K, which is applicable to the P-11 and P-12 permissive/interlock functions of the engineered safety feature actuation system (ESFAS). In addition, an editorial change is proposed for TS 5.6.8 to correct the citation of a condition requiring a report for the postaccident monitoring (PAM) instrumentation.

2.0 REGULATORY EVALUATION

The regulatory requirements and guidance which the NRC staff considered in its review of the applications are as follows:

1. Title 10 of the Code of Federal Regulations (10 CFR) Part 50 establishes the fundamental regulatory requirements with respect to the domestic licensing of nuclear production and utilization facilities. Specifically, Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50 provides, in part, the necessary design, fabrication, construction, testing, and performance requirements for structures, systems, and components important to safety.

2. General Design Criteria (GDC) - 10, "Reactor design," requires that the reactor core and associated coolant, control, and protection systems be designed with appropriate margin to assure that specified acceptable fuel design limits are not exceeded during

-2 any condition of normal operation, including the effects of anticipated operational occurrences.

3. GOC - 13, "Instrumentation and control," requires that instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems. Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges.

4. GOC - 20, "Protective system functions," requires the protection system be designed (1) to initiate automatically the operation of appropriate systems including the reactivity control systems, to assure that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences and (2) to sense accident conditions and to initiate the operation of systems and components important to safety.

5. GOC 21, "Protection System Reliability and Testability," requires that the system be designed for high functional reliability and in service testability, with redundancy and independence sufficient to preclude loss of the protection function from a single failure and preservation of minimum redundancy despite removal from service of any component or channel.

6. GOC 22, "Protection System Independence," requires that the system be designed so that natural phenomena, operating, maintenance, testing and postulated accident conditions do not result in loss of the protection function.

7. GOC 23, "Protection System Failure Modes," requires that the system be designed to fail to a safe state in the event of conditions such as disconnection, loss of energy, or postulated adverse environments.

8. GOC 24, "Separation of Protection and Control Systems," requires that interconnection of the protection and control systems be limited to assure safety in case of failure or removal from service of common components.

9. 10 CFR 50.36 - "Technical specifications," states, "Each applicant for a license authorizing operation of a production or utilization facility shall include in his application proposed technical specifications in accordance with the requirements of this section."

Specifically, 10 CFR 50.36(c)(2)(ii) sets forth four criteria to be used in determining whether a limiting condition for operation is required to be included in the TS.

10. 10 CFR 50.55a(h) requires that the protection systems meet IEEE 279. Section 4.2 of IEEE 279 -1971 discusses the general functional requirement for protection systems to assure they satisfy the single failure criterion.

-3

3.0 TECHNICAL EVALUATION

ESFAS permissives and interlocks are provided to ensure that engineered safety features are in the correct configuration for the current plant status. Specified engineered safety features are bypassed at specified plant conditions where they are not required for protection and would otherwise interfere with normal operation of the plant and are unblocked at other specified plant conditions. The P-11 and P-12 ESFAS permissive/interlocks are the subject of this technical specification amendment.

The P-11 ESFAS permissive/interlock permits normal unit cooldown and depressurization without actuation of safety injection (SI) due to a pressurizer low pressure condition. During normal plant power operations, two-out-of-three pressurizer pressure instrument channels less than the low-pressure SI setpoint would result in a pressurizer pressure low SI actuation signal that would initiate injection of makeup water to the reactor coolant system. To account for plant cooldown and low pressure operations with the plant shut down, the operator has the ability to manually block the Pressurizer Pressure -Low SI actuation signal when 2 of 3 pressurizer channels are below the P-11 setpoint. The P-11 interlock provides the following two safety functions.

1. With two-out-of-three pressurizer pressure channels above the P-11 setpoint, the Pressurizer Pressure -Low SI actuation is automatically reinstated.

2. With two-out-of three channels below the P-11 setpoint, the pressurizer power operated relief valves (PORVs) are interlocked closed in the automatic control mode to prevent uncontrolled reactor coolant system (RCS) de-pressurization that could be caused by a control system failure or malfunction.

Technical Specification limiting conditions for operation (LCO's) stipulate that the P-11 function must be operable in Modes 1, 2 and 3 to automatically reinstate the Pressurizer Pressure Low SI actuation function during normal unit heatup. The P-11 function must allow for an orderly cooldown and depressurization of the unit without the actuation of a Pressurizer Pressure Low SI.

The P-11 is also required to interlock automatic PORV operation, if necessary. The Low Pressurizer Pressure SI feature is not required to be operable in Modes 4, 5, or 6 because the associated safety functions are not required for accident detection and mitigation.

The P-12 ESFAS permissive/interlock permits normal unit cooldown and depressurization without actuation of SI and main steam line isolation (MSLI) due to a steam line low pressure condition.

During normal plant power operations, two-out-of-three steam line pressure instrument channels less than the SI actuation setpoint would result in a low steam line pressure safety injection actuation signal that would initiate injection of makeup water to the reactor coolant system and initiate a main steam line isolation signal. To account for plant cooldown and low pressure operations with the plant shut down, the operator has the ability to manually block the SI and MSLI on low steam line pressure when two-out-of-three Tavg channels are below the P-12 permissive setpoint. The P-12 interlock provides the following three safety functions.

1. On increasing reactor coolant temperature with two-out-of-three channels above the setpoint, the P-12 interlock automatically reinstates the SI and MSLI on Steam Line Pressure - Low functions.

-4

2. On decreasing reactor coolant temperature with two-out-of-three Tavg channels below the setpoint, the P-12 safety function generates a MSLI on High Steam Flow in Two Steam Lines Coincident with Tavg -Low Low.

3. On decreasing temperature with two-out-of three Tavg channels below the setpoint, the P-12 interlock blocks the steam dump valves to prevent an excessive cooldown of the RCS due to a control system failure or malfunction.

The LCO's stipulate that the P-12 function must be operable in Modes 1, 2, and 3 during plant heatup to automatically reinstate SI and MSLI on Steam Line Pressure Low when RCS Tavg is above the P-12 setpoint. In Modes 1,2, and 3, P12 must be operable to afford protection should a secondary side break, stuck open relief or safety valve, or steam dump malfunction result in the rapid depressurization of the steam lines. The P12 function is operable when the interlock is in the required state for the unit condition. The P12 function is not required to be operable in Modes 4, 5, or 6 because in these modes, there is insufficient energy in the secondary side to require mitigation of a postulated event.

The licensee has requested a revision to the FNP Unit 1 and Unit 2 TSs associated with the P-11 and P-12 ESFAS permissive/interlock as follows; Revise the LCO for TS 3.3.2, Table 3.3.2.1 condition K from "Two channels inoperable" to "One or more channels inoperable." The licensee stated that this change is necessary in order to account for all of the possible conditions of the P-11 and P-12 interlocks since each of these interlocks consists of three channels as described above. Prior to this change, the condition of only one or of all three of the P-11, or P-12 permissive/interlock channels being inoperable was not accounted for.

Prior to this revision, a condition wherein only one channel of the P-11, or P-12 permissive/interlock became inoperable would not have required the operator to take the TS REQUIRED ACTION K. Upon incorporation of this change, the same condition will require the operator to verify that the permissive/interlock is in the required state for the existing unit condition.

The staff has reviewed the licensee's proposed TS change and concludes that it clarifies the intent of the TS and that the intended operator actions required as a result of having inoperable P-11 or P-12 permissive/interlock channels are appropriate, and is therefore, acceptable. The revised text also conforms to the corresponding condition statement applicable to the P-11, and P-12 permissive/interlock functions (LCO 3.3.2 Condition L) contained in the Improved Standard Technical Specifications (STS) (NUREG-1431, Vol. 1 Revision 3.1), which are applicable to FNP.

The text in the Bases section of the TSs was also revised to reflect this change.

The licensee has also requested an editorial correction to the reporting requirements described in Technical Specification 5.6.8, "PAM Report." This correction changes the referenced LCO condition from Condition "G" to the correct Condition "F." This is consistent with the corresponding Section of the STS which is 5.6.7 and is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the State of Alabama official was notified of the

-5 proposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (73 FR 39056). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or the health and safety of the public.

Principal Contributor: Richard Stattel, NRR Date: March 11,2010

ML100570035 *Per Memo Dated, (**) Per E-mail OFFICE LPL2-1/PM LPL2-1/LA EICB/BC OGC/NLO ITSB/BC LPL2-1/BC NAME RMartin SRohrer WKemper* STurk REllioU** GKulesa (wI change) (wI comments)

DATE 03/10/10 03/01/10 02/23/10 03/04/10 03/09/10 03/11/10