NL-12-0867, License Amendment Request to Technical Specification 3.7.6, Condensate Storage Tank

License Amendment Request to Technical Specification 3.7.6, Condensate Storage Tank

ML12234A743
Person / Time
Site:	Farley
Issue date:	08/20/2012
From:	Ajluni M Southern Co, Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NL-12-0867
Download: ML12234A743 (14)

Text

Mark J. AjJuni, P.E. Southern Nuclear Nuclear Licensing Director Operating Company, Inc.

40 Inverness Center Par way Post Office Box 1295 Birmingham, Alab ama 35201 Tel 205.992.7673 Fax 205.992.7885 SOUTHERN'\'

COMPANY August 20,2012 Docket Nos.: 50-348 NL-12-0867 50-364 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant - Units 1 and 2 License Amendment Request to Technical Specification 3.7.6, Condensate Storage Tank Ladies and Gentlemen:

Pursuant to 10 CRF 50.90, Southern Nuclear Operating Company (SNC) hereby requests an amendment to the Technical Specifications (TS) for Joseph M.

Farley Nuclear Plant (FNP), Units 1 and 2.

The change would revise the current FNP TS minimum condensate storage tank level to reflect an increased minimum level. SNC concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of "no significant hazards consideration" is justified. provides the basis for the proposed change. Enclosure 2 contains the TS markup page. Enclosure 3 contains the TS clean typed page.

SNC requests approval of the proposed license amendment by August 15, 2013.

The proposed changes would be implemented within 60 days of issuance of the amendment.

In accordance with 10 CFR 50.91, a copy of this license amendment request with enclosures is being provided to the designated Alabama state officials.

U.S. Nuclear Regulatory Commission NL-12-0867 Page 2 This letter contains no NRC commitments. If you have any questions, please contact me at (205) 992-7673.

Mr. Mark Ajluni states he is Nuclear Licensing Director of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.

om to and subscribed before me thisdo"aay of d"t~ ,2012.

y commission expires: ~

Respectfully submitted, M. J. Ajluni Nuclear Licensing Director MJAlCLN/lac

Enclosures:

1. Basis for Proposed Change

2. Technical Specifications Markup Page

3. Technical Specifications Clean Typed Page cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. T. A. Lynch, Vice President - Farley Mr. B. L. Ivey, Vice President - Regulatory Affairs Mr. B. J. Adams, Vice President - Fleet Operations RTYPE: CFA04.054 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Project Manager - Farley Mr. E. L. Crowe, Senior Resident Inspector - Farley Alabama Department of Public Health Dr. D. E. Williamson, State Health Officer

Joseph M. Farley Nuclear Plant - Units 1 and 2 license Amendment Request to Technical Specification 3.7.6, Enclosure 1 Basis for Proposed Change

Enclosure 1 Basis for Proposed Change Table of Contents 1.0 Summary Detailed Description 3.0 Technical Evaluation 4.0 Regulatory Evaluation 4.1 Significant Hazards Consideration 4.2 Applicable Regulatory Requirements/Criteria 4.3 Precedent 4.4 Conclusions 5.0 Environmental Consideration 6.0 References

-1

NL-12-0867 Basis for t'rC)D()SEIO Change 1.0 Summary Description This evaluation supports a to revise Operating License (OL) NPF 2 and for Joseph M. Nuclear Plant (FNP), Units 1 and 2, proposed change would OL to change Condensate

<":1'1"'1,1"",,,,0 (CST) level specified in Specification (TS) Surveillance Requirement 3.7.6.1. The change is being as a result of a Nuclear Regulatory Commission (NRC) challenge to the current calculation basis with respect potential vortexing and assumptions regarding heat loads on volume. These were made during Component Design Inspection conducted in 2011.

2.0 Detailed Description proposed change is as follows:

3.7.6.1 is from "Verify the CST is ~ 150,000 gal.,"

to "Verify the CST is ~ 164,000 gal."

for TS Limiting Condition of Operation (LCO) 3.7.6 will be to incorporate the revised required CST minimum volume from 150,000 gallons to 164,000 gallons.

3.0 TO.l"nr\I"'l~1 Evaluation is a 500,000 gallon capacity tank that is a of the Auxiliary (AFW) System. CST provides makeup and surge capacity to compensate for changes in the turbine plant system's inventory and provides reserve supply for emergency shutdown heat removal, should the normal feedwater system fail.

CST volume for operability is specified in 3.7.6.1. The ro\,,,cGl,f'! to increase tank's minimum water volume. This r",,,,<.:.c..,

water volume The revised minimum storage for each unit determined from plant specific calculations performed to determine most limiting plant event. Based on calculations, the limiting event for CST required tank volume is maintaining the plant standby for a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after a reactor trip followed by a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> cooldown to 350°F, including total water volume lost from assumed ruptured lines of AFW pump recirculation lines and unisolated flow instrumentation lines. Also included in the calculation of volume is minimum tank level to prevent vortexing (10,132 A useable one reactor pump (Rep) in t'\l"\l"r<::llC1t'\1"\ for the duration (6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) plus 10 megawatt (MWt) net RCP heat added and decayed over one hour is also included.

limiting CST required tank volume for FNP 1 and 2 is 154,054 gallons and includes volume available to the AFW pumps, as stated in E1-2 to NL*1 Basis for Proposed Change 3.7.6 Bases. Other accidents scenarios less inventory.

Increasing the minimum level to 164,000 gallons provides n"'~'H.'CI margin is supported by the design the lower CST (protected volume is 164,832 gallons).

4.0 Regulatory Evaluation Significant Hazards Consideration Southern Nuclear Operating Company (SNC) evaluated whether or not a significant hazards consideration is involved with the proposed changes by focusing on three standards forth in 10 CFR 50.92(c) as discussed below:

1. the proposed amendment involve a significant in the probability or consequences of an accident previously evaluated?

Response: No.

proposed change would revise TS 3.7.6, "Condensate Storage Tank "to revise the CST level requirements specified in Surveillance Requirement (SR) . The proposed change administratively increases the volume margin of the The CST is not an accident initiator and is credited to mltlaalre accidents and These changes no impact on method by which the CST performs its functions. With these changes, a sufficient quantity of water will continue to be supplied by the to the Auxiliary Feedwater (AFW) pumps to remove heat from Reactor Coolant System (RCS) during a plant event.

With this change, the overall quantity of water required to meet operability requirements of SR 1 is This is acceptable, providing increased volume margin and is based on plant specific CST minimum storage volume calculations.

change not impact accident or analyzed events. It does not impact any assumed mitigation capability any or event. The change does not involve addition or removal of equipment; however, a change to the low alarm will be required.

operation of facility in accordance with proposed amendment not involve a significant in the probability or consequences of an accident previously evaluated.

Does proposed amendment possibility a new or different kind of accident from any accident previously evaluated?

E1 to NL-12-0867 Basis for Proposed Change Response: No.

The CST is not an accident initiator and is credited to accidents and events. changes have no impact on the method by which the performs functions. This change does not involve any physical modifications to plant structures, systems, or components (SSCs). or the manner in which SSCs are maintained, modified, tested, or inspected. In addition, there is no change in the types or in the amounts effluents that may be offsite, and there is no increase in individual or cumulative occupational radiation exposure. Therefore, the change does not the possibility of a new or different kind of accident from any previously evaluated.

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The accident analyses credit inventory to meet pressure, containment design 10 100 limits, 10 CFR 50.36 peak cladding temperature limits. The increase 3.7.6.1 required minimum volume increases the volume margin. CST volume for the natural circulation cooldown event is greater than that required to mitigate accidents.

CST will continue to provide entire required source of volume of safety grade to the System pumps to remove decay and sensible heat from the RCS. change does not involve any physical modifications to SSCs or manner in which are maintained, modified, , or inspected.

However, a design change to low level alarm setpoint will be required. The change does not alter the manner in which safety limits, limiting safety settings, or limiting conditions for operation are determined. The setpoints at which protective actions are are not altered by change. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, SNC concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of significant hazards consideration" is justified.

4.2 Applicable Regulatory Requirements/Criteria The regulatory for TS 1.3, "Condensate Storage Tank," is to provide a safety grade source of water to steam generators for removing and heat from the reactor coolant system FNP's CST provides the primary and source of AFW during plant transients.

to NL-12-0867 Basis for Proposed Change following lists the requirements specific design bases related the proposed changes.

• 10 CFR Part 50 General Design Criteria (GDC) 2, "Design bases for protection against natural phenomena," requires structures, systems, and components important to safety shall designed to withstand the effects of natural phenomena as earthquakes, hurricanes, floods, seiches without of capability to perform their functions.

• GDC 5, "Sharing of structures, components,"

requires that important to shall not be shared among nuclear power units unless it can be shown that sharing will significantly impair ability to perform their safety functions, including, in the an accident in one unit, an orderly shutdown and cooldown of the remaining units.

• GDC 44, "Cooling water," a system to heat from important to safety, to an ultimate heat sink shall be provided.

• GDC 45, "Inspection of cooling water system," defines that cooling water system shall be designed to permit appropriate periodic inspection of important components, such as piping, to assure integrity and capability of the system.

• of cooling water " requires that shall be designed to permit appropriate and functional Tom'lnn

• Regulatory Guidance 1.29, "Seismic Classification,"

describes method for identifying and classifying those of a light-watercooled power plant should be to withstand of a Safe Shutdown

• !\IRC Branch Technical Position , "Design Requirements of the Residual Heat System," dated July 1981

• !\IUREG -0800, "U.S. NRC Standard Plan," Section 9.2.6, Storage " provides guidance the NRC review and evaluation of system features to the connections or interfaces with other systems associated with the condensate storage facilities, which mayor may not be related.

-5 to NL-12-0867 Basis for Proposed Change The CST is aligned to AFW system as primary and preferred source of cooling water for plant transients that result in a for AFW. NUREG-0800, Standard Review Plan, Section 9.2.6, "Condensate Facility," provides guidelines assure conformance with requirements of General Design Criteria 2, 44, 45, and 46.

4.3 Precedent The proposed in CST minimum water volume previously been approved for Brunswick Steam Plant in Amendment to Facility Operating No. and Amendment No. 232 to Facility Operating License No. DPR-62 in the NRC letter, "Issuance of Amendment 201 to Facility Operating No. DPR-71 and Amendment No. to Facility Operating No. DPR-62 Condensate Storage Tank - Brunswick Steam Electric Plant, Units 1 2 (TAC Nos. MA1483 and MA 1484),"

June 1998, based on the Brunswick application dated April 3, 1998.

4.4 Conclusions In conclusion, based on the considerations discussed (1) is reasonable assurance that the health and safety of public will not be endangered by operation in the manner, (2) such activities will conducted in compliance with Commission's regulations, (3) the issuance the amendment will not inimical to common and security or to the health and safety of public.

5.0 Environmental Consideration A review has that the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant in the types or a significant increase in amounts of effluents that may released or (iii) a increase in individual or cumulative occupational radiation Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR .22(c)(9). pursuant to 10 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with proposed 6.0 References

1. Joseph M. Nuclear Unit 1 and Unit Analysis Report Update Revision June 201

2. Joseph M. Farley Nuclear Plant Unit 1 Unit 2, Final AnalYSis Update 24, June Section "Design

-6 to NL-12-0867 Basis for Proposed Change

3. M. Farley Nuclear Plant Unit 1 and Unit 2, Final Analysis Report Update Revision June 2012, Section

~~_"TL;>n' Description"

4. M. Farley Nuclear Unit 1 and Unit 2, Final Report Update Revision June 2012, Section

"_,;)'Tenl Considerations" Joseon M. Farley Nuclear Plant Units 1 and 2, Technical

,nl::>I",1"1"'01',r\n Bases Revision 3.7.6

6. M. Farley Nuclear Plant Units 1 and 2 Technical Specifications, Amendments 1 (Unit 1) and 183 (Unit 3.7.6

7. NRC "Issuance of Amendment No. 201 to Facility Operating

.rc.ne"" No. DPR-71 and Amendment No. 232 to License No.

Capacity - Brunswick Electric Plant, Units 1 and 2 (TAC Nos. MA1483 and MA 1484)", dated June 1998

8. NU 431, "Standard Specifications Westinghouse Plants," Revision 4, dated October 2011.

9. NU -0800, "U.S. NRC Review Plan,"

Storage

10. Calculation BM 95-0961-001 , "Verification

Joseph M. Farley Nuclear Plant - Units 1 and 2 License Amendment Request to Technical Specification Enclosure 2 Technical Specifications Markup Page

3.7.6 PLANT SYSTEMS 3.7.6 Condensate Storage Tank LCO 3.7.6 The CST APPLICABI LlTY: 1, 3.

ACTIONS CONDITION ACTION COMPLETION TIME A. CST inoperable. A.1 Verify by administrative 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> means OPERABILITY of backup water supply. AND Once per 12 7

B. Required Action and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> FREQU SR 3.7.6.1 Farley Units 1 and 2 Amendment No. (Unit 1)

Amendment No. (Unit

Joseph M. Farley Nuclear Plant - Units 1 and 2 license Amendment Request to Technical Specification 3.7.6, Enclosure 3 Technical Specifications Clean Typed

CST 3.7.6 3.7 PLANT SYSTEMS 3.7.6 Condensate Storage Tank (CST)

LCO 3.7.6 The shall APPLICABILITY: 1,2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. CST inoperable. A.1 by administrative 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> means OPERABILITY of backup supply.

Once 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND A.2 Restore to 7 days OPERABLE status.

Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion not met. AND in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SURVEILLANCE FREQUENCY SR 1 Verify the level is 2: 164,000 In accordance with Surveillance Frequency Control Program Units 1 and 2 Amendment No. (Unit 1)

Amendment No. (Unit