ML15077A526

Request for Additional Information on Multiple Technical Specification Changes

ML15077A526
Person / Time
Site:	Hatch
Issue date:	03/27/2015
From:	Martin R Plant Licensing Branch II
To:	Pierce C Southern Nuclear Operating Co
Martin R
References
TAC MF5026, TAC MF5027
Download: ML15077A526 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Marer 27, 2015 Mr. C. R. Pierce Regulatory Affairs Director Southern Nuclear Operating Company, Inc.

Post Office Box 1295, Bin - 038 Birmingham, AL 35201-1295

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT, UNITS 1AND2- REQ.UEST FOR ADDITIONAL INFORMATION ON MULTIPLE TECHNICAL SPECIFICATION CHANGES (TAC NOS. MF5026 AND MF5027)

Dear Mr. Pierce:

By letter dated October 10, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14288A226), Southern Nuclear Ope.rating Company, Inc.

(the licensee) submitted a license amendment request for the Hatch Nuclear Plant, Units 1 and 2, to adopt various previously approved Technical Specifications T~sk Force Travelers. In order to continue the review, the U.S. Nuclear Regulatory Commission staff requests additional

• information as discussed in the. Enclosure. It is requested that your response be provided within thirty (30} days of the date of this letter.

Sincerely,

/Ju-?:!711~

Robert Martin, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366

• cc: Distribution via Listserv

j REQUEST FOR ADDITIONAL INFORMATION (RAI)

REQUEST TO INCORPORATE 20 APPROVED TECHNICAL SPECIFICATION TASK FORCE (TSTF) TRAVELERS AND AN ISTS ADOPTION IN TECHNICAL SPECIFICATIONS HATCH NUCLEAR PLANT, UNITS 1 AND 2 (HNP)

Regulatory Analysis Basis 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit states:

'Whenever a holder of a license, including a construction permit and operating license under this part, and an early site permit, combined license, and manufacturing license under part 52 of this chapter, desires to amend the license or permit, application for an amendment must be filed with the Commission, as specified in §§ 50.4 or 52.3 of this chapter, as applicable, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications."

1. RAI 3.6.1-1 for TSTF-30, and TS 3.6.1.3 and Bases:

To explain the difference between TSTF-30-A requirements and the proposed changes to Hatch TS 3.6.1.3 and its associated Bases, the licensee states that:

" ... the Hatch Technical Specifications provide a separate Action (Condition D) for penetration flow paths with leakage not within limit with a Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

As a result, a penetration flow path with an inoperable PCIV due to leakage not within limit will continue to have a 4-hour Completion Time instead of the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time provided in TSTF-30-A .

. . . Additional text is added to the Bases for TS 3.6.1.3, Condition C, describing the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time for inoperable PCIVs in penetrations [other than those associated] with a closed system and excess flow check valves (EFCVs)."

• The staff's understanding of the above statement is that for Hatch, there are penetrations with one PCIV other than those associated with closed systems and EFCVs, and the 4-hour completion time (CT) is retained for these cases. Further, an inoperable PCIV, due to leakage not within limit, will fall under the existing Action D.1, not under the revised Action C.1.

The staff requests that the licensee provide examples of cases where the 4-hour CT would be applicable. The staff needs this information to ensure correct implementation of TSTF-30-A requirements.

Enclosure

2. RAI 3.6.1-2 for TSTF-30 and Bases 3.6.1.3:

In Enclosure 3 of the application, the licensee provides a copy of applicable marked-up TS Bases pages. The staff noted the following:

1. On Page B 3.6-20, Discussion C, the phrase "and the relative importance of supporting primary containment OPERABILITY during MODES 1, 2, and 3" is not needed to justify the CT of "72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />" for PCIV in closed system.

2. On Page B 3.6-27 (Unit 2), "FSAR, Section 3.1" is added as Reference 8. This added reference is different from a similar proposed change provided on Page B 3.6-26 (Unit 1) which states "7. FSAR, Section 5.2.2.5.1."

3. On Page B 3.6.1.3 (Unit 1), "Unit 2 FSAR, Section 15.3" is listed as Reference 1.

Should an equivalent FSAR section for Unit 1 be used for this reference in the Unit 1 TS Bases?

The staff requests that the licensee address the above noted observations. The staff requests this information to ascertain that the supporting discussions in the TS Bases reflect the system design as described in the FSAR.

3. RAI 3.6.2-1 for TSTF-458 and Bases 83.6.2.1:

TS 3.6.2.1 Conditions D and F are revised to clarify the intent of TS requirements. The staff noted the following editorial errors in the Bases discussion of the revised Conditions D and F:

1. In the discussion of Actions D.1, D.2 and D.3, the third sentence is no longer -

applicable. This sentence should be removed.

2. In the heading, "E.2" is no longer applicable.

The staff requests that the licensee correct these errors.

4. RAI 3.6.4-1 for TSTF-322, and SR 3.6.4.1.4 and Bases:

SRs 3.6.4.1.3 and 3.6.4.1.4 are revised to clarify the intent of the secondary containment pressure draw down test requirements. The staff noted the following oversight in the revised SR 3.6.4.1.4:

• Due to the unique secondary containment configuration supported by standby gas treatment (SGT) subsystems in both Hatch, Units 1 & 2, the phrase "for each subsystem" after "< 4000 CFM" should be replaced with "per subsystem" instead of being deleted.

• The staff requests that the licensee address this oversight, and adjust the associated changes to the TS bases, as appropriate.

5. RAI 3.6.4-2 for TSTF-322 and Bases B3.6.4.1:

In Enclosure 3 of the application, the licensee provides a copy of applicable marked-up TS Bases pages. The staff noted the following:

• On Page B 3~6-79, in the replacement insert for discussions of SR 3.6.4.1.3 and SR 3.6.4.1.4, the sentence "The SGT subsystem(s) used for these Surveillances are staggered to ensure that in addition to the requirements of LCO 3.6.4.3, the required SGT subsystem(s) will perform this test," needs further explanation clarifying the discussion on 'staggered test,' particularly since the definition has been removed with implementation of the surveillance frequency control program (SFCP).

The staff requests that the licensee address this inconsistency in the Hatch TS Bases.

6. RAI 3.8.1-1 for TSTF-283, and TS 3.8..1 and Bases:

TSTF-283 uses two sets of inserts for the TS and Bases for surveillance notes. One set is for when a full surveillance is used to reestablish operability and the other when portions of surveillance can be used to reestablish* operability. In adopting TSTF-283 the applicant made the following changes in the application of the notes without explaining the changes.

1) In both sets of inserts to the TS surveillances, the applicant replaced the word "reestablish" with "establish." The inserts for the associated Bases discussions retain the word "reestablish." Request the applicant make the inserts consistent both with each respective Bases and with TSTF-283, or if deemed appropriate justify this change and make the Bases consistent.

2) The wrong insert was inserted into TS SR 3.8.1.9 and TS SR 3.8.1.17; Insert 2 should be used in each case, not Insert 1.

3) The wrong insert was inserted into TS SR 3.8.1.11; Insert 1 should be used, not Insert 2.

4) The wrong insert was inserted into Bases SR 3.8.1.15; Bases Insert 1 should be used, not Bases Insert 2.

The NRC request the above inconsistencies be corrected.

7. RAI 3.8.4-1 for TSTF-283, and SR 3.8.4.6, SR 3.8.4.7, SR 3.8.4.8 and Bases:

The TSTF-283 changes for SR 3.8.4.6, SR 3.8.4.7 and SR 3.8.4.8 were. not adopted for either Hatch 1 or 2.

NRC suggests the appropriate TSTF-283 inserts be adopted for SR 3.8.4.6, SR 3.8.4.7 and SR 3.8.4.8 TS and Bases for Hatch1 and 2.

ML15077A526 OFFICE DORL/LPL2-1/PM DORL/LPL2-1 /LA DSS/STSB/BC DORL/LPL2-1 /BC DORL/LPL2-1 /PM RPascarelli NAME RMartin SFigueroa RElliott RMartin (SWilliams for)

DATE 03/25/15 03/23/15 03/26/15 03/27/15 03/27/15