NL-16-0572, Response to Request for Additional Information Regarding TSTF-432-A, Revision 1

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Response to Request for Additional Information Regarding TSTF-432-A, Revision 1
ML16104A123
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 04/13/2016
From: Pierce C
Southern Co, Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-16-0572
Download: ML16104A123 (6)
v • d • e


Text

Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

40 Inverness Center Parkv.ay Post Office Box 1295 Birmingham, AL 35201 Tel 205.992.7872 SOUTHERN . \

Fax 205.992.7601 NUCLEAR A SOUTHERN COMPANY APR 1 3 2016 Docket Nos.: 50-348 NL-16-0572 50-364 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Response to Request for Additional Information Regarding TSTF-432-A. Rev. 1 Ladies and Gentlemen:

By letter dated April13, 2015, Southern Nuclear Operating Company (SNC) submitted a request to revise the Joseph M. Farley (FNP) Units 1 and 2 Technical Specifications (TS) to adopt TSTF-432-A, Revision 1, "Change in Technical Specification End States, WCAP-16294". By letter dated April?, 2016, the Nuclear Regulatory Commission (NRC) sent a Request for Additional Information (RAI). Enclosure 1 provides the SNC response to the NRC RAI. Enclosure 2 provides the revised TS Bases page resulting from the RAI.

This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.

Mr. C. R. Pierce states he is Regulatory Affairs Director for 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.

RCJ?/Zitted, C. R. Pierce Regulatory Affairs Director CRP/RMJ Sworn o and subscribed before me this /3 ~day of Af {l..f L- ,2016.

~Notary Public

.b~

My commission expires: /0- '3

  • Z-of 1

U.S. Nuclear Regulatory Commission NL-16-0034 Page2

Enclosures:

1. Response to NRC RAI
2. Revised TS Bases Page cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bast, Executive Vice President & Chief Nuclear Officer Ms. C. A. Gayheart, Vice President- Farley Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. D. A. Madison, Vice President- Fleet Operations Mr. B. J. Adams, Vice President- Engineering Ms. B. L. Taylor, Regulatory Affairs Manager - Farley RTYPE: CFA04.054 U. S. Nuclear Regulatory Commission Ms. C. Haney, Regional Administrator Mr. S. A. Williams, NRR Project Manager- Farley Mr. P. K. Niebaum, Senior Resident Inspector- Farley Alabama Department of Public Health Dr. T. M. Miller, MD, State Health Officer

Joseph M. Farley Nuclear Plant Response to Request for Additional Information Regarding TSTF-432-A, Rev.1 Enclosure 1 Response to NRC RAI

Enclosure 1 to NL-16-0572 Response to NRC RAI NRC RAI As required by section 50.36 of Title 10 of the Code of Federal Regulations (1 0 CFR 50.36), "Technical Specifications," the licensee must provide a summary statement of the bases or reasons for such specifications as part of the LAR submittal. This information may be reviewed for consistency with the associated TS changes. Based on the above, please explain the discrepancies between the TS changes and TS bases that were submitted:

  • The Bases discussion for Required Action 0.1 and 0.2 from TS 3.8.4 still includes a Mode 5 end state reference SNC Response to NRC RAI This sentence in question should have been deleted when FNP submitted to adopt this TSTF Traveler. Enclosure 2 provides the revised TS Bases markup with this sentence deleted. (Please note that it's Required Actions C.1 and C.2 from TS Bases 3.8.4 that contains the erroneous sentence, not Required Actions 0.1 and 0.2.)

Joseph M. Farley Nuclear Plant Response to Request for Additional Information Regarding TSTF-432-A, Rev.1 Enclosure 2 Revised TS Bases Page

DC Sources- Operating B 3.8.4 BASES ACTIONS B.1 and D.1 (continued)

Conditions B and D represent one Auxiliary Building or SWIS DC electrical power subsystem with connection resistance not within the specified limit. Consistent with the guidance in IEEE-450, connection resistance not within the limit is an indication that the affected battery requires attention to restore the resistance to within the limit but is not a basis on which to declare the battery inoperable. Therefore, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time allowed to restore the battery connection resistance to within the required limit is a reasonable time considering that variations in connection resistance do not mean the battery is incapable of performing its required safety function, but is an indication that the battery requires maintenance.

C.1 and C.2 If a required SWIS DC electrical power subsystem is inoperable or the connection resistance is not restored to within the limit and the associated Completion Time has expired, the Service Water System train supported by the affected SWIS DC electrical power subsystem must be declared inoperable. The capability of the affected SWIS DC electrical power subsystem to fully support the associated train of Service Water is not assured. Therefore, consistent with the definition of OPERABILITY, the associated train of Service Water must be declared inoperable immediately, thereby limiting operation in this condition to the Completion Time associated with the affected Service Water System train.

(continued)

Farley Units 1 and 2 B 3.8.4-6 IReO'isjon 2511

Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

40 Inverness Center Parkv.ay Post Office Box 1295 Birmingham, AL 35201 Tel 205.992.7872 SOUTHERN . \

Fax 205.992.7601 NUCLEAR A SOUTHERN COMPANY APR 1 3 2016 Docket Nos.: 50-348 NL-16-0572 50-364 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Response to Request for Additional Information Regarding TSTF-432-A. Rev. 1 Ladies and Gentlemen:

By letter dated April13, 2015, Southern Nuclear Operating Company (SNC) submitted a request to revise the Joseph M. Farley (FNP) Units 1 and 2 Technical Specifications (TS) to adopt TSTF-432-A, Revision 1, "Change in Technical Specification End States, WCAP-16294". By letter dated April?, 2016, the Nuclear Regulatory Commission (NRC) sent a Request for Additional Information (RAI). Enclosure 1 provides the SNC response to the NRC RAI. Enclosure 2 provides the revised TS Bases page resulting from the RAI.

This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.

Mr. C. R. Pierce states he is Regulatory Affairs Director for 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.

RCJ?/Zitted, C. R. Pierce Regulatory Affairs Director CRP/RMJ Sworn o and subscribed before me this /3 ~day of Af {l..f L- ,2016.

~Notary Public

.b~

My commission expires: /0- '3

  • Z-of 1

U.S. Nuclear Regulatory Commission NL-16-0034 Page2

Enclosures:

1. Response to NRC RAI
2. Revised TS Bases Page cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bast, Executive Vice President & Chief Nuclear Officer Ms. C. A. Gayheart, Vice President- Farley Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. D. A. Madison, Vice President- Fleet Operations Mr. B. J. Adams, Vice President- Engineering Ms. B. L. Taylor, Regulatory Affairs Manager - Farley RTYPE: CFA04.054 U. S. Nuclear Regulatory Commission Ms. C. Haney, Regional Administrator Mr. S. A. Williams, NRR Project Manager- Farley Mr. P. K. Niebaum, Senior Resident Inspector- Farley Alabama Department of Public Health Dr. T. M. Miller, MD, State Health Officer

Joseph M. Farley Nuclear Plant Response to Request for Additional Information Regarding TSTF-432-A, Rev.1 Enclosure 1 Response to NRC RAI

Enclosure 1 to NL-16-0572 Response to NRC RAI NRC RAI As required by section 50.36 of Title 10 of the Code of Federal Regulations (1 0 CFR 50.36), "Technical Specifications," the licensee must provide a summary statement of the bases or reasons for such specifications as part of the LAR submittal. This information may be reviewed for consistency with the associated TS changes. Based on the above, please explain the discrepancies between the TS changes and TS bases that were submitted:

  • The Bases discussion for Required Action 0.1 and 0.2 from TS 3.8.4 still includes a Mode 5 end state reference SNC Response to NRC RAI This sentence in question should have been deleted when FNP submitted to adopt this TSTF Traveler. Enclosure 2 provides the revised TS Bases markup with this sentence deleted. (Please note that it's Required Actions C.1 and C.2 from TS Bases 3.8.4 that contains the erroneous sentence, not Required Actions 0.1 and 0.2.)

Joseph M. Farley Nuclear Plant Response to Request for Additional Information Regarding TSTF-432-A, Rev.1 Enclosure 2 Revised TS Bases Page

DC Sources- Operating B 3.8.4 BASES ACTIONS B.1 and D.1 (continued)

Conditions B and D represent one Auxiliary Building or SWIS DC electrical power subsystem with connection resistance not within the specified limit. Consistent with the guidance in IEEE-450, connection resistance not within the limit is an indication that the affected battery requires attention to restore the resistance to within the limit but is not a basis on which to declare the battery inoperable. Therefore, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time allowed to restore the battery connection resistance to within the required limit is a reasonable time considering that variations in connection resistance do not mean the battery is incapable of performing its required safety function, but is an indication that the battery requires maintenance.

C.1 and C.2 If a required SWIS DC electrical power subsystem is inoperable or the connection resistance is not restored to within the limit and the associated Completion Time has expired, the Service Water System train supported by the affected SWIS DC electrical power subsystem must be declared inoperable. The capability of the affected SWIS DC electrical power subsystem to fully support the associated train of Service Water is not assured. Therefore, consistent with the definition of OPERABILITY, the associated train of Service Water must be declared inoperable immediately, thereby limiting operation in this condition to the Completion Time associated with the affected Service Water System train.

(continued)

Farley Units 1 and 2 B 3.8.4-6 IReO'isjon 2511

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