Text

Issuance of Amendments 221 and 218 Technical Specification 3.3.2 Regarding Steam Flow Isolation on High Steam Flow
	ML18271A207
Person / Time
Site:	Farley
Issue date:	11/07/2018
From:	Shawn Williams; Plant Licensing Branch II
To:	Gayheart C; Southern Nuclear Operating Co
	Williams S
References
	EPID L-2017-LLA-0428
	Download: ML18271A207 (21)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 7, 2018 Ms.Cheryl A.Gayheart Regulatory Affairs Director Southern Nuclear Operating Company, Inc.

P.O. Box 1295, Bin 038 Birmingham, AL 35201-1295

SUBJECT:

JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS RE: TECHNICAL SPECIFICATION 3.3.2 REGARDING STEAM FLOW ISOLATION ON HIGH STEAM FLOW (EPID L-2017-LLA-0428)

Dear Ms. Gayheart:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 221 to Renewed Facility Operating License No. NPF-2 and Amendment No. 218 to Renewed Facility Operating License No. NPF-8 for the Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2, respectively. The amendments are in response to your application dated December 21, 2017, as supplemented on June 7, 2018.

The amendment changes Technical Specification {TS) 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation," by adding TS Actions that allow time to restore one high steam flow channel per steam line to Operable status before requiring a unit shutdown in the event two channels in one or more steam lines are discovered inoperable due to the trip setting not within Allowable Value.

C. Gayheart 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, Shawn A. Williams, Senior 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. 221 to NPF-2

2. Amendment No. 218 to NPF-8

3. Safety Evaluation Cc: 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. 221 Renewed License No. NPF-2

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

A. The application for amendment to the Joseph M. Farley Nuclear Plant, Unit 1, (the facility), Renewed Facility Operating License No. NPF-2, filed by Southern Nuclear Operating Company, Inc. (the licensee), dated December 21, 2017, as supplemented by letter dated June 7, 2018, 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.

Enclosure 1

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.C.(2) Technical Specifications The Technical Specifications contained in Appendix A. as revised through Amendment No. 221, are hereby incorporated in the renewed 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 Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: November 7, 2018

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SOUTHERN NUCLEAR OPERATING COMPANY ALABAMA POWER COMPANY DOCKET NO. 50-364 JOSEPH M. FARLEY NUCLEAR PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 218 Renewed License No. NPF-8

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

A. The application for amendment to the Joseph M. Farley Nuclear Plant, Unit 2, (the facility), Renewed Facility Operating License No. NPF-8, filed by Southern Nuclear Operating Company, Inc. (the licensee), dated December 21, 2017, as supplemented by letter dated June 7, 2018, 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.

Enclosure 2

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

2.C.(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 218, are hereby incorporated in the renewed 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 Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: November 7, 2 O1 8

ATIACHMENT TO JOSEPH M. FARLEY NUCLEAR PLANTS UNITS 1 AND 2 LICENSE AMENDMENT NO. 221 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-2 DOCKET NO. 50-348 AND LICENSE AMENDMENT NO. 218 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-8 DOCKET NO. 50-364 Replace the following pages of the Renewed Facility Operating Licenses and Appendix "A" Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove License License NPF-2, page 4 NPF-2, page 4 NPF-8, page 3 NPF-8, page 3 TSs TSs 3.3.2-6 3.3.2-6 3.3.2-7 3.3.2-7 3.3.2-8 3.3.2-8 3.3.2-11 3.3.2-11

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 221, are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications.

(3) Additional Conditions The matters specified in the following conditions shall be completed to the satisfaction of the Commission within the stated time periods following the issuance of the renewed license or within the operational restrictions indicated. The removal of these conditions shall be made by an amendment to the renewed license supported by a favorable evaluation by the Commission.

a. Southern Nuclear shall not operate the reactor in Operational Modes 1 and 2 with less than three reactor coolant pumps in operation.

b. Deleted per Amendment 13

c. Deleted per Amendment 2

d. Deleted per Amendment 2

e. Deleted per Amendment 152 Deleted per Amendment 2

f. Deleted per Amendment 158

g. Southern Nuclear shall maintain a secondary water chemistry monitoring program to inhibit steam generator tube degradation.

This program shall include:

1) Identification of a sampling schedule for the critical parameters and control points for these parameters;

2) Identification of the procedures used to quantify parameters that are critical to control points;

3) Identification of process sampling points;

4) A procedure for the recording and management of data;

5) Procedures defining corrective actions for off control point chemistry conditions; and Farley ~ Unit 1 Renewed License No. NPF-2 Amendment No. 221

(2) Alabama Power Company, pursuant to Section 103 of the Act and 10 CFR Part 50, "Licensing of Production and Utilization Facilities," to possess but not operate the facility at the designated location in Houston County, Alabama in accordance with the procedures and limitations set forth in this renewed license.

(3) Southern Nuclear, pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (4) Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5) Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

( 1) Maximum Power Level Southern Nuclear is authorized to operate the facility at reactor core power levels not in excess of 2775 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 218 are hereby incorporated in the renewed license.

Southern Nuclear shall operate the facility in accordance with the Technical Specifications.

(3) Deleted per Amendment 144 (4) Deleted per Amendment 149 (5) Deleted per Amendment 144 Farley - Unit 2 Renewed License No. NPF-8 Amendment No. 218

ESFAS Instrumentation 3.3.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME L. (continued) L.2 ------------NOTE-----------

One train may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for Surveillance testing, provided the other train is OPERABLE.

Restore train to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE status.

OR L.3.1 Be in MODE 3. 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months AND L.3.2 Be in MODE 5 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months M. ------------NOTES----------- M.1 ------------NOTE------------

1. Only applicable prior Only applicable when to steam flow channel below P-12 interlock.

normalization. --------------------------------

Verify one Manual Immediately

2. Only applicable within Initiation channel per 7 days after reaching steam line is 100% RTP following OPERABLE.

refueling.

AND One or more steam lines M.2 Restore one channel 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months with two channels per steam line to inoperable due to trip OPERABLE status.

setting not within Allowable Value.

Farley Units 1 and 2 3.3.2-6 Amendment No. 221 (Unit 1)

Amendment No. 218 (Unit 2)

ESFAS Instrumentation 3.3.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME N. Required Action and N.1.1 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition M not OR met.

N.1.2 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND N.2 Isolate steam lines. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS

NO TE---------------------------------------------------------

Refer to Table 3.3.2-1 to determine which SRs apply for each ESFAS Function.

SURVEILLANCE FREQUENCY SR 3.3.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.2.2 Perform ACTUATION LOGIC TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.3 Perform MASTER RELAY TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.4 Perform COT. In accordance with the Surveillance Frequency Control Program SR 3.3.2.5 Perform TADOT. In accordance with the Surveillance Frequency Control Program Farley Units 1 and 2 3.3.2-7 Amendment No. 221 (Unit 1)

Amendment No. 218 (Unit 2)

ESFAS Instrumentation 3.3.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.2.6 -------------------------------NO TE-------------------------------

Verificatio n of setpoint not required.

Perform TADOT. In accordance with the Surveillance Frequency Control Program SR 3.3.2.7 -------------------------------NOTE-------------------------------

Th is Surveillance shall include verification that the time constants are adjusted to the prescribed values.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.2.8 Perform SLAVE RELAY TEST In accordance with the Surveillance Frequency Control Program SR 3.3.2.9 -------------------------------NOTE-------------------------------

Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after SG pressure is 2 1005 psig.

Verify ESFAS RESPONSE TIMES are within limit. In accordance with the Surveillance Frequency Control Program SR 3.3.2.10 -------------------------------NOTE------------------------------- ------------NO TE----------

Verification of setpoint not required. Only required when not

performed within previous 92 days.

Perform TADOT. Prior to reactor startup Farley Units 1 and 2 3.3.2-8 Amendment No. 221 (Unit 1)

Amendment No. 218 (Unit 2)

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 3 of 4)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER NOMINAL SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE TRIP FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE SETPOINT

4. Steam Line Isolation 1 per steam

a. Manual Initiation 1,2(d),3(d) line F SR 3.3.2.6 NA NA

b. Automatic 1,2(d),3(d) 2 trains G SR 3.3.2.2 NA NA Actuation Logic SR 3.3.2.3 and Actuation SR 3.3.2.8 Relays C. Containment 1,2(d), 3(d) 3 D SR 3.3.2.1 ,,; 17.5 psig 16.2 psig Pressure - High 2 SR 3.3.2.4 SR 3.3.2.7 SR 3.3.2.9

d. Steam Line 1,2(d),3(b)(d) 1 per steam D SR 3.3.2.1 2 575(C) psig sss(c) psig Pressure Low line SR 3.3.2.4 SR 3.3.2.7 SR 3.3.2.9

e. High Steam Flow 1,2(d),3(d) 2 per steam D,M SR 3.3.2.1 (e) (f) in Two Steam line SR 3.3.2.4 Lines SR 3.3.2.7 Coincident with 1,2(d),3(d) 1 per loop D SR 3.3.2.1 2 542.6°F 543°F Tavg - Low Low SR 3.3.2.4 SR 3.3.2.7 (b) Above the P-12 (Tavg - Low Low) interlock.

(c) Time constants used in the lead/lag controller are h 2 50 seconds and t2,,; 5 seconds.

(d) Except when one MSIV is closed in each steam line.

(e) Less than or equal to a function defined as t.P corresponding to 40.3% full steam flow below 20% load, t.P increasing linearly from 40.3% full steam flow at 20% load to 110.3% full steam flow at 100% load.

(f) Less than or equal to a function defined as t.P corresponding to 40% full steam flow between 0% and 20% load and then a t.P increasing linearly from 40% steam flow at 20% load to 110% full steam flow at 100% load.

Farley Units 1 and 2 3.3.2-11 Amendment No. 221 (Unit 1)

Amendment No. 218 (Unit 2)

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 221 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-2 AND AMENDMENT NO. 218 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-8 SOUTHERN NUCLEAR OPERATING COMPANY JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-348 AND 50-364

1.0 INTRODUCTION

By application dated December 21, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17355A516), as supplemented by letter dated June 7, 2018 (ADAMS No. ML18158A579), Southern Nuclear Operating Company, Inc., (SNC, the licensee) submitted a request to change the Joseph M. Farley Nuclear Plant (FNP or Farley), Units 1 and 2, Technical Specifications (TSs).

Specifically, the application requested a revision to TS 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation," by adding TS Actions that allow time to restore one high steam flow channel per steam line to Operable status before requiring a unit shutdown in the event two channels in one or more steam lines are discovered inoperable due to the trip setting not within Allowable Value.

On July 31, 2018, the U.S. Nuclear Regulatory Commission (NRG, or the Commission) staff proposed to determine that the amendment request involves no significant hazards consideration determination as published in the Federal Register on July 31, 2018 (83 FR 36971, 36977-78).

Enclosure 3

2.0 REGULATORY EVALUATION

2.1 Description of Proposed Changes TS 3.3.2 addresses Engineered Safety Feature Actuation System (ESFAS) instrumentation.

Limiting condition for operation (LCO) 3.3.2 requires the ESFAS instrumentation for each Function in Table 3.3.2-1 "Engineered Safety Feature Actuation System Instrumentation" to be operable. When one or more Functions with one or more required channels or trains inoperable, then TS 3.3.2 requires the licensee to enter the Condition referenced in Table 3.3.2-1 for the channels(s) or trains(s). The proposed amendment to the FNP Units 1 and 2 operating licenses would revise TS 3.3.2 by adding new TS Conditions M and N, as shown below, that allow time to restore one high steam flow channel per steam line to Operable status before requiring a unit shutdown in the event two channels in one or more steam lines are discovered inoperable due to the trip setting not within the Allowable Value.

CONDITION REQUIRED ACTION COMPLETION TIME M. --------------NOTES---------- M.1 ------------NOTES--------------

1. Only applicable prior Only applicable when below to steam flow channel P-12 interlock.

normalization. ------------------------------------

Verify one Manual Initiation Immediately

2. Only applicable within channel per steam line is 7 days after reaching OPERABLE.

100% RTP following refueling. AND M.2 Restore one channel per 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months One or more steam lines steam line to OPERABLE with two channels status.

inoperable due to trip setting not within Allowable Value.

N.' Required Action and N.1.1 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition M not OR met.

N.1.2 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND N.2 Isolate steam lines. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months In addition, the proposed change would link proposed TS 3.2.2 Condition M to Function 4.e, "High Steam Flow in Two Steam Line" of Table 3.3.2-1 as illustrated below:

Table 3.3.2-1 Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER NOMINAL SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE TRIP FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE SETPOINT

4. Steam Line Isolation

e. High Steam Flow 1, 2(d), 3(d) 2 per D,M SR 3.3.2.1 (e) {f) in Two Steam steam line SR 3.3.2.4 Lines SR 3.3.2.7 (d) Except when one MSIV {main steam isolation valve] is closed in each steam line.

(e) Less than or equal to a function defined as flP corresponding to 40.3% full steam flow below 20% load. flP increasing linearly from 40.3% full steam flow at 20% load to 110.3% full steam flow at 100% load.

(f) Less than or equal to a function defined as flP corresponding to 40% full steam flow between 0% and 20%

load and then a flP increasing linearly from 40% steam flow at 20% load to 110% full steam flow at 100%

load.

In its letter dated December 21, 2017, the licensee stated that the Allowable Value and Trip Setpoint for the Steam Line Isolation - High Steam Flow in Two Steam Lines Function specified in TS Table 3.3.2-1 (Function 4.e) are not changed by the proposed amendment and the high steam flow channels continue to be calibrated in accordance with surveillance requirements (SR) 3.3.2.7 and existing plant procedures. In its letter dated June 7, 2018, the licensee stated that the proposed amendment does not involve a physical change to the ESFAS, nor does it change the safety function of the ESFAS instrumentation or the equipment supported by the ESFAS instrumentation.

2.2 Reason for Proposed Changes The licensee stated that the proposed amendment is needed because normalization of the ESFAS High Steam Flow in Two Steam Lines Function channels cannot be performed until after steam flow scaling data has been obtained and could result in the channels not being within the proper instrument accuracy requiring the channels to be declared inoperable. Currently, there are no TS Actions provided for two high steam flow channels inoperable in one or more steam lines requiring application of LCO 3.0.3 and resulting in a unit shutdown. The licensee notes that previous events associated with normalization of the ESFAS High Steam Flow in Two Steam Lines Function channels have resulted in unnecessary unit shutdowns and Licensee Event Reports in accordance with 10 CFR 50.73.

2.3 Regulatory Review The NRC staff's guidance for review of TSs is in Chapter 16, Technical Specifications, of NUREG-0800, Revision 3, Standard Review Plan (March 2010) (ADAMS Accession No. ML100351425).

The following regulatory requirements are applicable to the proposed change:

Title 10 of the Code of Federal Regulation (10 CFR) Part 50.36, "Technical Specifications" Paragraph 10 CFR 50.36(a)(1) 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. A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications.

Paragraph 10 CFR 50.36(c}(2)(i): "Limiting conditions for operation" states, in part:

Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

The remedial actions, which are called "Action Statements" in most technical specifications, must provide "reasonable assurance" that the activities at issue will not endanger the health and safety of the public.

3.0 TECHNICAL EVALUATION

3.1 Background As described in Section 1.0 of the LAR Supplement dated June 7, 2018, Enclosure 1, "Revised Basis for Proposed Change," the steam flow transmitters associated with the High Steam Flow in Two Steam Lines (HSFITSL) function are calibrated each refueling outage using the instrument scaling tables based on previous operational steam flow scaling data. Following the initial post-refueling power ascension, the steam flow transmitters are normalized, as needed, utilizing beginning-of-cycle steam flow scaling data. The ESFAS HSFITSL channels normalization cannot be performed properly until the steam flow scaling data has been obtained and could result in the channels not being within the proper instrument accuracy requiring the channels to be declared inoperable. Following a refueling outage, the steam flow scaling process requires the final required flow measurement data to be recorded after reaching 100 percent Rated Thermal Power (RTP) and establishing steady state steam flow.

The existing Table 3.3.2-1, "Engineered Safety Feature Actuation System Instrumentation," of TS 3.3.2 requires the HSFITSL Coincident with Tavg - Low Low function to be Operable in Mode 1, 2, and 3 with the exception of when one main steam isolation valve (MSIV) is closed in each steam line. With one channel inoperable, Required Action 1.1 of TS 3.3.2, Condition I requires to place the affected channel in trip within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or being in Mode 3 within 78 hours9.027778e-4 days 0.0217 hours 1.289683e-4 weeks 2.9679e-5 months .

With multiple channels inoperable, LCO 3.0.3 is applied resulting in a unit shutdown since there are no TS Actions specified for two inoperable channels of the HSFITSL Coincident with Tavg - Low Low function in one or more steam lines.

3.2 Reactor Systems Evaluation The NRC staff has reviewed the proposed change to TS 3.3.2. Specifically, the NRC staff reviewed the proposed new actions M and N to confirm that all design basis accident analysis would continue to be met.

Isolation of the main steam lines provides protection in the event of a steam line break either inside or outside of containment. Rapid isolation of the steam lines limits the steam line break accident to the blowdown from, at most, one steam generator. The Farley Updated Final Safety Analysis Report (UFSAR), Section 15.4.2, "Major Secondary System Pipe Rupture" (ADAMS Accession No. ML17117A373), credits the trip of the fast-acting main steam line isolation valves after receipt of an emergency core cooling system (ECCS) or main steam line isolation signal on the following:

High steam flow in two out of three main steam lines (one of two per line) in coincidence with two out of three low-low reactor coolant system (RCS) average temperature signals.

Low steam line pressure signal in any two out of three steam lines.

Two out of three high-high (hi-2) containment pressure signals.

However, as noted in the Enclosure to the LAR, "regarding the three ESFAS steam line isolation functions, the UFSAR does not explicitly define the primary and backup functions." Given these signals would occur at different times during a steam line break, in a request for additional information (RAI) No. 3, dated May 1, 2018 (ADAMS Accession No. ML18087A146), the NRC staff requested the licensee to discuss how the UFSAR, Chapter 15 safety analyses acceptance criteria will be met if the high steam flow trip does not occur within the time expected, or does not occur at all, during a design basis event.

In its letter dated June 7, 2018, the licensee clarified that although the high steam flow in two steam lines coincident with Tavg-Low Low ESFAS function does provide protection against a steam pipe rupture, the instrument function is not credited to isolate the steam lines in any accident or transient specified in UFSAR Chapter 15, including the full spectra of steam line breaks (SLBs) inside and outside containment. The licensee clarified that the main steam line break analysis shows a steam line isolation on the steam line pressure low function in two of three steam lines. The licensee noted that the main steam line break inside containment analysis assumes the high containment pressure function initiates a steam line isolation.

Additionally, for smaller steam line break sizes, the licensee states that ESFAS manual initiation signals are assumed to initiate a steam line isolation.

The NRC staff finds the licensee's response acceptable because the UFSAR Chapter 15 safety analyses acceptance criteria will not be affected by the proposed license amendment and will continue to be met if the high steam flow trip does not occur within the time expected, or does not occur at all, during a design basis event.

The Technical Specification Bases for Steam Line Isolation - Steam Line Pressure - Low, states that the "signal may be manually blocked by the operator below the P-12 setpoint," and that "Stuck valve transients and outside containment SLBs will be terminated by the Steam Line High flow in Two Steam Lines coincident with Tavg Low- Low signal for Steam Line Isolation below P-12 when SI has been manually blocked." Given that the proposed change to the technical specifications would allow all high steam flow channels to be inoperable, the staff asked the licensee (RAI No. 4) to provide a discussion on how stuck valve transients and

outside containment steam line breaks below the P-12 setpoint will be terminated if the steam line high flow channels are inoperable.

In its letter dated June 7, 2018, the licensee responded that stuck valve transients and outside containment steam line breaks below P-12 will be terminated by the ESFAS Manual Initiation channels when one or more steam line high flow instrumentation channels are inoperable, and when the steam line pressure-low signal is manually blocked. The licensee proposed new action M.1 to immediately verify that one manual initiation channel per steam line is operable when below the P-12 interlock to ensure manual initiation capability is available to isolate the steam lines if the steam line high flow instrumentation is not available. The licensee stated that verification may be performed as an administrative check and is not necessary to perform the surveillances needed to demonstrate the operability of the manual initiation channels. If the operability of at least one required manual initiation channel in each steam line cannot be verified, proposed Condition N must be immediately entered which requires the reactor be placed into either Mode 2 or Mode 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to isolate the steam lines within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The NRC staff finds the licensee's response acceptable and finds new action M.1 to confirm that a manual initiation channel is available when the other channels are either inoperable or manually blocked is appropriate. The NRC staff also finds new Condition N appropriate as it requires the unit to be placed in either Mode 2 or Mode 3 when at least one channel per steam line has not been made OPERABLE. In either of these two modes, a steam line break transient can be terminated by manual initiation of the steam line isolation function. The completion times for these conditions are appropriate and consistent with other actions to bring the unit to the different modes.

UFSAR Section 7.3.2.9.2, "Steam Break Protection" (ADAMS Accession No. ML17117A370) notes that the ESFAS instrumentation actuates the ECCS in order to protect the core against steam line breaks. The licensee stated that the major secondary system pipe rupture bounds minor secondary system pipe breaks and the accidental opening of a secondary system steam dump, relief, or safety valve. Given a high steam line differential pressure or low steam line pressure, an ESFAS actuation signal is generated which actuates the ECCS for a steam line break in order to prevent damage to the core. In addition, a reactor trip would be initiated from either an overpower trip or an ESFAS safety injection signal and core reactivity is further reduced by the highly borated water injected by the ECCS. Additional protection against the effects of an SLB accident is provided by feedwater isolation, which occurs upon actuation of the ECCS. The proposed changes to the technical specifications for the high steam flow channel does not alter any of these other ESFAS signals. Therefore, the NRC staff finds that the acceptance criteria for a steam line break would still be met with the proposed changes to the technical specifications.

NRC Staff Conclusion The proposed changes modify the remedial actions (i.e., Conditions, Required Actions (RAs) and completion times) applicable to the high steam flow in two steam lines coincident with Tavg-Low Low of the ESFAS Instrumentation in TS 3.3.2. The NRC staff concludes that the acceptance criteria for all design basis steam line breaks continue to be met and that there is reasonable assurance that the changes will not endanger the health and safety of the public.

3.3 Instrumentation and Control Evaluation According to the LAR and its supplement, the steam line isolation is provided by the following ESFAS instrumentation functions:

Steam Line Isolation - High Steam Flow in Two Steam Lines Coincident with Tav 9 - Low Low,

Containment Pressure - High 2, and

Steam Line Pressure Low.

These functions initiate closure of the MS IVs during a SLB accident or inadvertent opening of a steam generator (SG) relief or safety valve, to maintain at least one unfaulted SG as a heat sink for the reactor and to limit the mass and energy release to containment from a rupture inside containment. Safety injection is also initiated by the Steam Line Pressure Low function. The Steam Line Pressure Low function consists of three pressure channels, one per steam line, arranged in a two-out-of-three logic and may be manually blocked by the operator below the ESFAS Tavg Low Low (P-12) interlock setpoint.

The high steam flow channels provide input to the ESFAS main steam line isolation logic circuitry. The main steam flow transmitters associated with each SG measure the flow by measuring the differential pressure {Lip) across the flow restrictor that is an integral part of each SG. Two steam line flow transmitters in each steam line provide input to the ESFAS steam line flow channels. The steam line flow channels are combined in a one-out-of-two logic to sense high steam flow in one steam line. Steam line isolation on high steam flow in two steam lines results from a single steam line fault due to the increased steam flow in the remaining intact steam lines. The increased steam flow in the remaining intact lines actuates the required high steam flow MSIV isolation. The Steam Line Isolation - High Steam Flow in Two Steam Lines function actuates on one-out-of-two logic in any two of three steam lines coincident with a T avg - Low Low actuation on one-out-of-one logic in any two of three RCS loops.

To ensure that the high steam flow channels associated with Function 4.e of Table 3.3.2-1 accurately track with steam line flow following a refueling outage, the measured steam flow scaling data is compared to the predicted steam flow scaling data derived from previous operating cycles. Following the comparison, high steam flow channel adjustment may be required to normalize the channels with the measured steam flow scaling data. Prior to channel normalization, the trip setting of the steam flow transmitters may not be calibrated to within the required as-found tolerance band based on the new measured steam flow scaling data. This could result in the channel trip setting being less conservative than the Allowable Value, thus rendering the associated channel inoperable.

In its LAR and supplement, the licensee provided the evaluation of the proposed change as summarized below.

Proposed Condition M The proposed Condition M provides time to complete the channel normalization of multiple channels to restore at least one channel in each steam line to OPERABLE status. Restoring the channels to OPERABLE status includes ensuring the channel trip setting is adjusted to within the as-left tolerance band of the Trip Setpoint based on the normalized steam flow scaling data and the channel is not otherwise known to be incapable of performing its function.

The HSFITSL Coincident with Tavg - Low Low function is not credited to isolate the steam lines in any accident or transient specified in UFSAR Chapter 15, including the full spectra of SLBs inside and outside containment. The Containment Pressure - High 2, Steam Line Pressure Low, and Manual Initiation functions continue to provide steam line isolation protection during an SLB accident, which also bounds minor secondary system pipe breaks and the accidental opening of a secondary system steam dump, relief, or safety valve. Therefore, the potential failure of the HSFITSL Coincident with Tavg - Low Low function to close the MSIVs during this time period due to channel inaccuracies associated with the steam flow instrumentation has been determined to be of low risk significance and the proposed condition does not represent a loss of a safety function assumed in the accident analysis as described in TS 5.5.15, "Safety Function Determination Program (SFDP)."

According to the licensee, the proposed Completion Time (48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ) to restore one channel per steam line to OPERABLE status is acceptable because steam line isolation protection continues to be provided by the ESFAS instrumentation assumed in the safety analysis (i.e., the Containment Pressure- High 2 and the Steam Line Pressure Low Functions).

The NRC staff noted that relying on the Containment Pressure - High 2 and Steam Line Pressure Low functions for providing the steam line isolation protection during an SLB accident when one or more HSFITSL is (are) inoperable reduces the defense-in-depth of the ESFAS instrumentation functions, especially when one or more Containment Pressure - High 2 and Steam Line Pressure Low channels of each steam line is (are) inoperable. Thus, the NRC staff requested the licensee to provide a discussion on why the proposed change to TS 3.3.2 is acceptable if one or more Steam Line Pressure Low instrument channels becomes inoperable.

In its letter dated June 7, 2018, the licensee responded that with one Steam Line Pressure Low instrument channel inoperable, steam line isolation on a low steam line pressure signal can still occur because the Steam Line Pressure Low instrument channels are arranged in a two-out-of-three logic configuration. Currently, TS 3.3.2 Actions allow continued operation with multiple ESFAS channels inoperable and do not require additional restriction when channels of other ESFAS functions are inoperable, provided the number of channels in a trip function can continue to perform the safety function. The licensee further stated that action to verify that sufficient channels of Steam Line Pressure Low and Containment Pressure - High 2 functions are Operable is not necessary because currently LCO 3.0.3 is entered when the number of Operable channels are insufficient to provide steam line isolation capability irrespective of the status of the high steam flow channels. When the number of inoperable channels associated with an ES FAS function results in a loss of the associated trip function, the unit may be outside the safety analysis.

The NRC staff found the licensee's response acceptable because it adequately addressed the staff's concern, in particular that (a) the current TS 3.3.2 allows continued operation with multiple ESFAS channels inoperable, (b) the two-out-of-three logic configuration of the Steam Line Pressure Low instrument channels allows the steam line isolation on a low steam line pressure signal to occur with one Steam Line Pressure Low instrument channel inoperable, and (c) when the number of inoperable ESFAS channels results in a loss of the associated trip function, LCO 3.0.3 will be entered.

With regard to the limitation of the proposed change, Note 2 of proposed Condition M indicates that this condition is only applicable within 7 days after reaching 100 percent RTP following refueling. The staff noted that the 7 day allowance (168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months ) is longer than time required to normalize the affected channels of the High Steam Flow in Two Steam Lines with the measured

steam flow scaling data (80 hours9.259259e-4 days 0.0222 hours 1.322751e-4 weeks 3.044e-5 months based on operating experience) and 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months completion time to restore one channel per steam line to OPERABLE status (totaling 128 hours0.00148 days 0.0356 hours 2.116402e-4 weeks 4.8704e-5 months ).

In its letter dated June 7, 2018, the licensee responded that the 7-day completion time allowance after reaching 100 percent RTP was chosen because it is consistent with the allowed time for SRs applicable to similar instrument channel normalizations. For example, Note 1 to SR 3.3.1.3 and Note 2 to SR 3.3.1.9. Other similar uses of a 7-day duration in TS include the Note to SR 3.4.1.4 and Note 2 to TS 3.6.2 Action A. In addition, the technical basis for the selection of the 7-day duration limit considers that the HSFITSL Coincident with Tavg- Low Low ESFAS function is not credited to isolate the steam lines in any accident or transient specified in FSAR Chapter 15, including the full spectra of SLBs inside and outside containment. Therefore, providing sufficient time to determine if channel normalization is needed and performing channel calibrations as required offsets initiating an unnecessary plant transient.

The licensee explained the reasons for the TS using the following TS Bases:

FNP TS Bases B 3.3.1, Note 2 of SR 3.3.1.3 specifies that that the surveillance is required only if reactor power is ~ 50% RTP and that 7 days are allowed for performing the surveillance and channel adjustment for the incore detector. Note 2 of SR 3.3.1.9 specifies that this surveillance ( calibration of the excore channels to the incore channels) is required only if reactor power is ~ 50% RTP and that 7 days are allowed for completing the surveillance after reaching 50% RTP. This note further states that based on operating experience, a time allowance of 7 days for test performance, data analysis, and channel adjustments is sufficient.

FNP TS Bases B 3.4.1, the Note in SR 3.4.1.4 states that the SR (verifying the RCS total flow rate within the limits) is not required to be performed until 7 days after~ 90% RTP.

This note further states that this exception is appropriate since the heat balance and elbow tap measurement methods both require the plant to be at a minimum of 90% RTP to obtain the stated RCS flow accuracies.

Based on the NRC staff review of the LAR, the supplement, the FNP TS, and the FNP TS bases, the NRC staff finds that the proposed 7-day allowed time to normalize the affected channels of the HSFITSL provides reasonable assurance of public health and safety, and, therefore, is acceptable.

Proposed Condition N As described in the LAR, if one required manual initiation channel in one or more steam lines is discovered inoperable concurrent with Condition M when below the P-12 interlock or the inoperable high steam flow channels cannot be restored to Operable status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , proposed Action N requires the unit to be placed in either Mode 2 or 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and the steam lines isolated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

According to the licensee, the proposed Completion Time (6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ) is reasonable, based on operating experience, to reach Mode 2 or Mode 3 from full power conditions in an orderly manner and without challenging plant systems. The proposed Completion Time (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) is reasonable to isolate all the steam lines with at least one MSIV closed in each steam line. In Mode 2 or 3 with at least one MSIV closed in each steam line (i.e., steam lines isolated), the HSFITSL function (Function 4.e) is no longer required to be Operable. These Completion

Times (i.e., 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) are similar to other TS Actions requiring a unit shutdown to Mode 2 or 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and Mode 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Based on the NRC staff review of the LAR, the supplement, the FNP TS, and the FNP TS bases, the NRC staff finds that the proposed Condition N's required actions are appropriate and their completion time provides reasonable assurance of public health and safety when Condition M's completion time is not met, and, therefore, is acceptable.

NRC Staff Conclusion The NRC staff has reviewed the licensee's application related to the TS revision to allow additional time to restore one high steam flow channel per steam line to Operable status before requiring a unit shutdown in the event two channels in one or more steam lines are discovered inoperable due to the trip setting not within Allowable Value. Based on the information provided in the LAR and RAI responses, and staff's review of the licensee's TS and TS Bases, the staff found that the licensee's proposed changes provides reasonable assurance of public health and safety because the proposed change does not physically alter the plant equipment and safety function of the ESFAS instrumentation or the equipment supported by the ESFAS instrumentation, and the proposed change does not change the affected equipment's setpoint and its calibration method. Therefore, the NRC staff concludes that licensee's proposed change is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the State of Alabama official was notified of the proposed issuance of the amendments on October 15, 2018. On October 19, 2018, the State official confirmed that the State of Alabama had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to the 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 published in the Federal Register on July 31, 2018 (83 FR 36971, 36977-78). 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) there is reasonable assurance that 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 to the health and safety of the public.

Principal Contributors:

R. Beaton, NRR K. Nguyen, NRR Da~: November 7, 2018

C. Gayheart

SUBJECT:

JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS RE: TECHNICAL SPECIFICATION 3.3.2 REGARDING STEAM FLOW ISOLATION ON HIGH STEAM FLOW (EPID L-2017-LLA-0428)

DATED NOVEMBER 7, 2018 DISTRIBUTION:

PUBLIC RidsRgn2MailCenter Resource RidsNrrLAKGoldstein Resource RidsNrrDssStsb Resource RidsACRS_MailCTR Resource RidsNrrPMFarley Resource KNguyen, NRR DRahn, NRR RBeaton, NRR MChernoff, NRR ADAMS A ccess1on No.: ML18271A207 *B,ymemo OFFICE NRR/DORL/LPL2-1 /PM NRR/DORL/LPL2-1 /LA NRR/DSS/SRXB/ABC NRR/DE/EICB NAME SWilliams KGoldstein JWhitman* DRahn DATE 9/27/18 10/12/18 9/8/18 9/5/18 OFFICE NRR/DSS/STSB OGC/NLO NRR/DORL/LPL2-1 /BC NRR/DORL/LPL2-1 /PM NAME MChemoff for DRoth MMarkley SWilliams VCusumano DATE 10/16/18 10/30/18 11/2/18 11/7/18 OFFICIAL RECORD COPY

v t e Letter Sequence Approval
EPID:L-2017-LLA-0428, Plant Shutdown Required by Technical Specifications due to Inoperable Steam Flow Transmitters, LER 16-007-01 for Joseph M. Farley, Unit 1, Regarding Plant Shutdown Required by Technical Specifications due to Inoperable Steam Flow Transmitters (Approved, Closed)
Initiation Request, Request Acceptance Supplement Administration Questions 1 May 2018 Answers Results Approval Other:
MONTHYEAR2018-01-18 [Table View]

ML18271A207

Text

SUBJECT:

Dear Ms. Gayheart:

Enclosures:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

SUBJECT:

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