ML20115E392

NRR E-mail Capture - Joseph M. Farley Nuclear Plant, Units 1 and 2 - Request for Additional Information Regarding TS 3.3.1 and TS 3.3.7 License Amendment Request

ML20115E392
Person / Time
Site:	Farley
Issue date:	04/24/2020
From:	Shawn Williams NRC/NRR/DORL/LPL2-1
To:	Coleman J Southern Nuclear Operating Co
References
L-2019-LLA-0278
Download: ML20115E392 (5)

Text

From:

Williams, Shawn Sent:

Friday, April 24, 2020 11:05 AM To:

Coleman, Jamie Marquess Cc:

Sparkman, Wesley A.

Subject:

Joseph M. Farley Nuclear Plant, Units 1 and 2 - Request for Additional Information Regarding TS 3.3.1 and TS 3.3.7 License Amendment Request (EPID No. L-2019-LLA-0278)

Attachments:

Farley TS 3.3.7 RAIs.docx

Dear Ms. Coleman,

By letter dated December 12, 2019, the Southern Nuclear Operating Company, Inc., submitted a license amendment request for the Joseph M. Farley Nuclear Plant, Units 1 and 2. The proposed amendment would revise Technical Specification (TS) 3.3.1, "Reactor Trip System (RTS) Instrumentation," and TS 3.3.7, "Control Room Emergency Filtration/Pressurization System (CREFS) Actuation Instrumentation."

The U.S. Nuclear Regulatory Commission staff has determined that the attached additional information is needed in order to complete its review. Please respond within 30 days of the date of this e-mail.

Sincerely, Shawn A. Williams, Senior Project Manager Plant Licensing Branch, II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364

Enclosure:

Request for Additional Information cc w/encl: Listserv

Hearing Identifier:

NRR_DRMA Email Number:

547 Mail Envelope Properties (BN8PR09MB3348F8F346D30E26E1300FF690D00)

Subject:

Joseph M. Farley Nuclear Plant, Units 1 and 2 - Request for Additional Information Regarding TS 3.3.1 and TS 3.3.7 License Amendment Request (EPID No.

L-2019-LLA-0278)

Sent Date:

4/24/2020 11:05:03 AM Received Date:

4/24/2020 11:05:05 AM From:

Williams, Shawn Created By:

Shawn.Williams@nrc.gov Recipients:

"Sparkman, Wesley A." <WASPARKM@southernco.com>

Tracking Status: None "Coleman, Jamie Marquess" <JAMIEMCO@SOUTHERNCO.COM>

Tracking Status: None Post Office:

BN8PR09MB3348.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 960 4/24/2020 11:05:05 AM Farley TS 3.3.7 RAIs.docx 66556 Options Priority:

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REQUEST FOR ADDITIONAL INFORMATION JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 LICENSE AMENDMENT REQUEST TECHNICAL SPECIFICATION (TS) 3.3.1 AND TS 3.3.7 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

DOCKET NOS. 50-348 AND 50-364 By letter dated December 12, 2019 (Agency-wide Documents Access and Management System (ADAMS) Accession No. ML19346E959), Southern Nuclear Operating Company (the licensee) submitted a license amendment request (LAR) for Joseph M. Farley Nuclear Plant, Units 1 and 2 (FNP). The LAR proposes to revise TS 3.3.1, "Reactor Trip System (RTS) and TS 3.3.7, "Control Room Emergency Filtration/Pressurization System (CREFS) Actuation Instrumentation."

Regulatory Criteria Paragraph 50.36(c)(3) of Title 10 of the Code of Federal Regulations (10 CFR), states that Surveillance Requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

Paragraph 50.36(c)(1)(ii)(A) of 10 CFR, states that limiting safety system settings (LSSS) are settings for automatic protective devices related to those variables having significant safety functions. This clause requires, in part, that where a LSSS is specified for a variable on which a safety limit has been placed, the setting be chosen so that automatic protective action will correct the abnormal situation before a safety limit is exceeded.

Appendix B, General Design Criteria, Criterion 19 states that a control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents. Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem whole body, or its equivalent to any part of the body, for the duration of the accident.

=

Background===

The licensee proposed to revise TS 3.3.7, "CREFS Actuation Instrumentation," to change the unit of measure associated with the trip setpoint of TS Table 3.3.7-1, Function 3, "Control Room Radiation Control Room Air Intake (R-35A, B)," from " 800 cpm" to an equivalent value of

" 1x10-5 µCi/cc" and add a footnote clarifying that the value represents radiation above background with no system flow. Page E-3 of the LAR states in part, The proposed change from 800 cpm to 1x10-5 µCi/cc results in equivalent control room ventilation isolation protection and is considered administrative. However, the licensee has not provided any documentation which explains this equivalency. The NRC performed an Audit during the week of April 13, 2020, on Farley calculation SM-SNC972214-001, Radiation Monitor Setpoints to review the calculations that confirm <800 cpm is equivalent to the proposed value of " 1x10-5 µCi/cc."

The U.S. Nuclear Regulatory Commission (NRC) staff has determined that the following additional information is needed.

RAI No. 1 As part of the Audit, the NRC staff reviewed Farley calculation SM-SNC972214-001 to confirm the proposed change from " 800 cpm" is equivalent to " 1x10-5 µCi/cc." Please submit, on the docket, the information contained on Sheets 19 and 20 under Basis Determination in the section titled R-35A/B (MCR Isolation) Setpoint. Please include the diagram on Sheet 19.

RAI No. 2 The LAR states on page E-3:

CREFS Control Room Air Intake Radiation Monitors Trip Setpoint Measurement Units 10 CFR 20, Appendix D defines the derived air concentration (DAC) as the airborne concentration of a given radionuclide, which, if breathed by the reference man for a working year of 2,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, would result in a committed effective dose equivalent of 5 rem or a committed dose equivalent of 50 rem to any individual organ or tissue. DAC values for occupational dose are listed in Table 1, Column 3, of Appendix B to 10 CFR 20. The predominant inhalation radionuclides released during a fuel handling accident (FHA) are Xenon (Xe) -133 and Krypton (Kr) -85 and the DAC value for each of these isotopes is 1.0E-04 µCi/ml, or 1.0E-04 µCi/cc.

It appears that the correct reference is to Appendix B rather than Appendix D, and that the stated definition of a derived air concentration is not consistent with the definition of a derived air concentration in 10 CFR 20.1003. Please confirm or correct the record of the Appendix referenced and the definition of a DAC.

In addition, Appendix B states that:

The DAC values relate to one of two modes of exposure: either external submersion or the internal committed dose equivalents resulting from inhalation of radioactive materials. Derived air concentrations based upon submersion are for immersion in a semi-infinite cloud of uniform concentration and apply to each radionuclide separately.

The Xe-133 and Kr-85 radionuclides are listed in 10 CFR 20, Appendix B in the Class column as a submersion radionuclide. Please correct the record or explain the basis for selecting the mode of exposure as an internal exposure rather than as an external submersion exposure.

RAI No. 3 The LAR proposes an administrative change to Table 3.3.7-1, Function 3. Control Room Radiation Control Room Air Intake (R-35A/B) by adding a footnote (c) to the Trip Setpoint value. Please explain the meaning of the proposed footnote (c) Above background with no flow and how it relates to the statement in SM-SNC972214-001 (sheet 12):

Per REA99-2094-02, the air sample flow through the detector chambers results in a pressure of ~0.9 atmospheric. The term no flow above indicates that the setpoints have not been corrected for this effect.