ML20212C583
| ML20212C583 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 09/15/1999 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NEL-99-0323, TAC-MA1364, TAC-MA1365, NUDOCS 9909220036 | |
| Download: ML20212C583 (17) | |
Text
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. 0:ve Morey
' Southira Nuclxt Vice President Op: rating Compary,Inc. '
farley Project Post Othce Box 1295 Birmirgham. Alabama 35201 Tel 205 992.5131 SOUTHERN COMPANY September 15, 1999 p,,,gy,,3,,,,
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Docket Nos.:
50-348 NEL-99-0323 50-364
- U. S. Nuclear Regulatory Commission A'ITN: Document Control Desk
'. Washington, DC 20555 '
Joseph M. Farley Nuclear Plant License Amendments Application Regarding Conversion to the Improved Technical Specifications TAC NOS. MA1364 and MA1365 Ladies and Gentlemen:
In accordance with the provisions of 10 CFR 50.90, Southern Nuclear Operating Company (SNC), as the licensed operator for the Joseph M. Farley Nuclear Plant (FNP), hereby submits the enclosed application for amendment of the Facility Operating License Nos. NPF-2 for FNP Unit I and NPF-8 for Unit 2. This application is being submitted as requested in the August 6,1999 letter from the Nuclear Regulatory Commission. SNC is petitioning for the addition oflicense conditions to the existing Appendix C of the FNP Units 1 and 2 licenses. The license condition will commit SNC to tmnsfer certain current Technical Specification requirements into SNC-
. controlled documents, as described in a letter dated March 12,1998,as supplemented by letters dated April 24,1998; August 20,1998; November 20,1998; February 20,1999; April 30,1999; May 28,1999; June 30,1999; July 27,1999 and August 19,1999, previously submitted to the NRC and in the August 6,1999 draft NRC Safety Evaluation. Additionally, the license conditions will specify the schedule fo' performing new and revised Improved Technical Specifiaation (ITS) surveillances related to implementing the ITS.
Enclosure I contains the basis for the proposed license amendments. The supporting significant hazards evaluation pursuant to 10 CFR 50.91 is provided in Enclosure 2. Based upon the analysis provided, SNC has determined that the proposed changes to the Facility Operating License Nos.
NPF-2 and NPF-8 do not involve a significant hazards consideration as defined by 10 CFR 50.92.
SNC has also determined that the proposed license amendments will not significantly affect the
. quality of the human environment.
l The proposed amended license typed pages are included in Enclosure 3. The marked pages of the current licenses, which denote the proposed amendments, are provided in Enclosure 4.
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! ~ The Plant Operations Review Committee has reviewed and recommended approval of these proposed changes. A copy of these proposed changes is being sent to Dr. Donald E. Williamson, the Alabama State Designee, in accordance with 10 CFR 50.91(b)(1).
9909220036 990915 90R ADOCK 05000348 9
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U.S. Nuclear Regulatory Commission Page 2 If there are any questions, please advise.
Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY fN Dave Morey Sworn to andsubscribed re me this /
day of _
1999 Y////djYL nb r
'K Ootary Pd>lW My Commission Expires:f l> S00l C.
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Enclosures:
- 1. Basis for Proposed License Amendment 2.
10 CFR 50.92 Evaluation l
- 3. Proposed Amended Typed Pages of FNP Licenses
- 4. Marked Pages of the Current Licenses cc:
See next page.
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U.S. Nuclear Regulatory Commission Page 3 j
cc:
Southern Nuclear Operatina Comnarly Mr. L. M. Stinson, General Manager - Farley U. S. Nuclear Regulatory Commission. Washington. D. C.
Mr. L. M. Padovan, Licensing Project Manager - Farley U. S. Nuclear Renulatory Commission. Recion 11 Mr. L. A. Reyes, Regional Administrator i
Mr. T. P. Johnson, Senior Resident inspector - Farley State of Alabama Dr. D. E. Williamson, State Department of Public IIcalth f
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ENCLOSURE 1 License Amendments Application Regarding Conversion to the improved Technical Specifications Basis for Proposed License Amendment The Joseph M. Farley Nuclear Plant (FNP) Unit I and Unit 2 have been operating with Technical Specifications (TS) issued with original operating licenses on June 25,1977, for Unit I and March 31, 1981, for Unit 2, as amended. Southern Nuclear Operating Company (SNC) proposed to amend Appendix A of Operating License Nos. NPF-2 and NPF-8 to completely revise the FNP TS by letter dated March 12,1998, as supplemented by Ictters dated April 24,1998; August 20,1998; November 20, 1998; February 20,1999; April 30,1999; May 28,1999; June 30,1999; July 27,1999 and August 19, 1999. The proposed amendment was based upon NUREG-1431, " Standard Technical Specifications -
Westinghouse Plants," Revision 1, dated April 1995, and upon guidance in the "NRC Final Policy Statement on Technical Specification Improvements for Nuclear Power Reactors" (Final Policy Statement), published on July 22,1993 (58 FR 39132). The overall objective of the conversion, consistent with the Final Policy Statement, was to rewrite, reformat, and streamline the TS for FNP to be in accordance with 10 CFR 50.36.
The NRC staffs Improved Technical Specifications (ITS) review evaluated changes to Current Technical Specifications (CTS) that fall into five categories, as defined by SNC: administrative changes, technical changes - more restrictive, technical changes - less restrictive (specific), technical changes - less restrictive (generic), and relocated specifications. These categories include an evaluation of the adequacy of existing regulatory requirements for controlling future changes to conditions removed from the CTS and placed in SNC-controlled documents. Through documented clarifications and SNC provided additional information, it is SNC's understanding that the NRC staff has found that the submittals provide sufficient detail to allow the staff to reach the conclusion that SNC's proposed changes are adequate and acceptable.
To ensure that the appropriate specifications are relocated *o SNC-controlled documents, as described in the corresponding significant hazards evaluations, and to specify the schedule for performing new and revised ITS surveillances, SNC is requesting that Appendix C to NPF-2 and NPF-8 reflect documented commitments to this effect.
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ENCLOSURE 2 License Amendments Application Regarding Conversion to the Improved Technical Specifications 10 CFR 50 92 Evaluation Pursuant to 10 CFR 50.92, each application for amendment to an operating license must be reviewed to determine if the proposed change involves a significant hazards consideration. The amendment, as dermed below, describing the proposed amendment to Facility Operating License Nos. NPF-2 and NPF-8, has been reviewed and deemed not to involve a significant hazards consideration. The basis for this determination follows.
BACKGROUND The Joseph M. Farley Nuclear Plant (FNP) Unit I and Unit 2 have been operating with Technical Specifications (TS) issued with original operating licenses on June 25,1977, for Unit I and March 31, 1981, for Unit 2, as amended. Southern Nuclear Operating Company (SNC) proposed to amend Appendix A of Operating License Nos. NPF-2 and NPF-8 to completely revise the FNP TS by letter dated March 12,1998, as supplemented by letters dated April 24,1998; August 20,1998; November 20, 1998; February 20,1999; April 30,1999; May 28,1999; June 30,1999; July 27,1999 and August 19, 1999. The proposed amendment was based upon NUREG-1431, " Standard Technical Specifications -
Westinghouse Plants," Revision 1, dated April 1995, and upon guidan, e in the "NRC Final Policy Statement on Technical Specification Improvements for Nuclear Power Reactors" (Final Policy Statement), published on July 22,1993 (58 FR 39132). The overall objective of the conversion, consistent with the Final Policy Statement, was to rewrite, reformat, and streamline the TS for FNP to be in accordance with 10 CFR 50.36.
The NRC staffs Improved Technical Specifications (ITS) review evaluated changes to Current Technical Specifications (CTS) that fallinto five categories, as defined by SNC: administrative changes, technical changes - more restrictive, technical changes - less restrictive (specific), technical changes - less restrictive (generic), and relocated specifications. These categories include an evaluation of the adequacy of existing regulatory requirements for controlling future changes to conditions removed from the CTS and placed in SNC-controlled documents. Through documented clarifications and SNC provided additional information, it is SNC's understanding that the NRC staff has found that the submittals provide sufficient detail to allow the staff to reach the conclusion that SNC's proposed changes are adequate and acceptable.
DESCRIPTION OF CHANGE REOUEST To ensure that the appropriate specifications are relocated to SNC-controlled documents, as described in the corresponding significant hazards evaluations, and to specify the schedule for performing new and revised ITS surveillances related to implementing the !TS, SNC is requesting that Appendix C to NPF-2 and NPF-8 reflect documented commitments to this effect. This propsed amendment is being submitted as requested in the August 6,1999 letter from the Nuclear Regulatory Commission.
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ANALYSIS When requirements have been shown to give little or no safety benefit, their removal from the TS may be appropriate. In most cases, relaxations previously granted to individual plants on a plant-specific basis were the result of(l) generic NRC actions, (2) new staff positions that have evolved from technological advancements and operating experience, or (3) resolution of the Owners Group'r comments on the Standard Technical Specifications (STS). Generic relaxations contained in STS have been found to be acceptable because they are consistent with current licensing practices and the Commission's regulations.
The FNP design has been reviewed to determine if the specific design basis and licensing basis are consistent with the technical basis for the model requirements in STS, and thus provide a basis for frS significant number of changes to the CTS involved the removal of specific requirenants and detalk information from individual specifications evaluated to be one of four types: 1) Details of system mign and system description including design limits; 2) Descriptions of systems operation; 3) Procedual details for requirements and related reporting problems; and 4) Administrative requirements redundan: to regulations.
The Final Policy Statement states that LCOs and associated requirements that do not satisfy or fall within the specified criteria may be relocated from existing TS (an NRC-controlled document) to appropriate licensee-centrolled documents. In its application, SNC proposed relocating such specifications to the FSAR (which includes the Technical Requirements Manual, by reference). The SNC submittals have been reviewed to ensure that the relocation of these requirements to the FS AR is acceptable, in that changes to these documents will be adequately controlled by 10 CFR 50.59. These provisions will continue to be implemented by appropriate plant procedures (i.e., operating procedures, maintenance procedures, surveillance and testing procedures, and work control procedures). Other licensee-controlled documents contain provisions for making changes consistent with other applicable regulatory requirements: for example, the ODCM can be changed in accordance with ITS 5.5.1, the emergency plan implementing procedures (EPIPs) can be changed in accordance with 10 CFR 50.54(q); and the administrative instructions that implement the QA Plan (including CTS 6.2.3 Safety Audit and Engineering Review Group, CTS 6.5 Review and Audit, CTS 6.8.2 Procedures, and CTS 6.10 Record Retention administrative control requirements) can be changed in accordance with 10 CFR 50.54(a) and i
10 CFR Part 50, Appendix B. Temporary procedure changes are also controlled by 10 CFR 50.54(a).
Because the Significant IIazards Evaluations contained in the ITS conversion documentation address the CTS relocations, it is not necessary to do so individually here; however, the proposed license amendment will definitively ensure that the relocation of the appropriate information is completed.
Additionally, the schedule for performing new and revised Surveillance Requirements associated with the implementation ofITS is outlined in Appendix C to the licenses. The addition of these commitments in j
the FNP licenses provide definitive assurance that the commitments to perform the Surveillance Requirements associated with the implementation ofITS are met.
10 CFR 50.92 EVALUATION CONCLUSIONS Based on the preceding evaluation, the following conclusions are provided with respect to the criteria contained in 10 CFR 50.92.
(1)
The proposed changes do not significantly increase the probability or consequences of an accident previously evaluated in the FSAR. The relocated CTS are not required to be in the TS under 10 CFR 50.36 and do not meet any of the four criteria in the Final Policy Statement. They are not needed to obviate the possibility that an abnormal situation or event will give rise to an immediate threat to the public health and safety. In addition, sufficient regulatory controls exist E2-2
to maintain the effect of the provisions in these specifications. This is the subject of a license condition. Until incorporated in the FSAR and procedures, changes to these specifications, information, and requirements will be controlled in accordance with the applicable current procedures that control these documents. Accordingly, these specifications, information, and requirements may be relocated from CTS and placed in the FSAR or other SNC-controlled documents. Also, the schedule to perform the Surveillance Requirements associated with the implementation oflTS does not significantly increase the probability or consequences of an accident previously evaluated in the FSAR. There is no change in the FNP design basis as a result of this change, and therefore, this change does not involve a significant increase in the consequences of an accident previously evaluated.
I (2)
The proposed changes to the TS do not increase the possibility of a new or different kind of l
accident than any accident already evaluated in the FS AR. No new limiting single failure or accident scenario has been created or identified due to the proposed changes. Safety-related systems will continue to perform as designed. The proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.
l (3)
The proposed changes de not involve a significant reduction in the margin of safety. There is no impact in the acciden; analyses. The relocated TS are not needed to obviate the possibility that an abnormal situation or event will give rise to an immediate threat to the public health and safety Likewise, the schedule to perform the Surveillance Requirements associated with the implementation oflTS does not affect the margin of safety. Thus the proposed changes do not involve a significant r~iuction in the margin of safety.
Accordingly, SNC has determined that the proposed amendments to the Facility Operating License Nos.
NPF-2 and NPF-8 do not involve a significant hazards consideration.
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ENCLOSURE 3 Joseph M. Farley Nuclear Plant Conversion to the Improved Technical Specifications Proposed Amended Tyned Paces of FNP Licenses I
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i APPENDIX C ADDITIONAL CONDITIONS j
OPERATING LICENSE NO. NPF-2 Southern Nuclear Operating Company, Inc. (SNC), shall comply with the following conditions on the schedules noted below-
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Amendment Condition Completion i
Number Additional Condition Date i
137 SNC shall complete classroom and simulator training Prior to Unit 2 entering for operations crews as described in SNC's letter Mode 2 from the I
dated September 22,1997, and evaluated in the staff's spring 1998 refueling Safety Evaluation dated April 29,1998.
outage 137 SNC shall complete final simulator modifications in Two years after restart accordance with ANSl/ANS 3.5-1985 and review from the Unit 1 fall results of the Cycle 16 startup testing to determine 1998 refueling outage any potential effects on operator training as described in SNC's letter dated September 22,1997, and evaluated in the staffs Safety Evaluation dated April 29,1998.
137 SNC shall provide a Steam Generator (SG) Tube Prior to the Unit 1 i
Rupture radiological consequences analysis that steam generator incorporates a flashing fraction, which is replacement outage appropriate for the Unit 1 design.
In spring 2000 i
SNC shall relocate certain Technical Specification Concurrent with the requirements to SNC-controlled documents, implementation of the Implementation of the Improved Technical Specifications improved Technical shall include relocating these certain technical Specifications specification requirements to the appropriate documents, as described in Table LA - Removal of Requirements from Retained Technical Specifications and Table R-Relocation of Technical Specifications, that are attached to the NRC staffs Safety Evaluation enclosed with this amendment.
CTS 6.2.3 Safety Audit and Engineering Review Group, CTS 6.5 Review and Audit, CTS 6.8.2 Procedures, and CTS 6.10 Record Retention administrative control requirements are incorporated verbatim into the QA Program.
The schedule for performing new and revised Concurrent with the Surveillance Requirements (SRs) shall be as follows:
implementation of the improved Technical 1.
For SRs that are new in this amendment the Specifications first performance is due at the end of the first surveillance interval that begins on the date of implementation of this amendment.
AMENDMElfr NO.
APPENDIX C ADDITIONAL CONDITIONS OPERATING LICENSE NO. NPF-2 Amendment Condition Completion Number Additional Condition Date 2.
For SRs that existed prit r to this amendment whose intervals of performance are being reduced, the first reduced surveillance intewal begins upon completion of the first surveillance performed afterimplementation of this amendment.
3.
For SRs that existed prior to this amendment that have modified acceptance criteria, the first performance is due at the end of the first surveillance interval that began on the date the surveillance was last performed prior to the implementation of this amendment.
4.
For SRs that existed prior to this amendment whose intervals of performance are being extended, the first extended surveillance interval begins upon completion of the last surveillance performed prior to implementation of this amendment.
2 AMENDMENT NO.
APPENDIX C ADDITIONAL CONDITIONS OPERAsTING LICENSE NO. NPF-8 Southern Nuclear Operating Company, Inc. (SNC), shall comply with the following conditions on the schedules noted below:
Amendment Condition Completion Number Additional Condition Date 129 SNC shall complete classroom and simulator training Prior to Unit 2 entering for operations crews and temporary simulator Mode 2 from the modifications as described in SNC's letter dated spring 1998 refueling September 22,1997, and evaluated in the staffs Safety outage Evaluation dated April 29,1998.
129 SNC shall review the results of the Cycle 13 startup Prior to Unit 1 startup I
testing to determine any potential effects on operator from the fall 1998 training and incorporate these changes into licensed refueling outage operator training as described in SNC's letter dat d September 22,1997, and evaluated in the staffs Safety Evaluation dated April 29,1998.
129 SNC shall provide a Steam Generator (SG) Tube Prior to the Unit 2 Rupture radiological consequences analysis that steam generator incorpurates a flashing fraction, which is replacement outage appropriate for the Unit 2 design.
In spring 2001 SNC shall relocate certain Technical Specification Concurrent with the requirements to SNC controlled documents.
implementation of the Implementation of the Improved Technical Specifications Improved Technical shall include relocating these certain technical Specifications specification requirements to the appropriate documents, as described in Table LA - Removal of Requirements from Retained Technical Specifications and Table R -
Relocation of Technical Specifications, that are attached to the NRC staffs Safety Evaluation enclosed with this amendment.
CTS 6.2.3 Safety Audit and Engineering Review Group, CTS 6.5 Review and Audit, CTS 6.8.2 Procedures, and CTS 6.10 Record Retention administrative control requirements are incorporated verbatim into the QA Program.
The schedule for performing new and revised Concurrent with the Surveillance Requirements (SRs) shall be as follows:
implementation of the Improved Technical
- 1. For SRs that are new in this amendment the first Specifications performance is due at the end of the first surveillance interval that begins on the date of
- implementation of this amendment.
AMENDMENT NO.
t APPENDIX C ADDITIONAL CONDITIONS OPERATING LICENSE NO, NPF-8 Amendment Condition Completion Number Additional Condition Date 2.
For SRs that existed prior to this amendment whose intervals of performance are being reduced, the first i
reduced surveillance interval begins upon completion of the first surveillance I
perfomled after implementation of this amendment.
3.
For SRs that existed prior to this amendment that have modified acceptance criteria, the first performance is due at the end of the first surveillance
' interval that began on the date the surveillance was last performed prior to the implementation of this amendment.
4.
For SRs that existed prior to this amendment whose intervals of performance are being extended, the first extended surveillance interval begins upon completion of the last surveillance performed priorto implementation of this amendment.
-2 AMENDMENT NO.
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l ENCLOSURE 4 Joseph M. Farley Nuc! car Plant Conversion to the Improved Technical Specifications Marked Paces of the Current Licenses l
APPENDIX C ADDITIONAL CONDITIONS OPERATING LICENSE NO. NPF-2 Southern Nuclear Operating Company, Inc. (SNC), shall comply with the following conditions on
' the schedules noted below:
Amendment Condition Completion Number Additional Condition Date 137 SNC shall complete classroom and simulator training Prior to Unit 2 entering for operations crews as described in SNC's letter Mode 2 from the dated September 22,1997, and evaluated in the staffs spring 1998 refueling Safety Evaluation dated April 29,1998.
outage 137 SNC shall complete final simulator modifications in Two years after restart accordance with ANSI /ANS 3.5-1985 and review from the Unit 1 fall results of the Cycle 16 startup testing to determine 1998 refueling outage any potential effects on operator training as described in SNC's letter dated September 22,1997, and evaluated in the staffs Safety Evaluation dated April 29,1998.
137 SNC shall provide a Steam Generator (SG) Tube Prior to the Unit 1 Rupture radiological consequences analysis that steam generator incorporates a flashing fraction, which is replacement outage INSERT appropriate for the Unit 1 design.
In spring 2000 SNC shall relocate certain Technical Specification Concurrent with the requirements to SNC-controlled documents, implementation of the implementation of the improved Technical Specifications Improved Technical I
shallinclude relocating these certain technical Specifications specifkation requirements to the appropriate documents, as described in Table L.A-Removal of Requirements from Retained Technical Specifications and Table R -
' Relocation of Technical Specifications, that are attached to the NRC staff's Safety Evaluation enclosed with this amendment.
CTS 6.2.3 Safety Audit and Engineering Review Group, CTS 6.5 Review and Audit, CTS 6.8.2 Procedures, and j
CTS 6.10 Record Retention administrative control requirements are incorporated verbatim into the QA Program.
The schedule for performing new and revised Concurrent with the Surveillance Requirements (SRs) shall be as follows:
implementation of the improved Technical
- 1. For SRs that are new in this amendment the first Specifications performance is due at the end of the first i
surveillance interval that begins on the date of implementation of this amendment.
AMENDMENT NO.447-
APPENDIX C ADDITIONAL CONDITIONS OPERATING LICENSE NO. NPF-2 1
1 Amendment Condition Completion Number Additional Condition Date 2.
For SRs that existed prior to this amendment whose intervals of performance are being reduced, the first INSERT reduced surveillance interval begins upon completion of the first surveillance t
performed afterimplementation of this amendment.
3.
For SRs that existed prior to this amendment that have modified acceptance criteria, the first performance is due at the end of the first surveillance Interval that began on the date the surveillance was last performed prior to the implementation of this amendment.
4.
For SRs that existed prior to this amendment whose intervals of performance are being extended, the first extended surveillance interval begins upon completion of the last surveillance performed prior to implementation of this
. amendment.
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-2 AMENDMENT NO. t&T i
APPENDlX C ADDITIONAL CONDITIONS OPEPATING LICENSE NO. NPF-8 Southem Nuclear Operating Company, Inc. (SNC), shall comply with the following conditions on the schedules noted below:
- Amendment Condition Completion Number Additional Condition Date 129.
SNC shall complete classroom and simulator training '
Prior to Unit 2 entering for operations crews and temporary simulator Mode 2 from the modifications as described in SNC's letter dated spring 1998 refueling i
September 22,1997, and evaluated in the staffs Safety outage Evaluation dated April 29,1998.
129
. SNC shall review the results of sthe Cycle 13 startup Priorto Unit i startup testing to determine any potential effects on operator from the fall 1998
- training and incorporate these changes into licensed refueling outage operator training as described in SNC's letter dated September 22,1997, and evaluated in the staffs Safety Evaluation dated April 29,1998.
129 SNC shall provide a Steam Generator (SG) Tube Prior to the Unit 2 Rupture radiological consequences analysis that steam generator incorporates a flashing fraction, which is replacement outage appropriate for the Unit 2 design.
In spring 2001 INSERT SNC shall relocate certain Technical Specification Concurrent with the requirements to SNC-controlled documents.
implementation of the implementation of the improved Technical Specifications improved Technical
- shall include relocating these cortain technical Specifications specification requirements to the appropriate documents, as described in Table LA - Removal of Requirements from Retained Technical Specifications and Table R -
Relocation of Technical Specifications, that are attached to the NRC staffs Safety Evaluation enclosed with this j
amendment.
CTS 6.2.3 Safety Audit and Engineering Review Group, CTS 6.S Review and Audit, CTS 6.8.2 Procedures, and l
CTS 6.10 Record Retention administrative control requirements are incorporated verbatim into the QA Program.
The schedule for performing new and revised Concurrent with the Surveillance Requirements (SRs) shall be as follows:
implementation of the
)
Improved Technical
- 1. For SRs that are new in this amendment the first Specifications performance is due at the end of the first surveillance interval that begins on the date of implementation of this amendment.
AMENDMENT NO. 430
r APPENDIX C ADDITIONAL CONDITIONS OPERATING LICENSE NO. NPF-8 Amendment Condition Completion Number Additional Condition Date 2.
For SRs that existed prior to this amendment whose intervals of performance are being reduced, the first INSERT reduced surveillance interval begins upon completion of the first surveillance performed afterimplementation of this amendment.
3.
For SRs that existed prior to this amendment that have modified acceptance criteria, the first performance is due at the end of the first surveillance interval that began on the date the surveillance was last performed prior to the implementation of this amendment.
4.
For SRs that existed prior to this amendment whose intervals of performance are being extended, the first i
extended surveillance interval begins upon I
completion of the last surveillance performed prior to implementation of this amendment.
-2 AMENDMENT NO.429-