ML20217E153

From kanterella
Jump to navigation Jump to search
Summary of 970916 Meeting W/Southern Nuclear Operating Co, Inc in Rockville,Maryland Re Licensees Improved Std TS Conversion Application & Schedule for Submittal.List of Meeting Attendees & Meeting Handouts Encl
ML20217E153
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 09/25/1997
From: Jacob Zimmerman
NRC (Affiliation Not Assigned)
To:
NRC (Affiliation Not Assigned)
References
NUDOCS 9710060341
Download: ML20217E153 (51)
v • d • e


Text

..

t 6 September 25, 1997 LICENSEE: Southem Nuclear Operating Company, Inc.

FACILITY: Joseph M. Farley Nuclear Plant, Units 1 and 2

SUBJECT:

MEETING

SUMMARY

OF SEPTEMBER 16,1997 The U.S. Nuclear Regulatory Commission (NRC) held a meeting with Southern Nuclear Operating Company, Inc. (Southern Nuclear) on September 16,1997, at NRC headquarters in Rockville, Maryland. The purpose of the meeting was to discuss Southern Nuclear's improved Standard Technical Specification conversion application and schedule for submittal. In addition, NRC topics of discussion included review expectations, schedule, conversion screening checklist, and lessons learned from previous reviews.

Enclosed is a list of attendees and meeting handouts.

in accordance with Section 2.790 of NRC's " Rules of Practice," Part 2, Title 10 of the Code of Federal Reaulations. a copy of this meeting summary and ita enclosures will be placed in the NRC's Public Document Room.

Jacob 1. Zimmerman, Project Manager Project Directorate 11-2 Division of Reactor Projects - l/II Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364

Enclosures:

DISTRIBUTION 1, List of Attendees see next page

2. Meeting Handouts s 0

.{1'.

cc w/encis: See next page To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" =

Copy with attachment / enclosure "N" = No cop 9 OFFICE PM:PDlJW LA:PDili20 D$Qt1/2/

NAME JZirosef$an:cn LBerry \(D H$6rkoM DATE 7 /2fl97 (l 1-D97 \

q'/rfl97 / /97 DOCUMENT NAME: G:\FARLEY\lSTS\09-16. SUM OFFICIAL RECORD COPY 9710060341 970925 PDR ADOCK 05000348 P PDR n 7 'P n'"*m rm q "m* "mE " * " "

ll.. ll l.ill.l I.ll.lil. l.l

DISTRIBUTION FOR MEETING

SUMMARY

DATED: September 25, 1997 HARD CQP_Y 10echst File (M)t PUBLIC (w/encis)

PD 11-2 Rdg. (wlencis)

PMShimerlRtffU4)1 OGC (Encl.1 only)

ACRS (Encl.1 only)

E-MAIL (w/ Encl.1 only)

, S. Collins /F. Miraglia R. Zimmerman B. Boger H. Berkow J. Zimmerman L. Berry T. Martin (e-mail to SLM3)

P. Skinner, Ril T. Ross, Farley SRI, Ril M. Gamberoni, EDO (Rll Plants) cc: Licensee & Service List (with all enclosures)

., e sC CEQy p t- UNITE] STATES

  • }2 NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. en- =1

% , , , , , ** September 25, 1997 LICENSEE: Southem Nuclear Operating Company, Inc.

FACILITY: Joseph M. Farley Nuclear Plant, Units 1 and 2

SUBJECT:

MEETING

SUMMARY

OF SEPTEMBER 16,1997 The U.S. Nuclear Regulatory Commission (NRC) held a meeting with Southem Nuclear Operating Company, Inc. (Southem Nuclear) on September 16,1997, at NRC headquarters in Rockville, Maryland. The purpose of the meeting was to discuss Southom Nuclear's improved Standard Technical Specification conversion application and schedule for subrnitial. In addition, NRC topics of discussion included review expectations, schedule, conversion screening checklist, and lessons learned from previous reviews.

Enclosed is a list of attendees and meeting handouts.

in accordance with Section 2.790 of NRC's " Rules of Practice," Part 2, Title 10 of the Code of Fed 7al Reaulations. a copy of this meeting summary and its enclosures will be placed in the NRC's Public Document Room.

J

.h Q acob1. mmerman, Project Manager Project Directorate ll 2 Division of Reactor Projects-l/II Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364

Enclosures:

1. List of Attendees
2. Meeting Handouts cc w/encls: See next page

Joseph M. Farley Nuclear Plant cc:

Mr. R. D. Hill, Jr. Mr. D. N. Morey General Manager - Vice President - Farley Project Southern Nuclear Operating Southern Nuclear Operating Company Company, Inc.

Post Office Box 470 Ashford, Alabama 36312 . P. O. Box 1295 Birmingham, Alabama 35201 Mr. Mark Ajiuni, Ucensing Mant.ger Southern Nuclear Operating Company Post Office Box 1295 Birmingham, Alabama 35201 1295 Mr. M. Stanford Blanton Balch and Bingham Law Firm Post Office Box 306 1710 Sixth Avenue North Birmingham; Alabama 35201 -

Mr. J. D. Woodard Executive Vice President Southern Nuclear Operating Company Post Office Box 1295 Birmingham, Alabama 35201 State Health Officer Alabama Department of Public Health 434 Monroe Street Montgomery, Alabama 36130-1701 Chairman Houston County Commission Post Office Box 6406 Dothan, Alabama 36302 Regional Administrator, Region 11 U.S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth Street, S.W., Suite 23T85 Atlanta, Georgia 30303 Resident inspector U.S. Nuclear Regulatory Commission 7388 N. State Highway 95 Columbia, Alabama 36319

i LIST OF AT'2NDEES U.S. Nuclear Raoulatorv Commisalon H. Berkow, NRR Project Directorate ll-2, Director J. Zimmerman, NRR Project Directorate Il 2, Falisy Project Manager W. Beckner, NRR Technical Specification Branch, Branch Chief M. Reinhart, NRR Technical Specification Branch, Section Chief Southern Nuclear Ooeratino Comoany Mark Ajiuni, Farley Project, Licensing Manager Wes Sparkman, Farley Project, Licensing Engineer 9

9 Enclosure 1

Conversions to improved Standard Technical Specifications Meeting with Licensees e Review expectations for submittal o NEl 96-06, improved Technical Specifications Conversion Guidance o Attachment 1, NRC Recommended Conversion Application Guidelines o Current adjustments
  • Do not use unapproved TSTFs
  • Eliminate beyond scope issues
  • Realistic schedular expectations (9 to 12 months)
  • Amendment about a month prior to implementation: should know what ITS look like about three or more months before impleraentation
  • Conversion Review Process
  • License Conditions a Surveillance Requirements

^

s Control of Relocated items

  • Four or five copies of submittats e Screening Checklist e Ongoing communications o Primarily Project Manager (PM)
  • PM can coordinate other communications o Lead reviewer and section specific reviewers as appropriate o Technical branch reviewer if necessary e Example Safety Evaluation (SE) [ Robinson]

o Provide copy ,

o Discuss need to submit tables to support SE e Example of good conversion submittal o Susquehanna o Available in PDR e Listen to and address licensee comments Enclosure 2 t _ - _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ . _.

I I

( Conversion Screening Checklist * ..

i I I l Plant Name: Section: Section Lead:

1 l

l l QUESTION YES N'O COMMENTS l 1. Does the submittal include a CTS markup ancl associated DOCS, an STS markup and associated JFDs, and a clean copy of the proposed ITS?

2. Is the CTS markup legible, clearly marked, and easy to fol!ow?
3. Is the STS markup legible, clearly marked, and easy to follow? 4
4. After reading a sampling of the administrative change DOCS, does it appear that the licensee has correctly categorized these changes as administrative (i.e., there are no hidden technical changes)?
5. After reading a sampling of the less restrictive DOCS, does it appear that the licensee has provided adequate technical justification to support the less restrictive changes?
6. After reading a sampling of the less restrictive DOCS, does it appear that the licensee has identified all of the major beyond scope changes in the submittal cover letter?

1

Conversion Screening Checklist * .

QUESTION YES NO COMMENT

, 7. After reading a sampling of the more l restrictive DOCS, does it appear that the .

' licensee has provided a reason for adding the new requirement, other than simply stating that it is consistent with the STS?
8. After reading a sampling of the JFDs, does it appear that the licensee has adequately justified differences from the STS?
9. After reading a sampling of the JFDs, does it appear that the licensee has identified pending TSTF travelers and potentially new generic changes?
  • Desired restv3nse to all questions is "yes."

2

v,,-------,-- n - - - - - - - , - , - - - - - , , , - - - - - - - - - -

e i

ENCLOSURE 1 JOSEPH M. FARLEY NUCLEAR PLANT UNITS 1 AND 2 IMPROVED TECHNICAL SPECIFICATION CONVERSION CHAPTER 3.7 - PLANT SYSTEMS MARKUP OF CURRENT FARLEY TS (CTS)

FNP TS Conversion Enclosure 1 - Markup of Current FNP TS -

Chapter 3.7 - Plant Systems -

MARKUP OF CURRENT FARLEY NUCLEAR PLANT (FNP)

TECHNICAL SPECIFICATIONS (TS) CHAPTER 3.7 nis enclosure contains markups of the current FNP TS (CTS). A complete set of Unit 1 CTS is included. Unit 2 CTS pages are included only when a diference exists between the Unit 2 and corresponding Unit 1 TS that must be individuallyjustified. All changes marked on the Unit 1 CTS apply to the Unit 2 CTS unless a separate Unit 2 CTS page is included. A list of Unit 2 CTS pages containing information diferent than a correspondmg Unit 1 CTS is provided below, ne markup of the CTS pages identify the significant changes necessary to convert to the new Standard TS (STS) contained in NUREG 1431 Rev 1. In addition, the markup of the CTS identi6es (where appropriate) the new location of the CTS requirement. Due to the large diferences between the CTS and the STS in format and presentation, not all editorial and format changes are identified. Each significant change resulting from the conversion is assigned a Discussion of Change (DOC) number and a no Significant Hazards Evaluation (SHE) designator. De DOC for each numbered item is contamed in Enclosure 2. The SHE designator assigned to each change corresponds to a generic or speci6c SHE contained in Enclosure 3. A list of SHE designators is provided below. Each SHE is fully described in Enclosure 3.

Section 3.7 - List of Unit 2 CTS nanen with different TS reouiramante than the Unit 1 CTS 3/4 7 3 - His page contains unit specific valve numbers on Table 3.7-3. As the FNP implementation of the STS will present one table for both Units and this is not a technical issue, the applicable DOC for the Unit I markup addresses the change for Unit 2 as well. Herefore, no Unit 2 page is included.

3/4 7 5 - his page contains Unit specific valve numbers in the surveillances. As this is not a technical issue and the STS does not include valve numbers in the surveillances, the applicable DOC for the Unit I markup addresses the change for Unit 2 as well. Derefore, no Unit 2 page is included.

3/4 7 Surveillance 4.7.9.b on this page references Unit speci6c Amendment numbers. As the surveillance is being relocated from the TS consistent with the STS, the applicable Unit 1 DOC addresses the change for Unit 2 as well. Therefore, no Unit 2 page is included.

3/4 7 27 - His page only contains a list of previously deleted TS page numbers. He deleted page numbers referenced are diferent for Unit I and 2. At this point in TS section 3.7 the subsequent TS page numbers are difforent for each Unit. - As page numbering is not a technical issue, and all pages containing only references to deleted pages will be eliminated during the conversion, no Unit 2 page has been included in this Enclosure due to page numbering differences alone.

3/4 7-65&66 - Dese Unit 2 pages contain the Unit 2 specific Area Temperature Monitonna TS. His TS is not part of the Unit 1 CTS. As such, these pages have been included in this Enclosure after the last Unit 1 page (97). A separate DOC is included to address this Unit 2 specific TS. In addition, the applicable Unit 2 bases page fer the Area Temperature Moni.aring TS is also included at the end of the Unit 1 bases pages.

. Chapter 3.7 El-1 1/13/97

FNP TS Conversion Enclosure 1 Markup of Current FNP TS Chapter 3.7. Plant Systems SHE Desinnatars Descriotion A Admmistrative ' Format, editorial, or rearrangement type changes.

L Less Restrictive Technical Less restrictive requirement than the CTS. Each SHE in this category is individually numbered with a separate speci6c SHE provided in Enclosure 3.

M More Restrictive Technical More restrictive requirement than the CTS R Reloceted In accordance with the NRC Policy Statement Criteria.

LA Less Restrictive Generic Information removed from TS not covered by the Policy Stat ment Criteria.

LB Less Restrictive Generic Allowance to use simulated or actual actuation signals to meet surveillance test requirements.

Chapter 3.7 El-2 1/13/97

I J,*/P(ANT $Y$TEMS J */, $ [3 /. 7..

$ttVICE w&Ttt !YSTtu frag'rg$

t!MITING CONDITION FOR OPERATIONj

_u >

Lto J.7. 8 0 1.3 E ie.svqt.. [ nee.e.. 2 ...iee w.i.e QU (_t avsat tuO survic. W.ter pWGPs per leSp. es, ih it 6e 0,taintt.

ArpttCalttttvt McDis 1, 2, 3 a .

_I M LA 3

ACT10u:

6h caG ene service w.ter y trein er. opera.blD

~

y' restore (t ie.st two ioops to h bhD.h OptmasLL st.tus within 72 hoses or e neat 6 hears .nd in COLD $ NUT 00NN within the fellowing 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.n f et le.st Mm ala

$URytiLLANCE tt0UlttutNT1 di ie.st two s.rvice w.ter ice,s sheii ne d onstr.tes 0,tRaitti 5 R 3.7,8. l--9 At least eace per 31 **,5 6, eerit, tag th.t e.ch (ccessit)O~

v.1re (e.nu.1, , ewer oper.ted er .utes. tic) in the rios posh. (e servicing s foty reinted equipment th.t is not iocked, se.le L.A J or otherwise secured in position, is in its correct positie A

, %h E5 m,7.8.2 , ; $ e.t..le.st once per II esaths . w n, rin Iu...tes.ti.

..e..shut ..i.e iA .

by9 6eifvtag that

..t..tes it erro ..o e. - m

. c.i.,.. .m . . -- , ne.

m a.s.1 dAtie.st

"'"' 2eue "JtA"">%s.res, ei bases otieeg $b he aY0$pt, , ,

is ie.= ti.ht o u .,..rie,in, th, e ,is..i i.s,-ti.. er the ire.n.norte. pipin .re.. w ,fer

_1 .- 01bltrWl54.

" 3 #'g'3 ygt,f eash Su.)$ pv y 4to.d s 4. ado M h D f d ^

.n ,nD ,,,,,go.4,,c4 A M . M o 4 D 9 s z e. s a rg ne w e s.

9

_- IO y

. nor - -

ISolAfsoneF.SMS Sow- -/Ac --1IVN[UE b FARLEY-UNIII w)--

% torn onents cines rer

~3/4 7-II r %e sw$ ocoperakle.

am awm ai uo 55 g + -

d> M M Es D 'Aep;

~

53B Enh.I, N Soutras O incperable, b SWA.Wfinc,"for 7 rdenay aseme&f4.E Qe oMEo 2,Enterdu his Cer&+.hns si Atpowed. Ar.to'ons ef ko 3.4.6, s t. cops.nece R" For an R toets made. inepernble ,

bgstos. i

e.

9 ENCLOSURE 2 JOSEPH M. FARLEY NUCLEAR PLANT UNITS 1 AND 2 IMPROVED TECHNICAL SPECIFICATION CONVERSION CHAPTER 3.7 - PLANT SYSTEMS DISCUSSION OF CHANGES TO CURRENT FARLEY TS

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.7 - Plant Systems CHAPTER 3,7 DISCUSSION OF CHANGES (DOCS)

TO THE CURRENT FARLEY NUCLEAR PLANT (FNP)

TECHNICAL SPECIFICATIONS (TS)

This enclosure contains a brief DOC for each marked up change to the FNP Current Technical Specifications (CTS) required to produce the FNP specific Improved Technical Specification (ITS). The DOC numbers are referenced directly from Enclosure 1 (CTS markup), and the associated Significant Hazard Evaluations (SHEs) are contained in Enclosure 3. Some obsious editorial changes made to the CTS in order to conform with the Standard TS (STS) contained in NUREG-1431, Rev,1 may not be specifically addressed by a DOC but are covered by the ge.neric administrative SHE contained in Enclosure 3, Each of the following DOCS and associated SHEs are applicable to both Unit I and 2 unless otherwise stated.

In order to facilitate review, the DOCS in this enclosure are organized by individual TS and may be ca.eily separated into individual TS review sect!ons if desired. The DOCS are labeled with the 2

corresponding CTS number and name and the proposed FNP ITS specific number and name.

Chapter 3.7 E2-1 8/14/97

.= .

C.

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.7 - Plant Systems CTS 3/4.7.4 SERVICE WATER SYSTEM FNP ITS 3.7.8 SERVICE WATER SYSTEM (SWS)

DOC HQ SHE DISCUSSION 1 A The CTS 3/4.7.4 LCO statement is revised consistent with the STS. The term "at least" is deleted. As the intent of the LCO statement is to specify the minimum requirements, the descriptive phrase "at least" is redundant and unnecessary and is not used in the STS. The word " independent" describes a design feature of the system. The STS includes a sufficient description of the system design and related operability requirements in the bases and system design requirements are adequately maintained by existing QA/QC programs which are intended to control plant design and configuration. In addition, the TS also specify and control the electrical power supply operability and availability requirements for the SWS. Therefore, the word

" independent" is unnecessary and is deleted from the LCO statement consistent with the STS. The CTS LCO statement is also revised by the use of the word " trains" in place of" loops". This change is made to maintain -

consistency with the STS terminology in this and other TS. The STS terminology " trains" is consistent with the intent of the CTS LCO requirement for loops. The changes described above are considered clarifications and enhancements that do not introduce technical changes to the intent of the CTS or affect plant design, and are made to conform with the presentation and format of this information in the STS. Therefore, these changes are considered administrative.

2 LA The CTS 3/4.7.4 LCO statement is revised consistent with the STS. The LCO operability requirement for two SW pumps per loop is moved into the bases description of the SW system. The placement of descriptive information (operability requirements) in the bases describing the SWS is consistent with the philosophy of the STS for this type of detail. Reliance on the information contained in the STS bases for determining system operability is acceptable since changes to the information in the bases is controlled by the Bases Control Program specified in the administrative controls section of the TS.

3 A The CTS 3/4.7.4 Action statement is revised consistent with the STS. The terminology and phrasing used in the CTS is revised and the Action statement is divided into 2 Action Conditions. These revisions do not introduce technical changes to the intent of the CTS, and are made to conform with the presentation and format of this information in the STS.

Therefore, these changes are considered administrative.

Chapter 3.7 E2-1-H 8/14/97

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.7 - Plant Systems CTS 3/4.7.4 SERVICE WATER SYSTEM FNP ITS 3.7.8 SERVICE WATER SYSTEM (SWS)

DOC HQ H DISCUSSION 4' .M The CTS 3/4.7.4 Action statement is revised consistent with the STS. Two notes are added to the CTS Actions that require: 1) Entry into the applicable Conditions and Required Actions of LCO 3.8.1,"AC Sources-Operating,"

for the emergency Diesel Geaerator (DG) made inoperable by the SWS and,

2) Entry into the applicable Conditions and Required Actions of LCO 4.4.6, "RCS Loops Mode 4" for RHR loops made inoperable by SWS. LCO 3.8.1 contains Actions Conditions applicable to the DGs required operable. LCO 3.4.6 contains Actions Condi< .ls to address various combinations of

. inoperable RCS and RHR loop and requires immediate action be taken. If 4

the RHR loop affected by the inoperable SWS train was required operable to meet LCO 3.4.6, then the note requires that the applicable Action Condition of LCO 3.4.6 be entered. If the RHR loop affected by the inoperable SWS train was not used to meet LCO 3.4.6, there is no applicable Condition in LCO 3.4.6 to enter. The STS note provides suppor'Jsupported system guidance required due to the immediate actions of the RCS LCO and the DG Actions which address the potential for a loss of safety function. This additional guidance is necessary since the STS includes LCO 3.0.6 which precludes entering a supported system TS unless specifically directed by the support system LCO. Although consistent with the operability requirements of the RHR system and DGs at FNP, this additional TS requirement was not previously specified in the FNP TS.

Therefore, the addition of these notes is considered more restrictive.

5 M The CTS surveillance 4.7.4.a is r: vised consistent with the STS. The CTS surveillance verifies SWS valve position to ensure valves in the flow path servicing safety related equipment that are not locked, sealed or otherwise secured in position are correctly aligned. The CTS surveillance takes an additional exception to the requirement to verify valve position by qualifying the valves to be verified as " accessible" All FNP SWS valves required to be in the correct position by this surveillance are in fact verified in the correct position. The CTS allowance for accessible valves is not necessary and has been deleted consistent with the STS. Since this change deletes a CTS allowance it is considered rnore restrictive.

6. LA The CTS surveillance 4.7.4.b is revised consistent with the STS. The CTS surveillance verifies the actuation of automatic SWS valves on a Safety Injection test signal. The CTS surveillance statement contains a requirement Chapter 3.7 E2-2-H 8/14/97 t . .

. t FNP IS Conversion Enclosure 2 Discussion of Changes to CTS

. --Chapter 3.7 - Plt.nt Systems

.I

~i CTS 3/4.7.4 SERVICE WATER SYSTEM ,

FNP ITS 3.7.8 SERVICE WATER SYSTEM (SWS)

DOC NQ SHE DISCUSSION that the surveillance be performed "during shutdown" and specifies the signal being tested as " Safety Injection." In the STS, the 18 month ,

frequency is typically used when the surveillance must be performed during shutdown conditions. The corresponding STS surveillance bases discussion contains a discussion of the 18 month frequency and describes it as based on the need to perform this surveillance under the conditions that apply during a unit outage. Therefore, the CTS surveillance qualification of"during shutdown" is effectively incorporated into the proposed FNP ITS bases. In addition, the Safety Injection signal specified in the CTS surveillance has been removed and added to the prcposed FNP ITS bases for this surveillance. The surveillance is revised consistent with the STS to refer only to the " actuation signal." The placement of descriptive information (type of signal) or guidance (during shutdcnyn) for performing a surveillance in the bases for the suiveillance is consistent with the philoscphy of the STS for this type of detail. Reliance on the information contained in the STS bases for guidance in performing the associated surveillance is acceptable since changes to the infonnation in the bases is controlled by the Bases Control Program specified in the administrative controls section of the TS.

7 LB The CTS surveilluce 4.7.4.b is revised consistent with the STS, The surveillance includes a requirement to verify automatic SWS valve actuation upon receipt of an Safety Injection test signal. The STS replaces " test signal" with " actual or simulated actuation signal". The CTS surveillance is revised consistent with the STS to provide the allowance to utilize a simulated or actual signal to verify the required eutomatic actuations. This change allows satisfactory automatic actuations (requi ed equipment / system operation is verified) that occur due to an actual automatic actuation signal to fulfill the surveillance requirement. Operability is adequately demonstrated in either case as the arTected equipment or system cannot discrimina:e between an actual or simulated (test) signal. This change is considered less restrictive as it provid s an alternate method to satisfy the surveillance requirement to verify automatic valve actuation, s L The CTS surveillance 4.7.4.b is revised consistent with the STS. The CTS 5

surveillance verifies the actuation of automatic SWS valves on a Safety Injection test signal. The surveillance requires each automatic valve servicing safety related equipment be tested. The CTS requirement

" servicing safety related equipment"is replaced with the STS requiremer.t Chapter 3.7 E2-3-H 8/14/97

+

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS '

I ,

Chapter 3.7 Plant Systems CTS 3/4.7.4 SERVICE WATER SYSTEM FNP ITS 3.7.8 SERVICE WATER SYSTEM (SWS)

DOC EQ SHE DISCUSSION "in the flow path that is not locked, sealed, or otherwise secured in position." The STS requirement la intended to address the same SWS valves with the exception that valves locked, sealed or otherwise secured in position do not have to be tested. The addition of this STS test exception is reasonable considering the fact that the affected valves are secured in the position required to perform their intended safety function and no automatic actuation is required. In addition, the position of valves locked, sealed or otherwise secured in position is administratively controlled and verified in

, accordance with existing key / lock control, tagging, or other applicable valve position / alignment proceduces.

9 M CTS 3/4.7.4 is revised consistent with the STS by the addition of a surveillance requirement to verify automatic SWS pump start. A:though, the SWS pump auto start function is cunently tested as part of ESF actuation surveillance tests performed at FNP, placing a specific surveillance requirement for this testing in the SWS TS identifies the applicable equipment LCO supported by this test requirement. In addition, this change is consistent with the STS organization of testing requirements and places all the SWS system requirements in the same TS, However, since this change adds a specific test requirement that did not previously exist within the TS, it ,

is considered a more restrictive change.

10 L The CTS surveillance 4.7.4.a is revised consistent with the STS. This surveillance verifies that SWS System valves that are not locked, sealed, or otherwise secured in position that are in the flow path servicing safety-related equipment are in the correct position. The surveillance is performed every 31 days. The surveillance is modified by the addition of an STS note which provides guidance regarding the isolation of SWS to individual components. The STS note clarifies that the SWS system is not rendered inoperable by the isolation of flow to individaal components. The addition of the STS note is reasonable and acceptable considering that the isolation ofindividual ' components from the SWS reduces the heat load and flow requirements on the SWS which does not render the system inoperable and the fact that the definition of operability would require the isolated components without required cooling water to be considered inoperable.

The SWS system is still capable of performing its intended safety function o for the remaining operable components it services and individual TS requirements including LCO 3.0.6 and the Safety Function Determination Chapter 3.7 E2-4-H 8/14/97

FNP TS Conversion Enclosure 2 - Discussion of Changes to CTS Chapter 3.7 - Plant Systems CTS 3/4.7.4 SERVICE WATFR SYSTEM FNP ITS 3,7.8 SERVICE WATER SYSTEM (SWS)

DOC NQ SHE DISCUSSION Program in Section 5.0 address the inoperable supported components and provide the appropriate actions for those components. The isolation of individual components does not prevent the SWS from performing its safety function for the remaining components serviced, however, isolation of th:

valves to those components results in a failure to meet the SWS valve position su.veillance (CTS 4.7.4.a.). Therefore, the addition of this note also provides a necessary exception to SR 3.0.1 which states that failure to meet an SR constitutes failure to meet the LCO.

h Chapter 3.7 E2-5-H 8/14/97 i

4 e 4

~

ENCLOSURE 3 JOSEPH M. FARLEY NUCLEAR PLANT UNITS 1 AND 2 IMPROVED TECHNICAL SPECIFICATION CONVERSION CHAPTER 3.7 - PLANT SYSTEMS SIGNIFICANT HAZARDS EVALUATIONS FOR CHANGES TO CURRENT FARLEY TS

. p FNP TS Conversion Enclosure 3 - Significant Hazards Evaluations Chapter 3.7 - Plant Systems SiONIFICANT HAZARDS EVALUATIONS CONTENTS I. Organization.......................................................................................................................2 II Generic Evaluations

"' A" - Admini strative . . . .. . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . .. . . . . . . . . . . . . . .. . . .. . . . . .. . . . . . . . . . . . . . . . . . . .

"R" - Relocation of Technical Specifications . ..... .... .... .. .... ................. ...... ..... ...... . .... .... 5 "M" - M o re Restrictive . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

"LA" - Removal of Requirements from Retainei TS ...... ............ ............... .........................10 "LB" - Use of Simulated or Actual Test Signal ......... ........ ........ ........ ........ ............. .. .. ....12 III Soecific Evaluations "L" - Less Restrictive . . . .. .. .. . .. . . . . . . . ....... .. . .. . .. .. . . . .. .. . ..... . . .... .. ... ... .. .. . . . . . . . . . . . . .. . . . . . . . . . . . .. . . . . I 5 9

Chapter 3.7 E3-1 8/14/97

. p ,

4 FNP TS Conversion Enclosure 3 - Significant Hazards Evaluations Chapter 3.7 - Plant Systems I. SIGNIFICANT HAZARDS EVALUATION ORGANIZATI'ON

( In accordance with the provisions of 10 CFR 50.90, Southern Nuclear Operating Company (SNC) proposes to amend the Farley Nuclear Plant (FNP) Unit 1 and 2 current Technical Specifications (CTS). The proposed change revises the CTS in accordance with the NRC Policy Statement on Technical Specification improvements for Nuclear Power Reactors, July 22,1993

- (58 FR 39132). The proposed change includes converting the CTS to the Improved Standard Technical Specifications (STS) of NUREG-1431. The conversion to the STS has generated a large number of changes to the CTS, Evaluations pursuant to 10 CFR 50.92 showing that the proposed changes do not involve significant hazards considerations are provided for each change.

However, due to the volume of changes, similar changes have been grouped in categories to facilitate the significant hazards evaluations (SHEs) required by 10 CFR 50.92. ,

Generic O ~cs have been developed that correspond to each category of changes. The SHEs -

contained in Enclosure 3 are presented on an STS chapter basis as are each of the other Enclosures that make up the conversion document. SHEs for changes that cannot be grouped into a category have also been developed. Typically, less restrictive technical changes must be i evaluated individually Each TS may therefore contain individual "less restrictive-specific" SHEs as well as generic SHEs.

Each significant change to the CTS is marked up on the appropriate page in Enclosure 1 and assigned a reference number and SHE designator. Due to the large volume of changes, obvious editorial or administrative changes do not always receive a reference number but are considered to '

. be addressed by the applicable generic SHE for " Administrative" changes. The reference number assigned to a change is used in the Discussion of Change (DOC) in Enclosure 2 which provides a detailed description (basis) for each change and an additional reference to the applicable SHE in -

Enclosure 3.

' Chapter 3.7 E3-2 8/14/97

v -- - .c FNP TS Conversion 3 Enclosure 3 - Significant Hazards Evaluations '

- Chapter 3.7 Plant Systems 1

II. GENERIC SIGNIFICANT HAZARDS EVALUATION 10 CFR 50.92 EVALUATION

._ FOR ADMINISTRATIVE

("A" labeled changes) 2 This generic category applies to changes that are editorial in nature, involve the movement of requirements within the CTS without affecting their technical content, simply reformat a requirement, or clarify the TS (such as deleting a footnote no longer applicable due to a technical change to a requirement). It also includes non-technical changes such a reformatting and rewording the remaining requirements in order to conform with the format and style of the STS.

These changes are intended to make the TS more readily understandable to plant operators and other users. The application of the STS format and style will also assure consistency is achieved between TS. During this reformatting and rewording process, no technical changes (either actual or interpretational) were made to the TS unless they were identified and jus,tified. Howen,r, some obvious administrative changes may not be specifically referenced to a discussion of change or SHE,- If no discussion of change or SHE is referenced for a change, it is considered administrative in nature and this Generic SHE applies.

Changes to the CTS requirements categorized as Administrative are annotated with an "A" in the Enclosure 1 markup and Enclosure 2 DOC.

' SNC has evaluated each of the proposed TS changes identified as Administrative in accordance

' with the criteria set forth in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration. Administrative changes are considered generic and each change identified as Administrative will not be specifically discussed in this %IE. This evaluation will be applicable to each of the changes identified with an "A" in the Enclosure 1 markup of the CTS and the associated Enclosure 2 DOC.

The bases for the determination that the proposed changes do not involve a significant hazards consideration is an evaluation of these changes against each of the criteria in 10 CFR 50.92(c).

The criteria and conclusions of the evaluation are presented below.

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed changes involve reformatting, renumbering, and rewording of the CTS. These changes involve no technical revisions to the CTS and were made to conform with the fermat and style of the STS. ~ As such, these changes are administrative in nature and do not impact initiators of analyzed events or safety analyses assumptions relative to the mitigation of accidents or transient events. Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

Chapter 3.7 E3-3 8/14/97

4 FNP TS Conversion Enclosure 3 - Significa..t Hazards Evaluations i Chapter 3.7 Plant Systems II. GENERIC SIGNIFICANT HAZARDS EVALUATION 10 CFR 50.92 EVALUATION FOR ADMINISTRATIVE _

("A" labeled changes)

(continued)

2. Does the change create the possibility of a new or different kind of accident from any accidem previously evaluated?

The proposed changes do not involve a physical alteration of the plant (no new or different type of equipment will be installed) or changes in the methods governing nonnal plant operation. The proposed changes will not impose any new or different requirements or eliminat'e any existing requirements. In addition, the change does not alter assumptions made in the safety analyses and licensing basis. Therefore, the changes do not create the possibility of a new or different kind of accident from any accident pr(viously evaluated.

3. Does this change involve a significant reduction in a margin of safety?

The proposed changes are administrative in nature and do not involve any technical changes. 4 As such, these cha.nges do not impact any safety analysis assumptions and no question of safety is involved. Therefore, the changes do not involve a significant reduction in a margin of safety.

- Chapter 3.7 E3-4 8/14/97

3 FNP TS Conversion Enclosure 3 - Significant Hazards Evaluations Chapter 3.7 ~. Plant Systems II. GENERIC SIGNIFICANT HAZARDS EVALUATION 10 CFR 50.92 EVALUATION' FOR RELOCATION OF TECHNICAL SPECIFICATIONS'

("R" labeled changes)

This generic category applies to changes that relocate CTS requirements that do not meet the criteria in the NRC Final Policy Statement on Technical Specification Improvement for Nuclear

- Power Reactors (58FR39132, dated 7/22/93). This category of SHE may only be applied to entire TS that do not meet the NRC Policy Statement Criteria. Relocation of these CTS requirements allows the TS document to be reserved only for those conditions or limitations upon reac' tor operation which are necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety thereby focusing the scope of the TS.-

Therefore, CTS which do not meet the criteria in the NRC Final Policy Statement on Technical Specification Improvement for Nuclear Power Reactors (58 FR 39132, dated 7/22/93) have been proposed for relocs. tion to other licensee controlled documents that are subject to the provisions of 10 CFR 50.59. This will ensure that changes to these relocated TS requirements will be limited to those that do not involve an unreviewed safety question.

3 The NRC policy statemen; addresses the scope and purpose of TS. In doing so, it sets forth a specific set of objective criteria for determining which regulatory requirements and operating restrictions should be included in the TS. These criteria are as follows: l Criterion 1: Installed instrumentation that is used to detect and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundaiy; Criterion 2: A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analyses that either assumes the faMure of or presents a challenge to the integrity of a fission product barrier; Criterion 3: A structure, syst_em or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission ,

barrier, Criterion 4: A structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.

Chapter 3.7 E3 8/14/97

FNP TS Conversion Enclosure 3 Significant Hazards E.aluations

_ Chapter 3.7 Plant Systems

11. GENERIC SIGNIFICANT llAZARDS EVAL.UATION 10 CFR 50 92 EVALUATION FOR RELOCATION OF TECHNICAL SPECIFICATIONS

("R" labeled changes)

(continued)

Changes to the CTS requirements categorized as Relocated are annotated with an "R" in the Enclosure 1 markup and Enclosure 2 DOC.

SNC has evaluated each of the proposed TS changes identified as Relocated in accordance with

, the criteria set forth in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration. Relocation changes are considered generic and each relocated TS will not be speci6cally discussed in this SHE. A specific DOC for each CTS identified for relocation is provided in Enclosure 2. This evaluation will be applicable to each of the changes identified with an "R"in the Enclosure 1 markup of the CTS aad the associated Enclosure 2 DOC.

The bases for the determination that the proposed changes do not involve a significant hazards l consideration is an evaluation of these changes against each of the criteria in 10 CFR 50.92(c).

The criteria and conclusions of the evaluation are presented below.

1. Does the change involve a significant increase in the probability or consequence: cf an accident previously evaluated?

The proposed changes relocate entire TS (all requi ements and surveillances) for structures, systems, components or variables which do not mee any of the four NRC Policy Statement criteria used for defining the scope of the TS. T he CTS proposed for relocation will be moved from the TS to a licensee controlled document that is administered pursuant to the requirements of 10 CFR 50.59. Therefore, the proposed changes will only reduce the leul of regulatory control on these requirements. The level of regulatory control has no impact on the prc,bability or the consequences of an accident previously evaluated. Thus, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

I l

Chapter 3.7 E3 6 8/14/97

FNP TS Conversion Enclosure 3 Signi6 cant Hazards Evaluations Chapter 3.7 Plant Systems

11. GENERIC SIGNIFICANT HAZARDS EVALUATION ,

l 10 CFR 50.92 EVALUATION FOR I RELOCATION OF TECHNICAL SPECIFICATIONS l

("R" labeled changes)

(continued)

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed changes relocate CTS to a licensee controlled document. The changes do not involve a physical alteration of the plant (no new or differeat type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the changes do not impose any new or different requirements or eliminate any existing requirements. The changes do not alter assumptions made in the safety analyses and licensing basis. Thus, the changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does this change involve a significant reduction in a margin of safety?

The proposed changes relocate CTS to a licensee controlled document for which future changes will be evaluated pursuant to the requirements of10 CFR 50.59. The proposed

, changes uo not reduce a margin of safety because they have no impact on any safety analysis assumptions. Therefore, these changes do not involve a significant reduction in a margin of safety.

l l

Chapter 3.7 E3 7 8/14/97

FNP TS Conversion Enclosure 3 - Significant flazards Evaluations Chapter 3.7 Plant Systems II. GENERIC SIGNIFICANT IIAZARDS EVALUATION 10 CFR 50.92 EVALUATION FOR htORE RESTRICTIVE (changes labeled "hr')

This generic category consists of changes that rnodify the CTS to add new requirements or revise existing requirements to be more stringent. These changes are typically made to conform to applicable requirements in the STS, correct discrepancies, or remove ambiguities from the CTS.

hiore restrictive changes are proposed only wiien such changes are consistent with:

1. The FNP current licensing basis;
2. The applicable FNP safety analyses; and
3. Good engineering practice such that the availability and reliability of the affected equipment is not reduced.

Changes to the CTS requirements categorized as More Restrictive are annotated with an "hi" in the Enclosure 1 markup and Enclosure 2 DOC.

SNC has evaluated each of the proposed TS changes identified as More Restrictive in accordance with the criteria set forth in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration. These changes are considered generic and each change identified as More Restrictive will not be specifically discussed in this SHE. This evaluation will be applicable to each of the changes identified with an "hr' in the Enclosure I markup of the CTS and the associated Enclosure 2 DOC.

The bases for the determination that the proposed changes do not involve a significant hazards consideration is an evaluation of these chtnges against each of the criteria in 10 CFR 50.92(c).

  • l he criteria and conclusions of the evaluation are presented below.

Chapter 3.7 E3,8 8/14/97

FNP TS Conversion Enclosure 3 - Significant Hazards Evaluations Chapter 3.7 Plant Systems

11. GENERIC SIGNIFICANT HAZARDS EVALUATION 10 CFR 50.92 EVALUATION FOR MORE RESTRICTIVE (changes labeled "hr')

(continued)

1. Does the change involve a significant increase in the probability or consequences of an accident pretiously evaluated?

The proposed changes provide more stringent requirements than previously existed in the CTS. These more stringent requirements are not assumed to be initiators of analyzed events and will not alter assumptions relative to mitigation of accident or transient events. The changes'are evaluated to ensure no previously analyzed accident has been adversely affected.

The more stringent requirements are imposed to ensure process variables, stmetures, systems and components are maintained consistent with the safety analyses and licensing basis. These changes will not alter assumptions relative to mitigation of an accident or transient event nor will they alter the operation of process variables, structures, systems, or components described in the safety analyses. Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed changes add more restrictive requirements to the TS or make existing requirements more restrictive. The proposed changes do not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The proposed changes do impose new or different

, requirements. However, these changes are consistent with assumptions made in the safety analysis and licensing basis. Thus, these changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does this change involve a significant reduction in a margin of safety?

The proposed changes add more restrictive requirements to the TS or make existing requirements more restrictive and have been evaluated to ensure consistency with the safety analysis and licensing basis. As such, these changes do not impact any safety analyses assumptions and no question of safety is involved. Therefore, these changes do not involve a reduction in a margin of safety.

Chapter 3.7 E3 9 8/14/97 l

FNP TS Conversion Enclosure 3 Significant Hazards Evaluations

Chapter 3.7 Plant Systems

!!. GENERIC SIGNIFICANT HAZARDS EVALUATION 10 CFR 50.92 EVALUATION FOR REMOVAL OF REQUIREMENTS FROM RETAINED TS (changes labeled LA")

This generic category applies to changes that modify the CTS to achieve consistency with the style and format of the STS by removing some information and requirements from the CTS. This category of change is considered to be less restrictive (no longer controlled by TS) and is referred to as Less Restrictive Generic. N " partial relocation" ofinformation can not be addressed by the application of the criteria in the NRC Final Policy Statement on Technical Specification Improvement for Nuclear Power Reactors. The NRC Policy Statement criteria is only intended to apply to entire TS, This generic category is intended to apply to changes that remove some information that is typically descriptive in nature regarding the equipment, system (s), actions or surveillances from a CTS that is retained in the TS. W information that is removed from the CTS is proposed for inclusion in the TS Bases, FSAR, procedures, or other licensee controlled documents as appropriate. The removal of this information firom the CTS to licensee controlled

- documents is acceptable because the documents will be controlled through a process which utilizes 10 CFR 50.59. Wrefore, the information that has been moved continues to be maintained in an appropriately controlled manner, h proposed changes will not impact the actual information moved out of the CTS, but will reduce the level of regulatory control over this information.

Changes to the CTS requirements that fall within thi: category (Less Restrictive Generic) are annotated with an "LA" in the Enclosure 1 markup and Enclosure 2 DOC SNC has evaluated each of the proposed TS changes identified as Les: Restrictive Generic in _

accordance with the criteria set forth in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration. These changes are considered generic and each change identified as Less Restrictive Generic will not be specifically discussed in this SHE. This evaluation will be applicable to each of the changes identified with an "LA" in the Enclosure 1 markup of the CTS and the associated Enclosure 2 DOC.

The bases fpr thi determination that the proposed changes do not involve a significant hazards consideration is an evaluation of these changes against each of the criteria in 10 CFR 50.92(c).

The criteria and conclusions of the evaluation are presented below.

Chapter 3.7- E310 8/14/97

~

i FNP TS Conversion Enclosure 3 Significant Hazards Evaluations Chapter 3.7 Plant Systems II. GENERIC SIGNIFICANT HAZARDS EVALUATION 10 CFR 50.92 EVALUATION FOR REMOVAL OF REQUIREMENTS FROM RETAINED TS (changes labeled "LA")

(continued)

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed changes relocate requirements from the CTS to a licensee controlled document. -

The document containing the relocated requirements will be maintained using the provisions

~

of 10 CFR 50.59. Therefore, the proposed changes will only reduce the level of regulatory control 'on these requirements. The level of regulatory control has no impact on the probability or the consequences of an accident previously evaluated. Thus, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed changes relocate requirements from the CTS to a licensee controlled document.

The changes do not involve a physical alteration of the plant (no new or different type of -

equipment will be installed) or a change in the methods governing normal plant operation. In addition, the changes do not impose any new or different requirements or eliminate any existing requirements. The changes do not alter assumptions made in the safety analyses and licensing basis. Thus, the changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does this change involve a significant reduction in a margin of safety?

The proposed changes relocate requirements from the CTS to a licensee controlled document for which future changes will be evaluated pursuant to the requirements of 10 CFR 50.59.

- The proposed changes do not reduce a margin of safety because they have no impact on any safety analysis assumptions. Therefore, these changes do not involve a significant reduction in a margin of safety.

Chapter 3.7 E311 8/14/97

a FNP TS Conversion Enclosure 3 Significant Hazards Evaluations l Chapter 3.7 Plant Systems

! l II. GENERIC SIGNIFICANT HAZARDS EVALUATION . )

l 10 CFR 50.92 EVALUATION i FOR I

ALLOWANCE TO USE A SIMULATED OR ACTUAL \CTUATION SIGNAL (changes labeled "LB")

This generic category applies to those changes that provide the allowance to utilize a simulated or i

actual signal to verify the automatic actuation of specific components in the Surveillance test

{ requirements of the TS. This type of change is considered less restrictive as it provides an {

~

alternate method to satisfy surveillance requirements that verify automatic equipment / system '

actuation. This change allows satisfactory automatic actuations (required equipment / system i operation is verified) that occur due to an actual automatic actuation to fulfill the surveillance 3 requirement. Operability is adequately demonstrated in either .:ase as the affected equipment or '

system cannot discriminate between an actual or simulated (test) signal.

Changes to the CTS requirements that fall within this category (Less Restrictive Generic) are annotated with an "LB" in the Enclosure I markup and Enclosure 2 DOC.

l 1

SNC has evaluated each of the proposed TS changes identified as Less Restrictive Generic in accordance with the criteria set forth in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration. These changes are considered generic

! and each change identified as Less Restrictive - Generic will not be specifically discussed in this 4

SHE. This evaluation will be applicable to each of the changes identified with an "LB" in the l Enclosure 1 markup of the CTS and the associated Enclosure 2 DOC.

The bases fonhe determination that the proposed changes do not involve a significant hazards

. consideration is an evaluation of these changes against each of the criteria in 10 CFR 50.9
(c).

The criteria and conclusions of the evaluation are presented below.

I 4

1 i

a Chapter 3.7 E312 8/14/97

FNP TS Conversion Enclosure 3 SigniScant liazards Evaluations Chapter 3.7. plant Systems

11. GENERIC SIGNIFICANT HAZARDS EVALUATION 10 CFR 50.92 EVALUATION FOR ALLOWANCE TO USE A SIMULATED OR ACTUAL ACTUATION SIGNAL (changes labeled "LB")

(continued)

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed changes provide the allowance to utilize a simulated or actual signal to verify the automatic actuation of specific components in the surveillance test requirements of the TS.

These changes do not impose a requirement to create an actual signal, nor do they eliminate any restrictions on producing an actual signal. The proposed changes do not affect the procedures governing plant operations or the creation of required actuation signals; the proposed changes simply allow an actual signal to be used in evaluating the acceptsnee criteria for the equipment / system surveillance test requirements. These changes do not affect the function or intent of the surveillance requirement to verify equipment / systems capable of performing their required functions. Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The possibility of a new or different kind of accident from any accident previously evaluated is not created because the proposed changes do not introduce a new mode of plant operation and do not involve a physical modification to the plant.

3. Does this change involve a significant reduction in a margin of safety?

The allowance to use an actual signal (as well as a test or simulated signal) does not affect the acceptance criteria of the required surveillance test. Operability of the affected equipment / system may be adequately verified in either case since the equipment / system is not capable of discriminating between an actual or simulated signal. Therefore, these changes do not involve a significant reduction in a margin of safety.

Chapter 3.7 E313 8/14/97

4 FNP TS Conversion Enclosure 3 Significant llazards Evaluations Chapter 3.7 Plant Systems 111. SPECIFIC SIGNIFICANT MAZARDS EVALUATIONS 10 CFR 50.92 EVALUATIONS FOR LESS RESTRICTIVE (changes labeled ("L")

This category consists of technical changes which revise existing requirements such that more restoration time is provided, fewer compensatory measures are needed, or fewer or less restrictive surveillance requirements are required. This would also include requirements which are deleted from the TS ( not relocated to other documents) and other technical changes that do not fit a generic category. These changes must be evaluated individually and specific SHEs developed.

Each " specific" SHE for a less restrictive technical change will be individually numbered in each TS with the suffix "L".

Technical changes to the CTS requirements categorized as "Less Restrictive Specific" are annotated with the suffix "L" and an individual number in the Enclosure 1 markup and Enclosure 2 DOC for each TS.

In order to facilitate review, the less restrictive SHEs are organized by individual TS. The SHEs applicable to each TS may be separated into individual review packages if desired.

SNC has evaluated each of the proposed technical changes identified as "Less Restrictive -

Specific" individually in accordance with the criteria set forth in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.

The bases for the determination that the proposed changes do not involve a significant hazards consideration is an evaluation of these changes against each of the criteria in 10 CFR 50.92(c).

The criteria and conclusions of the evaluation are presented below.

Chaptcr 3.7 E3-14 8/14/97

l FNP TS Conversion Enclosure 3 Significant Hazards Evaluations Chapter 3.7 Plant Systems 111. SPECIFIC SIGNIFICANT HAZARDS EVALUATIONS CTS 3/4.7.4 SERVICE WATER SYSTEM FNP ITS 3.7.8 SERVICE WATER SYSTEM (SWS) 1:L

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change adds an exception to the requirement to verify the automatic actuation of SWS valves. The proposed change provides an exception for valves that are locked, realed or otherwise secured in position. This change does not result in any hardware or operating procedure changes. The afTected valves are secured in their required safety function position.

Therefore, the SWS remains capable of performing its safety function and the resision of this TS requirement does not affect the probability of an accident. The proposed change continues to provide adequate assurance that the SE is capable of performing its intended safety function. Therefore, the proposed change does not involve a significant increase in the consequences of an accident previously evaluated.

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed change does not necessitate a physical alteration of the plant (no new or different type of equipment will be installed) or changes in parameters governing normal plant operation. The proposed change only affects the SWS valve position surveillance requirement. The proposed change continues to ensure the SWS LCO is met. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does this change involve a significant reduction in a margin of safety?

The proposed change provides a test exception consistent with the STS for valves that are locked, scaled, or othenvise secured in position. The proposed change does not affect the capability or capacity of the SWS to perform its intended safety function for the equipment it senices. As such, the proposed change does not impact the applicable safety analyses assumptions regarding the SWS or the equipment it senices. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Chapter 3.7 E3-1-0 8/14/97

FNP TS Conversion Enclosure 3 Significant liazards Evaluations Chapter 3.7 Plant Systems III. SPECIFIC SIGNIFICANT HAZARDS EVALUATIONS CTS 3/4.7.4 SERVICE WATER SYSTEM FNP ITS 3.7.8 SERVICE WATER SYSTEM (SWS)

&L

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change adds a clarification to the valve position tutveillance requirement for the SWS. The addition of the STS note to this surveillance provides an allowance to isolate individual components seniced by the SWS without requiring the SWS to be declared inoperable for failure to meet the surveillance. This change does not result in any hardware or operating procedure changes. The SWS remains capable of performing its safety function for the components it services. The allowance to isolate individual components seniced by SWS does not include an exception to the TS definition of operability for the isolated components or any TS required actions that may result from the components being inoperable. Therefore, the proposed change does not affect the individual component TS requirements. As the individual component TS requirements continue to limit plant operation as appropriate, the revision of this TS requirement does not affect the probability of an accident. The proposed change continues to provide adequate assurance that the SWS is capable of performing its intended safety function for the equipment serviced. Therefore, the proposed change does not involve a significant increase in the consequences of an accident previously evaluated.

2. Does the change create the possibihty of a new or different kind of accident from any accident previously evaluated?

The proposed change does not necessitate a physical alteration of the plant (no new or different type of equipment will be installed) or changes in parameters governing normal plant operation. The proposed change only affects the SWS valve position surveillance requirement. The proposed change continues to ensure the SWS LCO is met for the components serviced. Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does this change involve a significant reduction in a margin of safety?

The proposed change provides an allowance to isolate components serviced by SWS without declaring the SWS moperable. The proposed change does not affect the capability or capacity of the SWS to perform its intended safety function for the equipment it senices. In addition, the proposed change does not affect the existing TS requirements for the definition of operability or for the individual components affected. Therefore, the proposed change does not impact TS operability requirements for the components that may be isolated from the SWS As such, the proposed change does not impact the applicable safety analyses.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Chapter 3.7 E3 2-G 8/14/97

4 ENCLOSURE 4 JOSEPH M. FARLEY PLANT UNITS 1 AND 2 IMPROVED TECHNICAL SPECIFICATION CONVERSION CHAPTER 3.7 - PLANT SYSTEMS MARKUP OF NUREG-1431, Rev 1 (STS)

LCOs

4 .

l FNP TS Conversl:n Enclosure 4 Markupof STS Chapter 3.7. Plant Systems 4

MARKUP OF STS LCOs CHAPTER 3.7 -

I This enclosure contains markups of the Technical SpeciAcation LCOs Rom NUREG 1431, l revision 1, referred to a the STS. The marked up STS pages show the Farley Nuclear Plant i Units 1 and 2 (FNP) specinc diferences from the STS. Each technical change resulting hom an

FNP speciAc diference is marked up and numbered in this enclosure. The corresponding FNP '

justifications for deviation (JD) hom the STS are contained in Enclosure 5.

. j In addition, the markups in this enclosure show the NRC approved changes to the STS resulting kom the Nuclea- Energy Institute (NEI)/NRC revision process. The Industry /NE! sponsored  ;

changes marked in this enclosure have been epproved by the NRC and have also been determined to be applicable to FNP. The Industry /NE! revisions to the STS are marked-up and identined with the NE! tracking number (i.e., TSTF 03, TSTF 19. etc). The NE! changes are treated as ,

though they are part of the STS for the FNP conversion. Each NE! change package cordains its own justification for change which is not repeated in this conversion documentation.

I t

i T

f Chapter 3 7 - E41 1/13/97

\ . .<

SWS 3.7.8 3.7 PLANT SYSTEMS 3.7.8 Service Water System (SWS)

LC0 3.7.8 Two SWS trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SWS train A.1 --------NOTES-------

inoperable. 1. Enter applicable Conditions and 4

Required Actions of LC0 3.8.1, "AC Sources-Operating," for emergency diesel generator made inoperable by SWS.

2. Enter applicable Conditions and Required Actions of LCO 3.4.6, "kCS Loops-MODE 4," for residual heat removal loops made inoperable by SWS.

Restore SWS train to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OPERABLE status.

(continued)

WOG STS 3.7-19 Rev 1, 04/07/95

i a

SWS 3.7.8 i

ACTIONS (continued) i CONDITION REQUIRED ACTION COMPLETION TINE 1

l B. Required Action and 8.1 Be in MODE 3.

j associated Completion 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />  :

Time of Condition A Agl

not met. '

1 8.2 8e in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />

( ,

i i

s i

SURVEILLANCE REQUIREMENTS

. SURVEILLANCE FREQUENCY 4

i

SR 3.7.8.1 -------------------NOTE--------------------

4 Isolation of SWS flow to individual i components does not render the SWS j inoperable.

3 ...........................................

1

! Verify each SWS manual, power operated, and 31 days -

l automatic valve in the flow path servicing

+

safety related equipment, that is not locked, sealed, or otherwise secured in

position, is in the correct position. ,

SR 3.7.8.2 Verify each SWS automatic valve in the flow months L path that is not locked, sealed, or

! otherwise secured in position, actuates to

! -the correct position on an actual or j simJlated actuation signal.

i SR 3.7.8.3 Verify each SWS pump starts automatically 18 months

} on an actual or simulated actuation signal.

l-i -

c v v v the M Writi fpn

5R,3,7.8 4 Vesi F g g ,,nggh kb V85 d th6 is 1 k t, nOfi d f oFuegroncL .

L 5 3 '

A .x ~

l WOC STS 3.7-20 Rev1,04/07/95 l

4 2

ENCLOSURE 5 JOSEPH M. FARLEY NUCLEAR PLANT UNITS 1 AND 2 IMPROVED TECHNICAL SPECIFICATION CONVERSION CHAPTER 3.7 - PLANT SYSTEMS JUSTIFICATIONS FOR DIFFERENCES (JD)

-FROM NUREG-1431, Rev 1 (STS) i

FNP TS Conversion Enclosure 5 JD from STS Chapter 3.7. Plant Systems JUSTIFICATIONS FOR DIFFERENCES (JD)

FROM NUREG 1431 Rev 1 (STS) . CilAPTER 3.7 4

This enclosure contains a brief discussion.Sustification for each marked up technical change to the STS to make them Farley Nuclear Plant Units 1 and 2 (FNP) specific Improved Technical Specifications (ITS). The Change Numbers are referenced directly from Enclosure 4 (STS markup). The STS markup in Enclosure 4 also contains the approved changes to the STS resulting from the Nuclear Energy Institute (NEI)/NRC revision process. Thejustifications for NET changes are contained in the associated change package submitted to the NRC and are not repeated in this document.

In order to facilitate review, the JDs in this enclosure are organized by individual TS and may be casily separated into Individual TS review sections if desired. The JDs are labeled with the corresponding STS number and name and the proposed FNP ITS specific number and name if different than the STS.

Chapter 3.7 E5-1 8/14/97

FNP TS Conversion Enclosure 5 JD fror.: STS Chapter 3.7 Plant Systems STS 3.7.8 SERVICE WATER SYSTEM (SWS)

FNP ITS 3.7.8 SERVICE WATER SYSTEM (SWS)

JD NUMBER JUSTIFICATION 1 Consistent with the CTS, the proposed FNP ITS for the SWS includes an additio'nal surveillance requirement. The proposed surveillance requirement SP 3.7.8.4 corresponds to the CTS requirement 4.7.4.c and requires a visual inspection be made of the ground area to confirm the leak tightness of the buried SWS pip ng. '

This FNP specific surveillance provides assurance of the SWS pipe integrity and contributes to the overall system reliability. The addition of this surveillance to the proposed FNP ITS maintains consistency with the current FNP SWS licensing basis -

as specified in the CTS.

Chapter 3.7 E510 9/12/97

e ENCLOSURE 6 JOSEPH M. FARLEY NUCLEAR PLANT UNITS 1 AND 2 IMPROVED TECHNICAL SPECIFICATION CONVERSION CHAPTER 3.7 - PLANT SYSTEMS MARKUP OF NUREG-1431, Rev 1 (STS)

BASES

O FNP TS Conversion Enc!osure 6 Markup of STS Bases Chapter 3.7 Plant Systema.

MARKUP OF STS BASES CHAPTER 3.7 This enclosure contains markups of the STS Bases. The marked up STS pages show the Fuley Nuclear Plant Units I and 2 (FNP) specific differences from the STS. Listed below are brief explanations for the changes to the Bues. The explanations are keyed to alpha designators which are used to mark each FNP specific Bues change. The FNP specific STS Bues in this enclosure will completely replace all the corresponding current FNP Bases.

In addition, the markups in this enclosure show the NRC approved changes to the STS resulting from the Nuclear Energy institute (NEI)/NRC revision process. The Industry /NE! rpor.nred changes marked in this enclosure have been approved by the NRC and have also been determined to be applicable to FNP. The Industry /NEl revisions to the STS are marked-up and identified with the NE! tracking number (i.e., TSTF 03, TSTF 19, etc). The NEl changes are treated as though they are part of the STS for the FNP conversion. Each NE! change package containa its own justification for change which is not repeated in this conversion documentation.

KEY EXPLANATION FOR FNP SPECIFIC CHANGES TSC-# Technical Specification Change This Bues change is due to a corresponding change made to the associated STS LCO and is explained in detail in the associated Enclosure 5 Justification of Differences from STS (JD). The JD number used in enclosure 5 is also referenced in the Bases markup (as TSC #)

, where applicable.

PSC Plant Specific Change - The Bues information is revised to conform to FNP design, analysis, terminology, or operating practice. This change may result in a deletion or revision ofinformation contained in the STS Bues.

PSE Plant Specific Enhancement - Additionalinformation specific to FNP is prosided to enhance the STS Bases information consistent with FNP design, analysis, terminology, or operating practice.

E Editorial - Changes made to the NUREG ' s 1 Bues to improve clarity and understanding or correct minor errors.

D Deletion This STS Bues information is deleted. The information constitutes extra detail not required to support the TS requirements for Operability, Applicability, Actions, Completion Times, or Surveillances and is not required or not readily verified for FNP or contained in other documents already referenced in the Bases.

Chapter 3.7 E6-1 1/13/97

SWS B 3.7.8 B 3.7 PLANT SYSTEMS S 3.7.8 ' Service Water System (50)

BASES BACKGROUND The SWS rovides a heat sink for the removal of process and operatin heat from safety related components during a or transient. During normal Design operation,Band sisaAccident norsa' shu(DBA)tdown, the SWS also provides this function for various safety related and nonsafety related components. The safety related function is covered by this LCO.

The SWS consists of two sey safety F5kR r t cooling water trai ts.ate.-00% Each trai_n cons \stsoftwo_s>

capacity SON c acJt) pumps, one c..onem cooiina water :Lcui noat? e D'I iping, vaiving,vinstrumentationi and ';wo cuc' oneT

.y' gi YT The pumps and valves dre remote anc manuay one sWM zgnes, ex. cept in tse unlikely event of a lons of coolant#

ge % p fyaccident (LOCA). The pumps I inned to the cr' tical lico r F6D 8Pgmg are automatically started upon receipt or a safe".y in;sition s

sin da and all essential valves are aligned to their post

(

3.asicot _ - 2 amTent posP. inns.97he SWS 41 r ' ides emergency makeup t

f(fgese) to t w rspent Get N P water supply <;o the Aux'1' "uel pool anti Et n am nd is tite backup gd u.k%r ary Feedwater SysteK

' sUate,mte Additional information about the esigr. nd operation of the SWS, along with a list of the one served, is PNsented in the FSAR, Section g.2.1 (Ref.1). The

  • "
  • l*6 6 *f principal safety rtlated funct on of he SWS I

is the removal M F5 of P de:ay heat from the reactor via the LCW System.

(Las6 sisj -

APPLICABLE T'io design basis of the SWS is for one SWS train, in SAFETY ANALYSES conjunction with the CCW System and a 100% capacity containee co ing system, to remove core decay heat followin d ign basia LOCA as discussed in the FSAR, Section . (Ref.2). This prevents the containment sump fluid from increasing in temperature during the recirculation phase following a LOCA and provides for a FSD A'gggoog gradual reduction in the temperature of this fluid as it is supplied to the Reactor Coolant System by the ECCS pumps.

The SWS is designed to perform its function with a single fat'4ure of any active component, assumis.g the loss of offsite power.

(continued)

WOG STS 8 3.7-41 Rev1,04/07/95

4 SWS 8 3.7.8

. i #'

g c

Q BASES fy-Q 1

APPLICA8LE TheSWS,QYnennjun)ctionwith ( "

IIe CCW System also cools the l

SAFETY ANALYSES unit from resqduahAeat remo a' i (continued) FSAR SectionT 5.4.7 , (Ref. ntry 3V conditions e(RHR), as 5d,scussed in to MODE

, during normal ann pos))t accident operations. The time l

required for this evolution is a function of the number of 4

S CCW and RHR System trains that are operating. One SWS train is sufficient to r ve decay heat during subsequent operations in M0 rniered, and 6. This assumes a O Pera*m

temperature of 9 'FoccurringsimultaneousIpaximu85WS 3 y with maximu j

heat loads on t e system. '

m mmum The SWS satisfies Criterion 3 of the NRC Policy Statement\worecar gt h

$8

' Ne <d i LCO Two SWS trains are required to be OPERABLE to provide the required redundancy to ensure that the system functions to i

remove post accident heat loads assuming that the worst case single active failure occur,s coincident with the loss

of offsite power.

! l

f' An SWS train is considered OPERABLE during MOCES 1, 2, 3 and 4 when:
a. h pum BLE; and

. b. The associated ping, valves, h at exe n naer'h and 4

instrumentation and controls requ' red to perform the safety related function are OPERABLE.

APPLICABILITY In MODES I, 2, 3, and 4, the SWS is a normally operating system that is required to support the OPERA 81LITY of the equipment scrviced by the SWS and required to be OPERABLE in

these MODES.

TSD f' g ooi In MODES 5 and 6, the OPERABILITY requirements of the SWS are determined by the systems it supports.

Ad ACTIONS If one SWS train is inoperable, action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In this Condition, (continued)

WOG STS B 3.7-42 Rev 1, 04/07/95

SWS B 3.7.8 i

I BASES ,

ACTIONS I

Ad (continued)  !

the remaining 0PERA8LE SWS train is adequate to perform the i

j heat removal function. However, the overall reliability is  !

reduced because a single failure in the OPERA 8LE SWS train could result in loss of SWS function. Required Action A.1 i

is modified by two Notes. The first Note indicates that the applicable Conditions and Required Actions of LC0 3.8.1, 'AC i

Sources - Operating,' should be entered if an inoperable SWS  !

I train results in an inoperable emergency diesel generator. '

l .

The second Note indicates that the a>plicable Conditions and Required Actions of LC0 3.4.6, 'RCS oops - MODE 4," should l

l l

be entered if an inoperable $!!S train results in an ~

j inoperable decay heet removal train. This is an exception to LC0 3.0.6 and ensures the proper actions are taken for these components. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is based on

! the redundant capabilities afforded by the OPERA 8LE train, j l_

' and the low probability of a D8A occurring during this time

. period. ,

t j B.1 and B.1 1

If the SWS train cannot be restored to OPERABLE status

! within the associated Completion Time, the unit must be placed ta a MODE in which the LC0 does not apply. To ,

! achieve this status, the unit must be placed in at least '

l ,

MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in N00E 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. .

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions j from full power conditions in an orderly manner and without j challenging unit systems.

l f

! SURVE!LLANCE sR 3.7.a.1 i

REQUIREMENTS

i. .

This SR is modified by a Note indicating that the isolation 1 of the SWS components or systems may render those components

! inoperable, but does not affect the OPERA 8ILITY of the SWS.

j Verifying the correct alignment for manual, power operated, and automatic valves in the SWS flow path provides assurance 4

that the proper flow paths exist for SWS operation. This SR 4

l Joes not apply to valves that are locked, sealed, or (continued) 4 WOG STS 8 3.7-43 Rev1,04/07/95 l

i

.. l o

l l SWS 4

8 3.7.8

BASES l l

! i SURVEILLANCE i

REQUIREMENTS R 3.7.ad (continued) l j

otherwise secured in position, since they are verified to be in the correct position prior to being locked, sealed, or i i

secured. This SR does not require any testing or valve manipulation

  • rather, it involves verification that those

! valves ca position.pableofbeingmispositionedareinthecorrect This SR does not apply to valves that rannot be j inadvertently misaligned, such as check valves. '

f The 31 day Frequency is based on engineering judgment, is '

consistent with the procedural controls governing valve operation, and ensures correct valve positions.

. S -

rgom 0;rs I* ' ' * *d

&QIW%9D This SR verifies proper automati operation of the SWS j

valves on an actual or simulated ctuation signal. The SWS is a normally operating system that cannot be fully actuated i as part of nomal testing. This Surveillance is not i required for val at are locked, sealed, or otherwise ,

j secured in the position under administrative >

i controls. The month Frequency is based on the need to i Perform this Surve 11ance under the conditions that apply i

during a unit outage and the potential for an unplanned transient if the Surveillance were perfomed with the reactor at power. Operating experience has shown that these ,

coup nents usually pass the Surveillance when perfomed at  :

i th 1 month Frequency. Therefore, the Frequency is

cop le from a reliability standpoint.

i j SR 3.7.8.3 l This SR verifies proper automatic operation of the SWS pumps on an actual or simulated actuation signal. The SWS is a

! no y operating system that cannot be fully actuated as

ar normal testing during nomal operation. The j month Frequency is based on the need to perform this j urveillance under the conditions that apply during a unit i outage and the potential for an unplanned transient if the
- Surveillance were performed with t te reactor at power.

Operating experiwnce has shown that these components usually j pass the Surveillance when performed at the 1 month i.

j (;ontinued) ,

j WOG STS B 3.7-44 Rev 1, 04/07/95 4

. .my,,,,m.,,._,g._ , , , ,m, , _ , . , . . , , . ,

SWS B 3.7.8 BASES Gus, enc sa s.28%__ crse o

/ _

SURVEILLANCE SR 3.7.8.3 (continued)

REQUIREMENTS Frequency. Therefore, the Frequency is acceptable from a reliability standpoint.

REFERENCES 1. FSAR, Section 2.1

2. FSAR, Section 2
3. FSAR,Section([5.4.7) h WOG STS B 3.7-45 Rev 1. 04/07/95 l

g . .,

4 CHAPTER 3.7 IN3ERT C ,

TO STS BASES PAGE B 3.745 FNP SPECIFIC SURVEILLANCE SR 3.7.8.4 SR 3.7.8 4 This SR requires a visual inspection be made of the ground area immediately surrounding the SWS buried piping. The performance of a visualinspection of the ground provides an indication of SWS piping integrity by monitoring the surrounding grour.d for excessive moisture or erosion.

The 18 month frequency is acceptable based on operating experience and the passive nature of the buried piping.

(

Chapter 3.7 Insert Page

___

Retrieved from "https://kanterella.com/w/index.php?title=ML20217E153&oldid=3294897"