ML20249A913

Provides Comments on Specific Points of 980409 NRC Issuance of Pressure Temp Limits Rept TS Amends.Util Is Concerned W/ Implications of Listed Paragraph Contained in NRC Ltr

ML20249A913
Person / Time
Site:	Farley
Issue date:	06/15/1998
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-96-03, GL-96-3, NUDOCS 9806190102
Download: ML20249A913 (3)

Text

-

Dave M: rey Southern Nuclear

'2'

. Vice President.

Op rating Company Farley Project

- P.O. Box 1295 '

' Birmingham. Alabama 35201 Tel 205.992.5131 June 15,1998 -

SOUTHERN h COMPANY Energy to ServeYourWorM*

Docket Nos.:

50-348 10 CFR 50.90 50-364 -

U. S. Nuclear Ref-*w Commission ATfN: Document Control Desk Washington, 20555 i

' Joseph M. Farley Nuclear Plant Pressure Ts.prature Limits Report

. Technid Wineatian Amendments

. Ladies and Gentlemen:

By letter dated April 9,1998, the NRC Staffissued the Pressure Temperature Limits Report (PTLR) technical specification amendments for Farley Units I and 2. In part, the NRC letter stated-

'Ihe technical content of the initial submittal was not complete and lacked important information needed to approve the license amendments. Specific examples included referencing WCAP-14040-NP-A, Revision 2, "Mahodology Used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Curves," and Generic Letter %-03, " Relocation of the Pressure Temperature Limit Curves and Low Temperature Overpressure Protection System Limits," without complying with all aspects of these documents. In addition, the submittals did not clearly address deviations taken from these methodologies.

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. While your staff provided timely responses to staff requests for additional 3

information, in some instances this information needed to be clarified or corrected through repeated conference calls, which caused further delays in the overall review process.

Southern Nuclear is concerned with the implications of the above paragraph and provides the following comments on specific points.

h

The technical content of the laitial submittal was not complete and lacked important (gO information needed to approve the license amendments. Specific examples inclub '

referencing WCAP-14040-NP-A, Revision 2, " Methodology Used to Develop Cold

' Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Curves," and Generic Letter 96-03," Relocation of the Pressure Temperature Limit Curves and Low

Temperature Overpressure Protection System Limits," without complying with au aspects of these doc====te.

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U. S. Nuclear Rpatary Commission Page 2

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It is Southern Nuclear's opinion that the Farley PTLR submittal complied with the applicable i

portions of WCAP-14040-NP-A, Revision 2, and Genenc letter 96 03.~ The WCAP consists of

. two separate wetiaan, the first of which provides the NRC-approved >=-*k~ialagy for generaten of the pressure temperature (P-T) limit curves, and the second of which provides the NRC-approved methodology for determinate of the Cold Overpressure Mitigation System (COMS) setpoints.

The first section of the WCAP was daractly applicable to Farley Nuclear Plant and was incorporated into the Farley PTLR submittal. The second section associated with establishing the COMS setpoints was not applicable to Farley Nuclear Plant and, therefore, was not ' corporated m

in the Farley PTLR submittal.

Instead of the COMS described in WCAP-14040-NP-A, Revision 2, Farley utilizes the residual heat removal (RHR) relief valves for low % inure protection (LTOP). Generic Letter 96-03, l

provided the following guidance to licensees regardmg use of RHR relief valves:

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'!he LTOP system for pressure relief typically consists of two power-operated relief valves (PORVs), two residual heat removal (RHR) suction relief valves, or a l

combination ofboth. Some plants have only one PORV. The LTOP system limits consist of PORV and RHR relief valve setpoints. The RHR suction relief valves do not have vanable pressure lift setpoints as the PORVs do and, therefore, are still addressed in the technical specifications.

Based on the above NRC guidance and since the LTOP system limits had been previously reviewed and approved by the NRC Staff, the setpoint for the RHR relief valves were retained in the technical specifications. Once the NRC advised that a methodology for verification of the RHR relief valve setpoint was required to be included in the PTLR and since no NRC-approved

==a*h~ialogy to determme RHR relief valve setpoints existed, Southern Nuclear was faced with the iterative task of developing a eh~Ialogy that met the requirements of Generic Letter 96-03.

While your staff provided timely responses to staff requests for additional information, in some instances this information needed to be clarifwd or corrected through repeated conference calls, which caused further delays in the overall review process.

Southern Nuclear agrees that repeated conference calls with the NRC Staff were required to address NRC questions regardmg the Farley PTLR submittal; however, these calls were initiated by the NRC and were manry to answer the NRC Staffs questions. While Southern Nuclear appreciated the opportunity to receive the NRC Staffs questions as early as possible, the number

. of wJw calls name=ry to obtain NRC Staff approval of the PTLR was beyond the control of

- Southem Nuclear and should not be considered indicative of the quality of the submittal.

Whde there were a number of conference calls concerning 'the PTLR, these calls may be attributed to two issues:

1. the omissen of the LTOP system from the original submittal as discussed above; and

2. positions / interpretations taken by the NRC that were unknown /not anticipated by Southern Nuclear.

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s U. S. Nuclear Regulatory C==I ion Page 3 During the NRC review of the Farley PTLR submittal, it came to the attention of Southern Nuclear that the NRC Staff had adopted new interpretations of the regulator} requirements contained in 10 CFR 50, Appendix G, and Regulatory Guide 1.99, Revision 2. 'Ihis claim is substantiated by

- NRC meetings with the industry on Novcenber 12,1997, and February 12-13,1998, to provide new interpretations regarding the requirements of 10 CFR 50, A#iv G, and Regal =*~y Guide 1.99, Revision 2. The new NRC Staffinterpretations differed from those previously used by

' Southern Nuclear in dcv?-:f==* ofits PTLR submittal made in July 1997. Had these new.

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interpretations been.available when the Farley Nuclear Plant PTLR was initially submitted in July 1997, Southern Nuclear would have considered them in the original PTLR analysis and several conference calls could have been avoided.

We are encouraged that the Staffis providing licensees with M 4 -- e y to improve subnuttals, and we are hopeful that both Southern Nuclear and the NRC can apply the lessons learned from this experience and avoid duplication of the problems encountered with the PTLR in future submittals. We look forward to working with you to improve our submittals with the resulting improvement in the effectiveness of the regulatory process commensurate with nuclear P ant safety.

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- If there are any questions, please advise Respectfully submitted, SOUIRERN NUCLEAR OPERATING COMPANY I

i 1

Dave Morey -

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TWS/ REM / cit:REBUTRV4. DOC j

1 cc:

Mr. L. A. Reyes, Region II Ad=iai % tor Mr. J. I. Zimmerman, NRR Project Manager j

Mr. T. M. Ross, Plant Sr. Resident Inspector l

Mr. S. J. Collins, NRR Director E_

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