NL-22-0799, License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.5

License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.5

ML22354A087
Person / Time
Site:	Farley
Issue date:	12/20/2022
From:	Gayheart C Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NL-22-0799
Download: ML22354A087 (1)

Text

3/4. Southern Nuclear December 20, 2022 Docket Nos.: 50-348 50-364 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Regulatory Affairs Joseph M. Farley Nuclear Plant - Units 1 and 2 License Amendment Request to Revise 3535 Colonnade Parkway Birmingham AL 35243 205 992 5000 NL-22-0799 the Frequency of Surveillance Requirement 3.6.3.5 Ladies and Gentlemen:

Pursuant to the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (CFR), Southern Nuclear Operating Company (SNC) hereby requests a license amendment to Joseph M. Farley Nuclear Plant (FNP) Unit 1 Renewed Facility Operating License NPF-2 and Unit 2 Renewed Facility Operating License NPF-8. The proposed amendment revises Surveillance Requirement (SR) 3.6.3.5 to eliminate event-based testing of containment purge valves with resilient seals and permit testing to be performed in accordance with the Surveillance Frequency Control Program.

The enclosure provides a basis for the proposed change. Attachment 1 contains marked-up Technical Specification (TS) pages. Attachment 2 contains revised TS pages. Attachment 3 provides marked-up TS Bases pages for information only. Attachment 4 contains Unit 1 quarterly containment purge air system containment isolation valve leakage history. contains Unit 2 quarterly containment purge air system containment isolation valve leakage history.

SNC requests approval of the proposed amendment within 12 months of completion of the NRC's acceptance review with an implementation period of 60 days.

In accordance with 10 CFR 50.91, a copy of this application, including attachments, is being provided to the designated Alabama Official.

This letter contains no regulatory commitments. If you have any questions, please contact Ryan Joyce at 205.992.6468.

U.S. Nuclear Regulatory Commission NL-22-0799 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 20th day of December 2022.

Respectfully submitted, art Directo egulatory Affairs Southern Nuclear Operating Company CAG/was/dmw

Enclosure:

Basis for Proposed Changes Attachments:

1. Proposed Technical Specification Changes (Marked-up Pages)

2. Revised Technical Specification Pages

3. Proposed Technical Specification Bases Pages (Marked-up) for Information Only

4. Unit 1 quarterly containment purge air system containment isolation valve leakage history

5. Unit 2 quarterly containment purge air system containment isolation valve leakage history cc:

Regional Administrator, Region II NRR Project Manager-Farley 1 & 2 Senior Resident Inspector-Farley 1 & 2 Alabama - State Health Officer for the Department of Public Health RType: CFA04.054

Joseph M. Farley Nuclear Plant - Units 1 and 2 License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.5 Enclosure Basis for Proposed Changes

Enclosure to NL-22-0799 License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.5 Basis for Proposed Changes

SUBJECT:

License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.5 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Current Technical Specifications Requirements 2.3 Reason for the Proposed Change 2.4 Description of the Proposed Change

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusion

6.0 REFERENCES

Attachments:

1. Proposed Technical Specification Changes (Marked-up Pages)

2. Revised Technical Specification Pages

3. Proposed Technical Specification Bases Pages (Marked-up) for Information Only

4. Unit 1 Quarterly Containment Purge Air System Containment Isolation Valve Leakage History

5. Unit 2 Quarterly Containment Purge Air System Containment Isolation Valve Leakage History E-1

Enclosure to NL-22-0799 License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.5 1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Southern Nuclear Operating Company (SNC) requests an amendment to Renewed Facility Operating License NPF-2 and NPF-8 for Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2, respectively. The proposed change revises Surveillance Requirement (SR) 3.6.3.5 to eliminate event-based testing of containment purge valves with resilient seals and permit testing to be performed in accordance with the Surveillance Frequency Control Program.

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation The containment isolation valves form part of the containment pressure boundary and help ensure that the containment atmosphere will be isolated from the environment in the event of a release of fission product radioactivity to the containment atmosphere as a result of a Design Basis Accident (OBA). The containment isolation valves include valves in the Shutdown Purge System and the Minipurge System.

The Shutdown Purge System operates during shutdown (i.e., Modes 5 and 6) to supply outside air into the containment for ventilation and temperature control and may also be used to reduce the concentration of noble gases within containment for personnel access. Because of their large size, the 48-inch purge valves are not qualified for automatic closure under OBA conditions and are required by TS to be closed in Modes 1, 2, 3, and 4. The Shutdown Purge System supply includes an outside air connection to prefilters, heating coils, a fan, a duct system, and a supply penetration with three butterfly valves in series. The Shutdown Purge System exhaust includes an exhaust penetration with three butterfly valves in series, a duct system, a filter bank with prefilters, HEPA and charcoal filters, and an exhaust fan.

The only radiological accident assumed to occur inside the containment during Mode 5 or 6 is a fuel handling accident. The analysis of the radiological consequences of a fuel handling accident inside the containment takes no credit for closing of the Shutdown Purge System isolation valves. The Shutdown Purge System is assumed to continue to operate following the event.

The Minipurge System is independent of the Shutdown Purge System but there is common ductwork and common filters. The 8-inch Minipurge System is used to maintain radioactivity levels in the containment and to equalize internal and external pressures as needed in Modes 1, 2, 3, and 4. The Minipurge System exhaust also has two isolation valves in series.

The DBAs that result in a release of radioactive material within containment are a loss of coolant accident (LOCA) and a rod ejection accident. In the analyses for each of these accidents, it is assumed that containment isolation valves are either closed or function to close within the required isolation time following event initiation. This ensures that potential paths to the environment through containment isolation valves (including shutdown purge and minipurge valves) are minimized.

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Enclosure to NL-22-0799 License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.5 2.2 Current Technical Specifications Requirements FNP TS 3.6.3, Containment Isolation Valves, SR 3.6.3.5 states:

Perform leakage rate testing for containment penetrations containing containment purge valves with resilient seals.

The Frequency is, "In accordance with the Surveillance Frequency Control Program AND Within 92 days after opening the valve."

The acceptance criteria for the leakage rate testing performed by SR 3.6.3.5 are provided in TS 5.5.17, "Containment Leakage Rate Testing Program," and are unchanged by the proposed amendment.

TS 3.3.6, "Containment Purge and Exhaust Isolation Instrumentation," provides initiation signals to automatically close the Shutdown Purge System and Minipurge System isolation valves on receipt of a containment isolation signal or on receipt of a high radiation signal from the purge exhaust monitors. These requirements are unchanged by the proposed amendment.

The FNP TS include a Surveillance Frequency Control Program (SFCP) as Specification 5.5.19, which was approved in Amendment No. 185/180, dated July 18, 2011. The program provides controls for Surveillance Frequencies to ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

2.3 Reason for Proposed Change In the 1970s it was recognized that containment purge and vent valves with resilient seals were more susceptible than other containment isolation valves to degradation caused by environmental factors (such as temperature extremes, and changes in humidity and barometric pressure) and mechanical factors (such as wear and tear and hardening of resilient seats due to aging and exposure to radiation). This degradation could cause significant and increasing leakage rates. In addition, the radiological consequences of such leaks were more significant than for most containment isolation valves because the containment purge and vent valves typically have large diameters and provide a direct connection between the containment atmosphere and the outside environment.

As part of the resolution of Generic Issue B-20 (later renamed Multi-Plant Action MPA-8020),

"Containment Leakage Due to Seal Deterioration," the frequency of leak testing of containment purge and vent valves was increased to limit the time in which the valves might be experiencing excessive leakage without detection. Although there was some variation, a typical testing arrangement was to have "passive" valves (those not opened during plant operation) tested every six months and "active" valves (those opened during plant operation) tested within three months of being operated.

Title 10 of the Code of Federal Regulations, Part 50, Appendix J, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors," Option B, to which FNP is committed, does not require more frequent testing for containment purge and vent valves. The more frequent testing is required by SR 3.6.3.5.

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Enclosure to NL-22-0799 License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.5 The industry has made considerable improvement to the performance of containment purge and vent valves with resilient seals. Improved seal materials, quality control, and modifications of equipment and environmental conditions have corrected the valve deficiencies in many plants.

Several plants have requested, and the NRC staff has granted, TS changes to eliminate the more frequent testing requirements for containment purge and vent valves with resilient seals.

This permits the testing to be performed at a frequency consistent with other containment isolation valves.

The performance history of the FNP Shutdown Purge System and Minipurge System resilient seal isolation valves does not warrant testing within 92 days after opening the valve. As a result, the Frequency is proposed to be revised to permit the Frequency of testing to be controlled by the licensee in accordance with the SFCP, which will establish an appropriate performance-based testing Frequency.

2.4 Description of the Proposed Change The Frequency of SR 3.6.3.5 is revised to state, "In accordance with the Surveillance Frequency Control Program."

A markup of the proposed change to TS SR 3.6.3.5 is provided in Attachment 1. Attachment 2 provides the "clean" retyped SR 3.6.3.5. provides a markup of TS SR 3.6.3.5 Bases for information only.

3.0 TECHNICAL EVALUATION

3.1 FNP Shutdown Purge System and Minipurge System Isolation Valve Testing Method The FNP Shutdown Purge System and Minipurge System isolation valves are tested as Type C valves against the criteria of 10 CFR 50, Appendix J, Option B, as described in NEI 94-01 Revision 3-A. FNP is required to follow the requirements in Appendix J, Option B, and the guidance in NEI 94-01, Revision 3-A, by TS 5.5.17.

These valves are locally leak-tested by local pressurization to the maximum calculated accident containment pressure. Each valve to be tested is closed by normal operation without any preliminary exercising or adjustments (e.g., no tightening of the valve after closure by the valve actuator). The design of the containment purge and vent systems requires that the test volume be defined by the inside and outside containment isolation valves; that is to say the test volume is between the valves. This means the inside containment isolation valve is tested in the reverse direction to accident pressurization. ANSI/ANS 56.8, 2002, Section 6.2, "Direction of Testing" states the following:

Tests should be performed so that the test pressure is applied in the same direction as that which would occur during the design-basis LOCA. A reverse-direction test may be performed if it provides equivalent or more conservative test results.

Butterfly valves employing resilient seals are configured internally such that testing in either direction is considered to be equivalent.

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Enclosure to NL-22-0799 License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.5 The TS limit for measured leakage through the containment purge valves is the acceptance criteria on startup after employing the shutdown purge, 11,738 cc/min per penetration when pressurized to the peak accident containment pressure. During all other testing, the TS limit is 0.6La minus the sum of all other Local Leak Rate Test results.

3.2 FNP Shutdown Purge System and Minipurge System Isolation Valve Testing Results A review of results of tests performed in accordance with SR 3.6.3.5 beginning in 2009 identified no instances of unacceptable seat leakage. Please refer to Attachments 4 and 5 of this LAR for FNP Units 1 and 2 quarterly test results. The tests have an acceptance criterion that states that the test measured leakage is added to the total Type B and Type C leakage for all other penetrations, and the total must be less than 0.6La. For tests performed during Mode ascension after an outage where the Shutdown Purge System was used, there is an additional criterion that the leakage be less than 0.05La (11,738 cc/min).

Because the acceptance criteria are dependent on the sum of the other Type B and Type C test results, the acceptance criteria vary from test to test.

The Unit 1 Penetration 12, Purge Supply, acceptance criteria ranged from a maximum allowed of 138,691 cc/min to a minimum of 98,325 cc/min. The measured leakage rates ranged from 2 cc/min to 8,002 cc/ min.

The Unit 1 Penetration 13, Purge Exhaust, acceptance criteria ranged from a maximum of 136,891 cc/min to a minimum of 91,469 cc/min. The measured leakage rates ranged from 2 cc/min to 28,634 cc/min.

The Unit 2 Penetration 12, Purge Supply, acceptance criteria ranged from a maximum of 135,160 cc/min to a minimum of 106,450 cc/min. The measured leakage rates ranged from 34 cc/min to 17,090 cc/min.

The Unit 2 Penetration 13, Purge Exhaust, acceptance criteria ranged from a maximum of 135,185 cc/min to a minimum of 108,198 cc/min. The measured leakage values ranged from 17 cc/min to 14,714 cc/min.

The maximum leakage measured for the Unit 1 Exhaust and the Unit 2 Supply and Exhaust valves exceeded the Mode Ascension criteria of 0.05La or 11,738 cc/min during quarterly testing. This is acceptable because the SR 3.6.3.5 acceptance criteria does not require meeting the 0.05La additional criteria. Therefore, these tests were satisfactory.

3.3 Impact of the Proposed Change on Plant Risk The major contributors to Large Early Release Frequency (LERF) for FNP are Interfacing System LOCAs, Medium pipe break LOCA, and Steam Line Breaks down stream of the MSIVs.

The Shutdown Purge System and Minipurge System do not contribute significantly to Large Early Release Frequency (LERF). The 48-inch Shutdown Purge System isolation valves are not explicitly modeled in the FNP PRA because they are normally locked closed and not manipulated in Modes 1, 2, 3, and 4. The Minipurge System isolation valves may be opened in E-5

Enclosure to NL-22-0799 License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.5 Mode 1, 2, 3, and 4, and are modeled in the FNP PRA. The potential failure of the Minipurge System isolation valves to close when required is a very small contribution to the LERF.

Extending the intervals between leakage rate tests on the Shutdown Purge System and Minipurge System isolation valves does not affect the ability of these valves to close. As a result, the proposed changes will have little to no effect on LERF.

3.4 Surveillance Frequency Control Program The SFCP ensures that SRs in the TS are performed at intervals sufficient to assure the regulatory requirements are met. Existing regulatory requirements, such as 10 CFR 50.65 (Maintenance Rule) and 10 CFR Part 50, Appendix B (Corrective Action Program), require monitoring of surveillance test failures and implementing corrective actions to address such failures. One of these actions may be to consider increasing the frequency at which a surveillance is performed. In addition, the SFCP implementation guidance in NEI 04-10, Revision 1, requires monitoring of the performance of structures, systems, and components (SSCs) for which surveillance frequencies are decreased to assure reduced testing does not adversely impact the SSCs. Changes to surveillance frequencies in the SFCP using NEI 04-10, Revision 1, including qualitative considerations, results of risk analyses, sensitivity studies and any bounding analyses, and recommended monitoring of SSCs, are required to be documented.

These are subject to regulatory review and oversight.

The proposed change will eliminate the event-based testing Frequency of within 92 days after opening a containment purge valve with resilient seals. The containment purge valves with resilient seals will be leak tested at a Frequency specified in the SFCP and any changes to the testing Frequency will be evaluated in accordance with the SFCP following the process in NEI 04-10, Revision 1.

FNP TS 5.5.17, "Containment Leakage Rate Testing Program," requires containment leakage rate testing to be in accordance with NEI 94-01, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," Revision 3-A. NEI 94-01 requires the containment purge and vent valve testing Frequency to not exceed 30 months. Therefore, the testing Frequency established by the SFCP cannot exceed this length.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met.

10 CFR 50.54(0) requires primary reactor containments for water-cooled power reactors to be subject to the requirements of Appendix J to 10 CFR 50, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors." Appendix J Option B, "Performance Based Requirements," specifies containment leakage testing requirements, including the types required to ensure the leak-tight integrity of the primary reactor containment and systems and components which penetrate the containment. In addition, Appendix J discusses leakage rate acceptance criteria, test methodology, frequency of testing and reporting requirements for each type of test.

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Enclosure to NL-22-0799 License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.5 FNP has implemented the performance-based Option B of 10 CFR 50 Appendix J for containment leakage rate testing. The current test interval for testing a containment purge valve with resilient seals of within 92 days after opening the valve, is not based on Appendix J and appears only in the plant TS. Generic Issue B-20, "Containment Leakage Due to Seal Deterioration," provides the basis for the determination that valves with resilient seals should be tested more frequently than required by Appendix J. However, the FNP testing history demonstrates that these valves have a very low failure rate and more frequent testing is not warranted. Therefore, the proposed change does not affect compliance with 10 CFR 50.54(0) or 10 CFR 50, Appendix J, Option B.

4.2 Precedent The NRC has approved the elimination of the event-driven leak rate testing Frequency for containment purge valves with resilient seals for a number of plants based on good valve performance demonstrated by plant-specific historical leakage rate testing results (References 1

- 4 ). The containment purge valve performance for FNP is similar to the valve performance at these plants and justifies a similar change to the FNP TS.

4.3 No Significant Hazards Consideration Southern Nuclear Operating Company (SNC) requests an amendment to Renewed Facility Operating License NPF-2 and NPF-8 for Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2, respectively. The proposed change revises Surveillance Requirement (SR) 3.6.3.5 to eliminate event-based testing of containment purge valves with resilient seals and permit testing to be performed in accordance with the Surveillance Frequency Control Program.

SNC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The containment purge valves, and containment purge valve leakage testing are not an initiator of any accident previously evaluated. As a result, the frequency of performing containment purge valve leakage testing does not affect the probability of any accident previously evaluated. The containment purge valves are part of the containment barrier, which is credited to mitigate the consequences of many previously evaluated accidents. However, plant testing data demonstrates that the containment purge valves are reliable, and the event-driven testing is not necessary to ensure the containment purge valves perform their role in preventing radiological releases from the containment following an accident. As a result, the proposed change does not have a significant effect on the consequences of any accident previously evaluated.

Therefore, this proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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Enclosure to NL-22-0799 License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.5

2.

Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change does not change the design function or operation of the containment purge valves. The proposed elimination of event-based leakage testing of the containment purge valves does not create any new credible failure mechanism or accident initiators not considered in the original design.

Therefore, this proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Do the proposed changes involve a significant reduction in a margin of safety?

Response: No The proposed change does not alter any controlling values of parameters assumed in the plant's licensing basis to avoid exceeding regulatory or licensing limits. The proposed change does not alter a design basis or safety limit. The proposed change permits changing the frequency of performing containment purge valve leakage testing but does not alter the acceptance criteria for such tests.

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

Based on the above evaluations, Southern Nuclear Operating Company concludes that the proposed amendment(s) present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and, accordingly, a finding of no significant hazards consideration" is justified.

4.4 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

Southern Nuclear Operating Company has determined that the proposed amendment would change requirements with respect to the installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. Southern Nuclear Operating Company has evaluated the proposed changes and has determined that the changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amount of effluent that may be released offsite, or (iii) a significant increase in the individual or cumulative occupational E-8

Enclosure to NL-22-0799 License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.5 radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22 (c)(9). Therefore, pursuant to 10 CFR 51.22(b),

an environmental assessment of the proposed change is not required 6.0 References

1.

Letter to Document Control Desk (NRC) from J. J. Sheppard (South Texas Project),

Subject:

South Texas Project, Units 1 and 2, Docket Nos. STN 50-498, STN 50-499, Proposed Amendment to Technical Specification 3/4.6.1.7, "Containment Ventilation System," for Containment Purge Valve Operability Test Interval, dated February 18, 2002 (ADAMS Accession No. ML020520535).

2.

Letter to William T. Cottle (South Texas Project) from Mohan Thadani (NRC),

Subject:

South Texas Project, Units 1 and 2 - Issuance of Amendments Re: Extension of the Intervals Between Operability Tests of the Normal and Supplementary Containment Purge Valves (TAC Nos. MB4048 and MB4049), dated January 7, 2003 (ADAMS Accession No. ML030140325).

3.

Letter to Document Control Desk (NRC) from Joseph E. Venable (Waterford),

Subject:

License Amendment Request, Leakage Rate Testing of Containment Purge Valves, Waterford 3 Steam Electric Station, Docket No. 50-382, License No. NPF-38, dated August 2, 2006 (ADAMS Accession No. ML062270490).

4.

Letter to Kevin T. Walsh (Waterford) from N. Kalyanam (NRC),

Subject:

Waterford Steam Electric Station, Unit 3 - Issuance of Amendment Re: Leakage Rate Testing of Containment Purge Valves (TAC NO. MD2711 ), dated May 23, 2007 (ADAMS Accession No. ML071290447).

5.

NEI 94-01, Revision 3-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," July 2012.

6.

ANSI/ANS-56.8-2002, "Containment System Leakage Testing Requirements,"

November 2002.

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Joseph M. Farley Nuclear Plant - Units 1 and 2 License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.5 Proposed Technical Specification Changes (Marked-up Pages)

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS SR 3.6.3.5 SR 3.6.3.6 SURVEILLANCE Perform leakage rate testing for containment penetrations containing containment purge valves with resilient seals.

Verify each automatic containment isolation valve that is not locked, sealed or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal.

FREQUENCY In accordance with the Surveillance Frequency Control Program

'Nithin 92 days after opening the vat-ve In accordance with the Surveillance Frequency Control Program Farley Units 1 and 2 3.6.3-8 Amendment No. ~

(Unit 1)

Amendment No. ~

(Unit 2)

Joseph M. Farley Nuclear Plant - Units 1 and 2 License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.5 Revised Technical Specification Pages

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS SR 3.6.3.5 SR 3.6.3.6 SURVEILLANCE Perform leakage rate testing for containment penetrations containing containment purge valves with resilient seals.

Verify each automatic containment isolation valve that is not locked, sealed or otherwise secured in position, actuates to the isolation position on an actual or simulated actuation signal.

FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Farley Units 1 and 2 3.6.3-8 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

Joseph M. Farley Nuclear Plant - Units 1 and 2 License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.5 Proposed Technical Specification Bases Pages (Marked-up} for Information Only

BASES SURVEILLANCE REQUIREMENTS (continued)

Farley Units 1 and 2 SR 3.6.3.4 Containment Isolation Valves B 3.6.3 Verifying that the isolation time of each automatic power operated containment isolation valve in the 1ST Program is within limits is required to demonstrate OPERABILITY. The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analyses. The isolation time and Frequency of this SR are in accordance with the INSERVICE TESTING PROGRAM.

Any change in the components being tested by this SR will require reevaluation of STI Evaluation Number 558904 in accordance with the Surveillance Frequency Control Program.

SR 3.6.3.5 For containment purge valves with resilient seals, additional leakage rate testing beyond the test requirements of 10 CFR 50, Appendix J, Option B, is required to ensure OPERABILITY. The containment purge and exhaust penetration leakage limit is based on not exceeding the total combined leakage rate limit for all Type B and C testing specified in 5.5.17, Containment Leakage Rate Testing Program.

Operating experience has demonstrated that this type of seal has the potential to degrade in a shorter time period than do other seal types.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Additionally, this SR must be performed within 92 days after opening the 1.ialve. The 92 day Frequency was chosen recognizing that cycling the valve could introduce additional seal degradation (beyond that occurring to a valve that has not been opened). Thus, decreasing the interval (from 184 days) is a prudent measure after a valve has been opened.

SR 3.6.3.6 Automatic containment isolation valves close on a containment isolation signal to prevent leakage of radioactive material from containment following a OBA. This SR ensures that each automatic containment isolation valve will actuate to its isolation position on a containment isolation signal {Phase A or Phase B). This surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

B 3.6.3-13 Revision-444

Joseph M. Farley Nuclear Plant - Units 1 and 2 License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.5 Unit 1 Quarterly Containment Purge Air System Containment Isolation Valve Leakage History

FNP Unit 1 Containment Purge Air System Containment Isolation Valves Leakage History (Quarterly Tests)

Pen 12 Pen 13 Q1P13V302 /Q1P13V282 / Q1P13V301 /

Q1P13V301 /Q1P13V281 / Q1P13V303 /

Q1P13V281 Q1P13V284 Date Test Leak Acceptance Date Test Leak Acceptance Type Rate Criteria Type Rate Criteria (seem)

(seem)

(seem)

(seem) 2/2/22 As Found 1835 134175 2/2/22 As 2935 134283 Found 11/3/21 As Found 1581 133949 11/3/21 As 2827 132993 Found 8/4/21 As Found 1915 138691 8/4/21 As 3783 136776 Found 1 F30 Refueling Outage (RFO is ~ iving credit to 1st Quarterly Test) 2/2/21 As Found 2200 129745 2/2/21 As 1734 128398 Found 11/18/20 As Found 853 130660 11/18/20 As 21 130596 Found 8/5/20 As Found 2

129131 8/5/20 As 85 130124.77 Found 5/7/20 As Found 995 129460 5/7/20 As 531 129688 Found 2/7/20 As Found 1223 130126 2/7/20 As 557 130683 Found 1F29 Refueling Outage (RFO is~ iving credit to 1st Quarterly Test) 8/15/19 As Found 609 128550 8/15/19 As 606 122406 Found 5/21/19 As Found 5070 127301 5/21/19 As 6750 133588 Found 2/27/19 As Found 175 133535 2/27/19 As 463 133835 Found 12/18/18 As Found 475 133605 12/18/18 As 124 133635 Found 10/24/18 As Found 505 133135 10/24/18 As 216 133505 Found 7/16/18 As Found 875 133921 7/16/18 As 116 133235 Found 1 F28 Refueling Outage (RFO is NOT taking credit for Quarterly Test since it was completed prior to RFO) 3/29/18 As Found 1364 135786 3/29/18 As 630 135163 Found 2/1/18 As Found 928 136460 2/1/18 As 1253 135960 Found 11/9/17 As Found 428 136623 11/9/17 As 456 136891 Found 8/22/17 As Found 265 136870 8/22/17 As 188 136763 Found 5/22/17 As Found 286 136745 5/22/17 As 295 136734 Found 3/1/17 As Found 275 136451 3/1/17 As 324 136451 Found 1 F27 Refueling Outage (RFO is taking credit for Quarterly Test) 9/16/16 As Found 298 119055 9/16/16 As 241 119227 Found 6/23/16 As Found 593 119002 6/23/16 As 605 102847 Found A4-1

FNP Unit 1 Containment Purge Air System Containment Isolation Valves Leakage History (Quarterly Tests)

Pen 12 Pen 13 01P13V302 /01P13V282 / 01P13V301 /

Q1P13V301 /Q1P13V281 / Q1P13V303 /

Q1P13V281 Q1P13V284 Date Test Leak Acceptance Date Test Leak Acceptance Type Rate Criteria Type Rate Criteria (seem)

(seem)

(seem)

(seem) 4/1/16 As Found 403 102013 4/1/16 As 16760 118080 Found 1/8/16 As Found 1237 118113 1/8/16 As 693 117563 Found 10/16/15 As Found 687 131238 10/16/15 As 1210 131116 Found 8/4/15 As Found 565 126236 8/4/15 As 481 130997 Found 1 F26 Refuelinq Outaqe (RFO is takinq credit for Quarterly Test) 3/9/15 As Found 998 132169 3/9/15 As 774 131859 Found 12/22/14 As Found 688 132357 12/22/14 As 525 132439 Found 10/1/14 As Found 770 132067 10/1/14 As 255 131814 Found 7/9/14 As Found 517 131869 7/9/14 As 798 132005 Found 4/16/14 As Found 715 128901 4/16/14 As 662 129001 Found 1/22/14 As Found 3825 130483 1/22/14 As 562 128040 Found 1 F25 Refuelinq Outaqe (RFO is takinq credit for Quarterly Test) 817/13 As Found 968 133774 8/7/13 As 1865 135466 Found 5/16/13 As Found 850 135963 5/16/13 As 173 135508 Found 2/20/13 As Found 353 136056 2/20/13 As 628 136159 Found 12/11/12 As Found 456 135381 12/11/12 As 461 135670 Found 10/3/12 As Found 847 135529 10/3/12 As 745 135525 Found 7/2/12 As Found 781 133030 7/2/12 As 1151 134819 Found 1 F24 Refuelinq Outaqe (RFO is takinq credit for Quarterly Test) 1/6/12 As Found 1061 132737 1/6/12 As 804 132836 Found 10/5/11 As Found 1160 134417 10/5/11 As 698 133329 Found 8/12/11 As Found 74 132982 8/12/11 As 107 132139 Found 5/10/11 As Found 3295 134268 5/10/11 As 2

134252 Found 2/28/11 As Found 19 132387 2/28/11 As 18 133648 Found 1/6/12 As Found 1061 132737 1/6/12 As 804 132836 Found 1 F23 Refueling Outage (RFO is taking credit for Quarterly Test) 917/10 As Found 3055 119419 9/7/10 As 10460 116703 Found 6/7/10 As Found 339 105880 6/7/10 As 8347 116213 Found A4-2

FNP Unit 1 Containment Purge Air System Containment Isolation Valves Leakage History (Quarterly Tests)

Pen 12 Pen 13 Q1P13V302 /Q1P13V282 / Q1P13V301 /

Q1P13V301 /Q1P13V281 / Q1P13V303 /

Q1P13V281 Q1P13V284 Date Test Leak Acceptance Date Test Leak Acceptance Type Rate Criteria Type Rate Criteria (seem)

(seem)

(seem)

(seem) 3/19/10 As Found 8002 98325 3/19/10 As 11553 91469 Found 1/15/10 As Found 1146 134864 2/15/10 As 28634 126309 Found 9/30/09 As Found 528 135789 9/30/09 As 650 135296 Found 7/8/09 As Found 35 133750 7/8/09 As 231 133184 Found 1 F22 Refuelinq Outaqe (RFO is takinq credit for Quarterly Test)

A4-3

Joseph M. Farley Nuclear Plant - Units 1 and 2 License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.5 Unit 2 Quarterly Containment Purge Air System Containment Isolation Valve Leakage History

FNP Unit 2 Containment Purge Air System Containment Isolation Valves Leakage History (Quarterly Tests)

Pen 12 Pen 13 Q2P13V302/Q2P13V282/Q2P13V301/ Q2P13V301/Q2P13V281/Q2P13V303/

Q2P13V281 Q2P13V284 Date Test Leak Acceptance Date Test Leak Acceptance Type Rate Criteria Type Rate Criteria (seem)

(seem)

(seem)

(seem) 1/6/22 As Found 380 134677 1/6/22 As 347 134698 Found 10/8/21 As Found 159 134702 10/8/21 As 328 134705 Found 7/8/21 As Found 155 134754 7/8/21 As 325 135004 Found 4/18/21 As Found 405 134222 4/18/21 As 17 133340 Found 1/8/21 As Found 936 135159.9 1/8/21 As 26 135185 Found 2F27 Refuelinq Outaqe (RFO is~ ivinq credit to 1st Quarterly Test) 7/8/20 As Found 6404 118518 7/8/20 As 90 112803 Found 4/9/20 As Found 689 113923 4/9/20 As 360 110317 Found 1/8/20 As Found 8890 121112 1/8/20 As 3966 118062 Found 11/6/19 As Found 1455 118319 11/6/19 As 3656 121369 Found 8/14/19 As Found 1198 123173 8/14/19 As 606 121975 Found 2F26 Refuelinq Outaqe (RFO is~ ivinq credit to 1st Quarterly Test) 2/28/19 As Found 4380 108166 2/28/19 As 1690 120876 Found 12/19/18 As Found 17090 126821 12/19/18 As 2817 108198 Found 10/12/18 As Found 512 123289 10/12/18 As 1045 123821 Found 6/20/18 As Found 1467 124207 6/20/18 As 513 123901 Found 3/28/18 As Found 1387 121497 3/28/18 As 1658 121204 Found 1/4/18 As Found 1094 114823 1/4/18 As 1353 111821 Found 2F25 Refueling Outage (RFO is NOT taking credit for Quarterly Test since it was completed prior to RFO) 10/11/17 As Found 104 110637 10/11/17 As 1876 111323 Found 7/27/17 As Found 790 110647 7/27/17 As 1525 110192 Found 5/19/17 As Found 780 111388 5/19/17 As 1980 110972 Found 2/2/17 As Found 365 111230 2/2/17 As 1200 109966 Found 12/8/16 As Found 523 112215 12/8/16 As 2464 112021 Found 8/16/16 As Found 1330 123704 8/16/16 As 2658 123746 Found 2F24 Refueling Outage (RFO is taking credit for Quarterly Test)

AS-1

FNP Unit 2 Containment Purge Air System Containment Isolation Valves Leakage History (Quarterly Tests)

Pen 12 Pen 13 Q2P13V302 /Q2P13V282 / Q2P13V301 /

Q2P13V301/Q2P13V281/Q2P13V303/

Q2P13V281 Q2P13V284 Date Test Leak Acceptance Date Test Leak Acceptance Type Rate Criteria Type Rate Criteria (seem)

(seem)

(seem)

(seem) 3/4/16 As Found 1020 123424 3/4/16 As 2127 123424 Found 12/10/15 As Found 765 122542 12/10/15 As 2565 122442 Found 9/25/15 As Found 665 128648 9/25/15 As 3363 128585 Found 6/26/15 As Found 2774 126387 6/26/15 As 602 128668 Found 3/27/15 As Found 582 121767 3/27/15 As 5055 121767 Found 1/8/15 As Found 278 125622 1/8/15 As 5405 122429 Found 2F23 Refueling Outage (RFO is taking credit for Quarterly Test) 9/26/14 As Found 748 123927 9/26/14 As 505 123519 Found 6/30/14 As Found 340 122454 6/30/14 As 494 123370 Found 4/7/14 As Found 642 123818 4/7/14 As 624 123707 Found 2/1/14 As Found 531 123856 2/1/14 As 412 123817 Found 10/3/13 As Found 495 119267 10/30/13 As 414 119220 Found 8/6/13 As Found 445 119267 8/6/13 As 1488 121509 Found 2F22 Refueling Outage (RFO is taking credit for Quarterly Test) 3/21/13 As Found 2687 128671 3/21/13 As 880 126251 Found 1/11/13 As Found 880 128716 1/11/13 As 550 128416 Found 10/4/12 As Found 835 128449 10/4/12 As 850 128449 Found 7/12/12 As Found 3200 128501 7/12/12 As 2361 126089 Found 4/29/12 As Found 788 128523 4/29/12 As 795 128523 Found 1/27/12 As Found 1385 126979 1/27/12 As 773 126362 Found 2F21 Refueling Outage (RFO is taking credit for Quarterly Test) 9/7/11 As Found 3076 126739 9/7/11 As 4495 125244 Found 6/20/11 As Found 1581 126243 6/20/11 As 2111 126324 Found 3/21/11 As Found 1662 125620 3/21 /11 As 2526 126646 Found 1 /12/11 As Found 2285 124889 1/12/11 As 1500 125124 Found 10/6/10 As Found 2520 106450 10/6/10 As 3040 113208 Found 8/4/10 As Found 9278 126739 8/4/10 As 14714 118733 Found AS-2

FNP Unit 2 Containment Purge Air System Containment Isolation Valves Leakage History (Quarterly Tests)

Pen 12 Pen 13 Q2P13V302 /Q2P13V282 / Q2P13V301 /

Q2P13V301/Q2P13V281/Q2P13V303/

Q2P13V281 Q2P13V284 Date Test Leak Acceptance Date Test Leak Acceptance Type Rate Criteria Type Rate Criteria (seem)

(seem)

(seem)

(seem) 2F20 Refueling Outage (RFO is NOT taking credit for Quarterly Test since it was completed prior to RFO) 3/30/10 As Found 1272 127435 3/30/10 As 755 126753 Found 1/5/10 As Found 16950 130771 1/5/10 As 2875 114440 Found 10/1/09 As Found 649 130690 10/1/09 As 73.5 130813 Found 7/9/09 As Found 772 130829 7/9/09 As 31 130092 Found 5/3/09 As Found 34.2 129639 5/3/09 As 610 130534 Found 1/21/09 As Found 930 129983 1/21/09 As 905 129253 Found 2F19 Refuelina Outaae (RFO is taking credit for Quarterly Test)

AS-3