NL-23-0069, Correction of Technical Specification Omission and Typographical Error
| ML23020A932 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 01/20/2023 |
| From: | Gayheart C Southern Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| NL-23-0069 | |
| Download: ML23020A932 (1) | |
Text
3535 Colonnade Parkway Birmingham, AL 35243 205 992 5316 tel 205 992 7601 fax cagayhea@southernco.com Cheryl A. Gayheart Regulatory Affairs Director January 20, 2023 Docket No.: 50-366 NL-23-0069 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Edwin I. Hatch Nuclear Plant - Unit 2 Correction of Technical Specification Omission and Typographical Error
References:
- 1. ML22297A146 - Edwin I. Hatch Nuclear Plant, Unit Nos. 1 and 2 - Issuance of Amendments Nos. 319 and 264 Regarding Revision to Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Iniative 4b (EPID L-2021-LLA-0199)
- 2. Proposed Guidance for Correction of Technical Specification Typographical Errors, SECY-96-238, November 19, 1996 Ladies and Gentlemen:
This letter requests Nuclear Regulatory Commission (NRC) approval of a correction of an omission and a typographical error in the Hatch Nuclear Plant (HNP) Unit 2 Technical Specifications (TS).
This omission and typographical error occurred during the processing of License Amendment 264 for HNP Unit 2 (Reference 1), where part of TS 3.6.1.3 Completion Time A.3 (A.2 prior to Amendment 264) was inadvertently omitted and a typographical error was introduced in the footer of TS page 3.7-2. The omission and typographical error were neither addressed in the notice to the public nor reviewed by the NRC, and thus fall within the scope of the guidance provided by SECY-96-238 (Reference 2).
describes the omission, typographical error, and correction. Enclosure 2 provides the page from Amendment 264 as issued, with the requested correction noted. Enclosure 3 contains the corrected page for Amendment 264.
U. S. Nuclear Regulatory Commission NL-23-0069 Page 2 of 2 Respectfully submitted, C. A. Gayheart Director, Regulatory Affairs Southern Nuclear Operating Company CAG/agq/cg Description of Technical Specification Omission and Typographical Error Marked Up Technical Specification Pages Revised Technical Specification Pages cc:
Regional Administrator, Region ll NRR Project Manager - Hatch Senior Resident Inspector - Hatch Director, Environmental Protection Division - State of Georgia RType: CHA02.004
Edwin I. Hatch Nuclear Plant - Unit 2 Correction of Technical Specification Omission and Typographical Error Enclosure to NL-23-0069 Description of Technical Specification Omission and Typographical Error to NL-23-0069 Description of Technical Specification Omission and Typographical Error Page 2 of 3 1.0 REQUESTED ACTION Consistent with the information contained in SECY-96-238, Southern Nuclear Operating Company (SNC) is requesting corrections of an omission and a typographical error that were inadvertently introduced into the Hatch Nuclear Plant (HNP) Unit 2 Technical Specifications (TS). The marked-up TS pages included in the original application for license amendment were correct (ML21300A153). The omission and typographical error were introduced by the SNC staff in development of the revised pages supplied to NRC for issuance with the amendment approval letter. The requested corrections are intended to restore the affected pages to the condition intended by the amendment application.
2.0 OMISSION AND TYPOGRAPHICAL ERROR The specific details of the omission and the typographical error are as follows:
- a. HNP Unit 2 TS page 3.6-8 Amendment No. 264 approved the addition of following isolation to the first Completion Time for Required Action A.3 (prior to Amendment 264, this was Required Action A.2) as shown below - blue underline font indicates text that was requested to be added by the application for license amendment and italicized text indicates text that was inadvertently omitted from the revised Unit 2 TS page:
Once per 31 days following isolation for isolation devices outside primary containment However, the clean page issued with HNP Unit 2 amendment 264 omitted the text for isolation, which was not requested to be deleted. This omission was introduced by SNC staff in the development of the revised pages supplied to the NRC staff for issuance with the amendment. For consistency with the approved Technical Specifications, the words for isolation should be added back.
- b. HNP Unit 2 TS page 3.7-2 Amendment No. 264 approved the addition of Risk Informed Completion Times (RICTs) for TS 3.7.1 Required Actions B.1 and C.1. The addition of RICTs pushed text from page 3.7-1 to 3.7-2. The left side of the page 3.7-2 footer has a typographical error - the number 5 appears prior to HATCH UNIT 2 as shown below. SNC staff introduced this typographical error in the development of the revised pages 3.7-1 and 3.7-2 and supplied it to the NRC for issuance with the amendment.
For consistency with the approved Technical Specifications, the 5 preceding HATCH UNIT 2 in the footer of page 3.7-2 should be removed.
5HATCH UNIT 2 3.7-2 Amendment No. 264 to NL-23-0069 Description of Technical Specification Omission and Typographical Error Page 3 of 3
- 3.
CORRECTION TO AFFECTED PAGES SECY-96-238 (Reference 2) provides guidance to correct inadvertent typographical errors in the Technical Specifications. The omission and typographical error described above were neither posted in the public notices nor were they reviewed by NRC as part of the license amendment process. Therefore, they may be corrected without a license amendment.
Edwin I. Hatch Nuclear Plant - Unit 2 Correction of Technical Specification Omission and Typographical Error to NL-23-0069 Marked-up Technical Specification Pages consists of 2 pages, excluding this cover page
PCIVs 3.6.1.3 HATCH UNIT 2 3.6-8 Amendment No. 264 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
(continued)
A.2
NOTE-----------
Only applicable to main steam line.
Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.
AND A.3
NOTES-----------
- 1. Isolation devices in high radiation areas may be verified by use of administrative means.
- 2. Isolation devices that are locked, sealed, or otherwise secured may be verified by administrative means.
Verify the affected penetration flow path is isolated.
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> OR In accordance with the Risk Informed Completion Time Program Once per 31 days following isolation devices outside primary containment AND Prior to entering MODE 2 or 3 from MODE 4 if primary containment was de-inerted while in MODE 4, if not performed within the previous 92 days, for isolation devices inside primary containment (continued)
Insert "for isolation"
RHRSW System 3.7.1 5HATCH UNIT 2 3.7-2 Amendment No. 264 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME D.
Required Action and associated Completion Time of Condition A, B, or C not met.
D.1
NOTE---------
LCO 3.0.4.a is not applicable when entering MODE 3.
Be in MODE 3.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> E.
Both RHRSW subsystems inoperable for reasons other than Condition B.
NOTE------------------
Enter applicable Conditions and Required Actions of LCO 3.4.7 for RHR shutdown cooling made inoperable by RHRSW System.
E.1 Restore one RHRSW subsystem to OPERABLE status.
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> F.
Required Action and associated Completion Time of Condition E not met.
F.1 Be in MODE 3.
AND F.2 Be in MODE 4.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 Verify each RHRSW manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position or can be aligned to the correct position.
In accordance with the Surveillance Frequency Control Program Delete "5"
Edwin I. Hatch Nuclear Plant - Unit 2 Correction of Technical Specification Omission and Typographical Error to NL-23-0069 Revised Technical Specification Pages consists of 2 pages, excluding this cover page
PCIVs 3.6.1.3 HATCH UNIT 2 3.6-8 Amendment No. 264 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
(continued)
A.2
NOTE-----------
Only applicable to main steam line.
Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.
AND A.3
NOTES-----------
- 1. Isolation devices in high radiation areas may be verified by use of administrative means.
- 2. Isolation devices that are locked, sealed, or otherwise secured may be verified by administrative means.
Verify the affected penetration flow path is isolated.
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> OR In accordance with the Risk Informed Completion Time Program Once per 31 days following isolation for isolation devices outside primary containment AND Prior to entering MODE 2 or 3 from MODE 4 if primary containment was de-inerted while in MODE 4, if not performed within the previous 92 days, for isolation devices inside primary containment (continued)
RHRSW System 3.7.1 HATCH UNIT 2 3.7-2 Amendment No. 264 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME D.
Required Action and associated Completion Time of Condition A, B, or C not met.
D.1
NOTE---------
LCO 3.0.4.a is not applicable when entering MODE 3.
Be in MODE 3.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> E.
Both RHRSW subsystems inoperable for reasons other than Condition B.
NOTE------------------
Enter applicable Conditions and Required Actions of LCO 3.4.7 for RHR shutdown cooling made inoperable by RHRSW System.
E.1 Restore one RHRSW subsystem to OPERABLE status.
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> F.
Required Action and associated Completion Time of Condition E not met.
F.1 Be in MODE 3.
AND F.2 Be in MODE 4.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 Verify each RHRSW manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position or can be aligned to the correct position.
In accordance with the Surveillance Frequency Control Program