ML23086A023

NRR E-mail Capture - for Your Action - Draft RAIs - Farley Surveillance Requirement (SR) 3.6.3.5 License Amendment Request (LAR) (L-2022-LLA-0189)

ML23086A023
Person / Time
Site:	Farley
Issue date:	03/24/2023
From:	John Lamb Plant Licensing Branch II
To:	Sparkman W Southern Nuclear Operating Co
References
L-2022-LLA-0189
Download: ML23086A023 (5)

Text

From: John Lamb Sent: Friday, March 24, 2023 5:37 PM To: Sparkman, Wesley A.

Cc: Joyce, Ryan M.

Subject:

For Your Action - DRAFT RAIs - Farley SR 3.6.3.5 LAR (L-2022-LLA-0189)

Importance: High

Wes, Below is the draft request for additional information regarding the Southern Nuclear Operating Company (SNC) Farley, Units 1 and 2, Surveillance Requirement (SR) 3.6.3.5 license amendment request (LAR). The draft RAI is being sent to you to ensure that it is understandable, the regulatory basis is clear, to ensure there is no proprietary information, and to determine if the information was previously docketed. Additionally, review of the draft RAI allows SNC to evaluate and agree upon a schedule to respond to the RAI. Please let me know if SNC wishes to have a clarification call. If so, what is SNCs availability (multiple days and times) so I can find a mutually agreeable day and time for the NRC technical staff?

If SNC does not respond by noon on March 30, 2023, I plan to issue the RAIs with a 30-day response date.

Thanks.

John DRAFT REQUEST FOR ADDITIONAL INFORMATION (RAI)

By letter dated December 20, 2022 (Agencywide Documents and Access Management System Accession No. ML22354A087), Southern Nuclear Operating Company (SNC, the licensee) submitted a license amendment request (LAR) for Joseph M. Farley Nuclear Plant (Farley),

Units 1 and 2. The proposed LAR would revise the Farley, Units 1 and 2, Technical Specification (TS) 3.6.3, Containment Isolation Valves, Surveillance Requirement (SR) 3.6.3.5 to eliminate event-based testing of containment purge valves with resilient seals. The proposed LAR would eliminate And within 92 days of opening the valve from SR 3.6.3.5.

The Nuclear Regulatory Commission (NRC) staff reviewed the LAR and the NRC staff determined that more information is needed to complete its review.

Regulatory Analysis Basis In Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36, Technical specifications, the U.S. Nuclear Regulatory Commission (NRC) establishes its regulatory requirements related to the content of TSs. Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) SRs; (4) design features; and (5) administrative controls. The regulation does not specify the particular requirements to be included in plants TSs.

The regulation 10 CFR part 50, Appendix J, Option B, Primary Reactor Containment Leakage Testing For Water-Cooled Power Reactors, Performance-Based Requirements, provides assurance that leakage through these containments or systems and components penetrating these containments does not exceed allowable leakage rates specified in the TS, and integrity of the containment structure is maintained during its service.

General Design Criteria 54, 55, 56, and 57 of Appendix A to 10 CFR Part 50 require, in part, that piping systems penetrating primary reactor containment be provided with isolation capabilities that reflect the importance to safety of isolating these piping systems.

Regulatory Guide (RG) 1.163, Performance-Based Containment Leak-Test Program (ML003740058), provides guidance on an acceptable performance-based leak-test program, leakage rate test methods, procedures, and analyses that may be used to comply with the performance-based Option B in Appendix J to 10 CFR Part 50.

Request for Additional Information EMIB-RAI-1 The LAR dated December 20, 2022, submitted by SNC, Section 3.4, Surveillance Frequency Control Program, second and third paragraph, state:

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

[Surveillance Frequency Control Program] and any changes to the testing Frequency will be evaluated in accordance with the SFCP following the process in NEI [Nuclear Energy Institute] 04-10, Revision 1.

FNP [Farley Nuclear Plant] 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 [Title 10 of the Code of Federal Regulations] Part 50, Appendix J, Revision 3-A. NEI 94-01 requires the containment purge and vent valve testing Frequency to not exceed 30 months.

[Emphasis added.] Therefore, the testing Frequency established by the SFCP cannot exceed this length.

The updated Farley Technical Specification (TS) Section SR 3.6.3.5 states:

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

Frequency: In accordance with the Surveillance Frequency Control Program (SFCP).

The NRC Safety Evaluation (SE) printed in NEI 94-01, Revision 3-A, Section 4.0, LIMITATIONS AND CONDITIONS (Reference 3 - ML12221A202) states:

The NRC staff finds that the guidance in NEI 94-01, Revision 3, is acceptable for referencing by licensees in the implementation for the optional performance-based requirements of Option B to 10 CFR Part 50, Appendix J. However, the NRC staff identified two conditions on the use of NEI 94-01, Revision 3.

As described above, LAR Section 3.4 and Farley TS 5.5.17 state that NEI 94-01 requires the containment purge and vent valve testing Frequency to not exceed 30 months. However, NEI 94-01, Revision 3-A (which is referenced in TS 5.5.17) allows valve testing beyond 30 months.

a. Please clarify and explain the discrepancy between the LAR Section 3.4 regarding the valve testing frequency not to exceed 30 months and TS 5.5.17 (and NEI 94-01, Revision 3-A) which allows extension of the valve testing frequency beyond 30 months.

b. Please explain the wording in Section 3.4, second paragraph, last sentence, which states Frequency will be evaluated in accordance with the SFCP following the process in NEI 04-10, Revision 1. However, TS 5.5.17 references NEI-94-01, Revision 3-A.

EMIB-RAI-2 Farley, Units 1 and 2, Fifth 10-Year Interval Inservice Testing (IST) Program includes containment isolation valves (Reference 2 - ML19070A247). Please provide a response to the following:

a. Explain the impact of the deleted 92 days requirements on the Farley, Units 1 and 2, IST Program.

b. Containment Purge Valves are included in the Farley, Units 1 and 2, Fifth 10-Year IST Program (ML19070A247). Farley IST Program lists P13 - Containment Purge Valves Q1(2)P13V0281, Q1(2)P13V0282, Q1(2)P13V0283, Q1(2)P13V0284 in Section 10 Unit 1 Valve Table on pages 55 and 56, and Section 11 Unit 2 Valve Table on pages 55 and 56. Tables Frequency Colum list Frequency as LJ (Leak testing by Appendix J) and Plan Notes Column list STC see Note 3 (Abbreviation STC is Stroke Time Close).

Farley IST Program, Section 9, Valves Notes, Note No. 3 states that Any change in the frequency or components being tested by this surveillance will require reevaluation of Farley CR 558904 in accordance with Surveillance Frequency Control Program (SFCP).

Please explain and clarify the difference between leak testing frequencies of Containment Purge Valves as specified in Farley Fifth 10-Year IST Program versus SFCP as specified in the Farley TS.

EMIB-RAI-3 The current TS SR 3.6.3.5, Bases, states:

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 valve. 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. [This paragraph is being deleted under the submitted LAR.]

First paragraph, third sentence, states that this type of seal has potential to degrade in a shorter time than do other seal types. By deleting SR requirements of 92 days, please explain the following:

a. How the valve resilient seal degradation will be measured.

b. Its impact on the degradation of the valves.

Hearing Identifier: NRR_DRMA Email Number: 2015 Mail Envelope Properties (MN2PR09MB50849827ADF6927CC6219AB1FA849)

Subject:

For Your Action - DRAFT RAIs - Farley SR 3.6.3.5 LAR (L-2022-LLA-0189)

Sent Date: 3/24/2023 5:37:27 PM Received Date: 3/24/2023 5:37:00 PM From: John Lamb Created By: John.Lamb@nrc.gov Recipients:

"Joyce, Ryan M." <RMJOYCE@southernco.com>

Tracking Status: None "Sparkman, Wesley A." <WASPARKM@southernco.com>

Tracking Status: None Post Office: MN2PR09MB5084.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 8794 3/24/2023 5:37:00 PM Options Priority: High Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: