ML24200A139
| ML24200A139 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 07/25/2024 |
| From: | Turner Z Plant Licensing Branch II |
| To: | Coleman J Southern Nuclear Operating Co |
| Turner, Zachary | |
| References | |
| EPID L-2024-LLA-0098 | |
| Download: ML24200A139 (1) | |
Text
July 25, 2024
Jamie M. Coleman Regulatory Affairs Director Southern Nuclear Operating Co., Inc.
3535 Colonnade Parkway Birmingham, AL 35243
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 -
REGULATORY AUDIT IN SUPPORT OF REVIEW OF THE LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATION 3.6.5, CONTAINMENT AIR TEMPERATURE (EPID L-2024-LLA-0098)
Dear Jamie Coleman:
By letter dated July 18, 2024 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML24201A107 - non-publicly available; ML24201A108
- publicly available), 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) 3.6.5, C ontainment Air Temperature, Actions upon exceeding the containment average air te mperature limit of 120 degrees Fahrenheit
(°F), and remove an expired Limiting Conditi on for Operation (LCO) Note. Specifically, the change would modify the TS 3.6.5 Actions if containment average air temperature exceeds the LCO of 120 degrees °F to allow continued operation for up to seven cumulative days per calendar year prov ided that the containment average air temperature does not exceed 122°F (verified within eight hours of containment average air temperature exceeding 120°F and once per eight hours thereafter) and that refueling water storage tank temperature remains less than or equal to 100°F (verified within eight hours of containment average air temperature exceeding 120°F and once per eight hours thereafter).
The U.S. Nuclear Regulatory Commission (NRC) staff has determined the need for a regulatory audit to be conducted in accordan ce with Office of Nuclear Reactor Regulation Office Instruction LIC-111, Regulatory Audits (ML19226A274), for the NRC staff to examine the licensees non-docketed information with the intent to gain a better understanding of the LAR, to verify informat ion, and to identify information that may require docketing to support the basis of the NRC staffs licensing decision.
J. Coleman
The NRC staff will conduct a hybrid formatted audit, both in person and virtually via Teams, potentially using a licensee-established electronic portal available to NRC staff, from approximately July 30, through August 13, 2024, with formal audit meetings to be scheduled during this period as needed. The NRC staff reserves the right to extend the audit, if necessary. The detailed audit plan is enclosed with this letter. Any subsequent changes to logistical aspects of the audit will be coordinated with and communicated to your staff.
If you have any questions, please contact me at (301) 415-2258 or by e-mail at Zachary.Turner@nrc.gov.
Sincerely,
/RA/
Zachary M. Turner, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos. 50-348 and 50-364
Enclosure:
Audit Plan
cc: Listserv
REGULATORY AUDIT PLAN
BY THE OFFICE OF NUCLEAR REACTOR REGULATION
TO SUPPORT THE REVIEW OF THE LICENSE AMENDMENT REQUEST
TO REVISE TECHNICAL SPECIFICATION 3.6.5, CONTAINMENT AIR
TEMPERAURE,
SOUTHERN NUCLEAR OPERATING COMPANY
JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2
DOCKET NOS. 50-348 AND 50-364
1.0 BACKGROUND
By letter dated July 18, 2024 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML24201A107 - non-publicly available; ML24201A108
- publicly available), 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) 3.6.5, Containment Air Temperature, Actions upon exceeding the containment average air temperature limit of 120 degrees Fahrenheit
(°F), and remove an expired Limiting Condition for Operation (LCO) Note. Specifically, the change would modify the TS 3.6.5 Actions if containment average air temperature exceeds the LCO of 120 degrees °F to allow continued operation for up to seven cumulative days per calendar year provided that the containment average air temperature does not exceed 122°F (verified within eight hours of containment average air temperature exceeding 120°F and once per eight hours thereafter) and that refueling water storage tank temperature remains less than or equal to 100°F (verified within eight hours of containment average air temperature exceeding 120°F and once per eight hours thereafter).
The U.S. Nuclear Regulatory Commission (NRC) staff has determined the need for a regulatory audit to be conducted in accordance with Office of Nuclear Reactor Regulation Office Instruction LIC-111, Regulatory Audits (ML19226A274), for the NRC staff to examine the licensees non-docketed information with the intent to gain a better understanding of the LAR, to verify information, and to identify information that may require docketing to support the basis of the NRC staffs licensing decision.
2.0 REGULATORY AUDIT BASIS
A regulatory audit is a planned license-or regulation-related activity that includes the examination and evaluation of primarily non-docketed information associated with the
Enclosure
LAR. An audit is conducted to gain understanding, to verify information, and to identify information that will require docketing to support the basis of a licensing or regulatory decision. An audit will assist the NRC staff in efficiently conducting its review and gaining insights to the licensees processes and procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket.
This audit will be conducted in accordance with NRR Office Instruction LIC-111, Regulatory Audits, Revision 1, dated October 2019 (ML19226A274), with any exceptions noted within this audit plan.
The NRC staff (i.e., audit team) will perform the audit to support its evaluation of whether SNCs request meets the standards of sections 50.36, Technical specifications, and 50.46, Acceptance criteria for emergency core cooling systems for light-water nuclear power plants, of Title 10 of the Code of Federal Regulations (10 CFR).
3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY
NRCs objectives of the audit are the following:
Gain a better understanding of the evaluation and supporting analyses performed in support of the LAR and confirm the NRC staffs understanding of the LAR.
Gain a better understanding of the plants relevant design features and safety analysis implications for the LAR.
Gain a better understanding of the methodologies and plant-specific analyses used to justify the proposed changes in this LAR.
Identifying any information needed to enable the NRC staffs evaluation of whether the proposed changes challenge design-basis functions or adversely affect the capability or capacity of plant equipment to perform its safety functions.
Identifying questions and requests that may become formal requests for additional information (RAIs) per NRR Office Instruction LIC-115, Processing Requests for Additional Information (ML21141A238).
4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE AUDIT
The NRC staff will request information throughout the audit period. The NRC staff will identify the information to be audited (e.g., methodology, process information, and calculations) and the subjects of requested meetings.
The NRC staff requests access to the following documents:
Item # Audit Item 1 Large Break Loss of Coolant Accident (LOCA) Peak Cladding Temperature Rack-Up Calculations and Methodology details for Plants A and B to support acceptable evaluation model that realistically models FNP consistent with 10 CFR 50.46 requirements.
2 Gothic calculations performed for the Net Positive Suction Head (NPSH) margin for Residual Heat Removal and Containment Spray Pumps 3 Calculation of sump strainer head loss showing that the losses decrease as the sump temperature increases above 140°F. This calculation should confirm that the competing effects between vapor pressure of the sump inventory and strainer head losses, the pump NPSH margin would be expected to increase or stay the same as the sump temperature increases above 212°F 4 Probabilistic Risk Assessment (PRA) related documents:
- a. Documents supporting the results of PRA screening and evaluation of human failure events (HFEs) and success criteria impacted by increased containment temperature, as presented in LAR Section 3.4 and Tables 3.4-1, 3.4-2, and 3.4-3.
- b. PRA quantification notebooks that support the information provided in Tables 3.4-4, 3.4-5, and 3.4-6.
- c. PRA uncertainty analysis report that supports the uncertainty evaluation conclusions in Section 3.4.5.
- d. A report on focused-scope peer review (FSPR) performed in January 2023 on the upgraded Farley PRA and disposition of the F&Os resulting from the FSPR.
5 Accumulator sensitivity studies performed to support the Farley LAR 6 Plant specific analysis performed for FNP as per the Code Qualification Document (CQD) methodology (WCAP-12945-P-A) limitation stated in the NRC transmittal letter for the approval of the WCAP-12945-P-A (ML20113E156) 7 Documents supporting Small Break LOCA show a 0°F impact from the proposed change to support containment air temperature to 122 °F 8 Documents or evaluations supporting assurance of equipment operability and containment integrity during design basis accident conditions relevant to this LAR, service water and ultimate heat sink evaluations relevant to this LAR, Generation III reactor coolant pump seals, and LAR section 3.5 Implementation and Monitoring Plan.
The NRC staff requests the licensee to have the information identified above available and accessible for the NRC staffs review via a web-based electronic portal within one week, or earlier, of the date of this audit plan. The NRC staff requests that any supplemental information requested be available and accessible for the NRC staffs review within approximately one week of the date of the NRCs notification to the licensee of the new requests. The NRC staff requests the licensee to notify the audit
team when the audit item is added to its electronic portal by sending an email to the NRC licensing project manager. The NRC will document the final audit items list as an enclosure to the audit report, which will be publicly available.
The NRC staff requests the licensee to coordinate the facilities to be readily available and accessible for the staffs review via a third-party location to support a day of in person audit.
The staff acknowledges and will observe appropriate handling and protection of proprietary information made available for the audit. Any information accessed through the licensees portal will not be held or retained in any way by NRC staff.
5.0 AUDIT TEAM
The audit team will consist of the following NRC staff:
Zachary Turner, Division of Operating Reactor Licensing (DORL)/Plant Licensing Branch 2-1 (LPL2-1)
David Nold, Division of Safety Systems (DSS)/Containment and Plant Systems Branch (SCPB)
Nicholas Soliz, DSS/SCPB Ahsan Sallman, DSS/SNSB Santosh Bhatt, DSS/SNSB Steve Smith, DSS/Technical Specification Branch John Lehning, DSS/Nuclear Methods and Fuels Branch Sunwoo Park, Division of Risk Assessment (DRA)/Plant Licensing Branch C (APLC)
Keith Tetter, DRA/APLC Matthew McConnell, Division of Engineering and External Hazards/Long Term Operations and Modernization Branch
6.0 LOGISTICS
The audit will be conducted from July 30-August 13, 2024 in a hybrid format. The in-person portion of the audit will be held on July 31, 2024 at a third-party facility in Rockville, MD. The virtual audit will be conducted using a secure, online electronic portal, established by the licensee to present supporting documentation and calculations and by teleconferences with SNCs subject matter experts, virtually. The audit will begin within one week of the date of this audit plan (approximately July 30, 2024) and last through August 13, 2024. The NRC will establish a schedule of audit teleconferences on mutually agreeable dates and times to discuss information needs and questions arising from the NRCs review of the audited items. The NRCs licensing project manager will inform the licensee of audit meeting dates when they are established. Audit meeting agenda and questions will be sent in advance of the audit teleconferences.
7.0 SPECIAL REQUESTS
For the July 31, 2024 in-person portion of the audit, the NRC would like access to the following equipment and services:
Enclosed conference room (or comparable space) with a table, chairs sufficient to accommodate NRC participants and supporting licensee staff; Access to any documentation applicable for this audit. Document format can be electronic or physical at your discretion; and Access to knowledgeable licensee personnel, as appropriate, to discuss staff information needs.
For the virtual portion of the audit, the NRC requests access to requested documents and information through a Web-based portal that allows the NRC staff and contractors to access documents over the Internet. The following conditions associated with the online portal must be maintained while the NRC staff and contractors have access to the online portal:
The online portal will be password-protected. A separate password will be assigned to each member of the NRC staff and NRC contractors participating in the audit.
The online portal will prevent the NRC participants from printing, saving, downloading, or collecting any information directly from the online portal.
Conditions of use of the online portal will be displayed on the login screen and will require acknowledgment by each user.
Username and password and/or other Web-based portal access information should be provided directly to members of the NRC staff and contractors as needed. The NRC licensing project manager will provide the licensee with names and contact information of the NRC staff and contractors participating in the audit. All other communications should be coordinated through the NRC project manager. The NRCs project manager will inform the licensee via routine communications when the NRC staff no longer needs access to the electronic portal.
No data accessed by the audit team members will be retained by the NRC following the conclusion of the audit.
8.0 DELIVERABLES
An audit summary will be prepared within approximately 60 days of the completion of the audit. If the NRC staff identifies information during the audit that is needed to support its regulatory decision, the NRC staff will issue separate requests for additional information to the licensee per NRR Office Instruction LIC-115, Processing Requests for Additional Information (ML21141A238).
ML24200A139 OFFICE NRR/DORL/LPLII-1/PM NRR/DORL/LPLII-1/LA NRR/DRA/APLC/BC NAME ZTurner KGoldstein SVasavada (SAlferink for)
DATE 07/22/2024 07/22/2024 07/24/2024 OFFICE NRR/DSS/SCPB/BC NRR/DSS/SNSB/BC NRR/DSS/STSB NAME MValentin PSahd SMehta DATE 07/24/2024 07/25/2024 07/25/2024 OFFICE NRR/DORL/LPLII-1/BC NRR/DORL/LPLII-1/PM NAME MMarkley ZTurner DATE 07/25/2024 07/25/2024