ML24227A051
| ML24227A051 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 08/14/2024 |
| From: | Turner Z Plant Licensing Branch II |
| To: | Sparkman W Southern Nuclear Operating Co |
| Turner, Zachary | |
| References | |
| EPID L-2024-LLA-0044 | |
| Download: ML24227A051 (3) | |
Text
1 Zach Turner From:
Zach Turner Sent:
Wednesday, August 14, 2024 7:17 AM To:
Sparkman, Wesley A.
Cc:
John Lamb; Michael Markley; Joyce, Ryan M.; Joshua Wilson; Derek Scully; Rob Atienza; Shivani Mehta (She/Her/Hers); Milton Valentin
Subject:
Request for Additional Information - Farley, Units 1 and 2 - LAR to Revise TS SR 3.6.6.8 Frequency (EPID L-2024-LLA-0044)
Attachments:
Farley 1&2 - RAI for TS SR 3.6.6.8 Frequency Change LAR.docx
- Wes, By letter dated April 5, 2024 (ADAMS Documents and Access Management System (ADAMS) Accession No. ML24096B775), 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 change would revise the Frequency for Technical Specification (TS) Surveillance Requirement (SR) 3.6.6.8, Verify each spray nozzle is unobstructed.
To complete its review of the application, the U.S. Nuclear Regulatory Commission (NRC) staff requests additional information (RAI) as discussed in the attachment to this email. On August 12, 2024, NRC staff provided SNC the draft RAI questions 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 docketed previously. SNC confirmed that a clarification call would not be needed.
This request is now released formally with a 30-day calendar response period from the date of this email. If you have any questions, you may contact me at 301-415-2258.
Very Respectfully, Zach Turner, Project Manager Nuclear Regulatory Commission Division of Operating Reactor Licensing NRR/DORL/LPL2-1 (301) 415-2258 Office: OWFN-07C12 Mail Stop: O-08 B01A
1 REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FARLEY - UNITS 1 AND 2 - LAR TO REVISE TS SR 3.6.6.8 - CONTAINMENT SPRAY NOZZLE TEST FREQUENCY SOUTHERN NUCLEAR OPERATING COMPANY FARLEY, UNITS 1, 2 DOCKET NO. 05000348, 05000364 ISSUE DATE: 08/14/2024
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Background===
In the letter dated April 5, 2024 (ML24096B775), the Southern Nuclear Operating Company, Inc. (SNC, the licensee) requested changes to the Technical Specifications (TS) for Renewed Facility Operating License Nos. NPF-2 and NPF-8 for Joseph M.
Farley Nuclear Plant (Farley), Units 1 and 2, respectively. The proposed change would revise the Frequency for Surveillance Requirement (SR) 3.6.6.8, Verify each spray nozzle is unobstructed, from:
In accordance with the Surveillance Frequency Control Program to:
Following activities that could result in nozzle blockage.
As listed in Attachment 3 to the SNC's submittal, the licensee is proposing the following corresponding change to the SR 3.6.6.8 TS Bases:
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Activities that could cause nozzle blockage include inadvertent fluid flow through the nozzles, a loss of [Foreign Matter Exclusion] control within the system boundary or a major configuration change. An evaluation will determine if performance of this SR is required.
To complete its review of the application, U.S. Nuclear Regulatory Commission (NRC) staff determined that additional information is needed as described below.
Regulatory Basis 10 CFR 50.36(c)(3) requires that surveillance requirements are met to ensure that facility operation is within safety limits and that limiting conditions for operation are met.
Question 1
2 TS 5.5.14, "Technical Specification (TS) Bases Control Program," paragraph(b)(1) stipulates that licensees may make changes to Bases without prior NRC approval provided the changes do not require a change in the TS incorporated in the license; or a change to the updated Facility Safety Analysis Report or Bases that require NRC approval pursuant to 10 CFR 50.69. SNC's proposed TS Bases change does not match the Frequency requirements in SR 3.6.6.8. The licensee's proposed TS Bases statement, [a]n evaluation will determine if performance of this SR is required, implies that the surveillance will not always be performed following activities that could result in nozzle blockage and that an evaluation will be conducted to determine if performance of the SR is required.
The language in the TS Bases (Perform evaluation to determine if SR is required) appears to contradict the proposed TS change (Perform SR) that directs the surveillance be performed following activities that may cause nozzle blockage.
Clarify the proposed conforming TS Bases changes for SR 3.6.6.8 to ensure that the surveillance will be performed following activities that could result in nozzle blockage as stated in the proposed SR 3.6.6.8 Frequency.
OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL2-1/BC NRR/DSS/SCPB/BC NAME ZTurner MMarkley MValentin-Olmeda DATE 08/12/2024 08/08/2024 08/08/2024