NL-03-1470, Withdrawal of Request for Technical Specification Changes Deletion of LCO 3.6.1, Condition a and Addition of LCO 3.0.8, Inoperability of Non-Technical Specification Support Systems

Withdrawal of Request for Technical Specification Changes Deletion of LCO 3.6.1, Condition a and Addition of LCO 3.0.8, Inoperability of Non-Technical Specification Support Systems

ML032320208
Person / Time
Site:	Farley
Issue date:	08/18/2003
From:	Beasley J Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-03-1470
Download: ML032320208 (2)

Text

J. Barnie Beasley, Jr., P.E Southern Nuclear Vice President Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.7110 Fax 205.992.0341 S SOUTHERN August 18, 2003 COMPANY Energy to Serve YourWorld' Docket Nos.: 50-348 NL-03-1470 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Withdrawal of Request for Technical Specification Changes Deletion of LCO 3.6.1, Condition A and Addition of LCO 3.0.8. Inoperabilitv of Non-Technical Specification Support Systems Ladies and Gentlemen:

On December 26, 2001, Southern Nuclear Operating Company (SNC) submitted a proposed amendment to the Farley Nuclear Plant (FNP) Technical Specifications (TS),

Appendix A to Operating License(s) NPF-2 and NPF-8. This TS amendment would add a new LCO 3.0.8, based on TSTF-372, Rev. 0. If approved, this change would allow a delay time, consistent with the delay time that existed prior to the conversion to the Improved Technical Specifications (ITS), before entering a TS Limiting Condition for Operation (LCO) for a supported system. Adoption of the proposed LCO 3.0.8 would also eliminate the need for LCO 3.6.1, Condition A, which the proposed change would delete.

As part of the conversion to the ITS, the former TS requirements for snubbers and many other support systems were relocated to the Technical Requirements Manual (TRM) or other licensee controlled documents based on the fact that the TS requirements did not meet any of the four criteria of 10 CFR 50.36(cX)(2Xii) for inclusion in the ITS. The removal of these requirements from the TS was classified as a relocation as opposed to a more restrictive or less restrictive change. The NRC approved the relocation without restriction. Therefore, it was intended that when a non-TS support system (e.g., a snubber) could not perform the required safety function(s) for a system that is required to be OPERABLE by the TS, the licensee controlled document requirements (e.g., TRM) for the support system would be invoked before the system TS LCO would become applicable. Should the actions of the licensee controlled document requirements for the support system not be completed within the allocated time, the supported system would be declared inoperable and the Conditions and Required Actions of the TS LCO for that system followed. Subsequent to ITS implementation, the NRC has challenged this position making clarification necessary.

The Industry is currently working with the NRC to resolve this issue for snubbers, resulting in subsequent proposed revisions to TSTF-372. Therefore, in accordance A-CP

U. S. Nuclear Regulatory Commission NL-03-1470 Page 2 with the NRC request, SNC withdraws this amendment request until a resolution is reached between the NRC and the Industry for snubbers. At that time, SNC will determine what course of action will be taken to address the issue of snubbers as well as other support systems outside of TS for FNP.

Mr. J. B. Beasley, Jr. states he is a Vice President of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.

This letter contains no NRC commitments. If you have any questions, please advise.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY

- 4 . B. Beasley, Jr.

Sworn to andsubscribedbefore me this jl day of .A uciLa 2003.

Notary Public My commission expires: a_____

JBB/WAS/sdl cc: Southern Nuclear Operating Company Mr. J. D. Woodard, Executive Vice President Mr. D. E. Grissette, General Manager - Plant Farley Document Services RTYPE: CFA04.054; LC# 13810 U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. F. Rinaldi, NRR Project Manager - Farley Mr. T. P. Johnson, Senior Resident Inspector - Farley Alabama Department of Public Health Dr. D. E. Williamson, State Health Officer