Text

Exigent Technical Specification Revision Request for TS 3.5.4 Refueling Water Storage Tank (RWST)
	ML12059A327
Person / Time
Site:	Farley
Issue date:	02/28/2012
From:	Ajuni M; Southern Co, Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-12-0403
	Download: ML12059A327 (43)
	v • d • e

Mark J. Ajluni, P.E. Southern Nuclear Nuclea r Licensing Director Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Bi rm ingham. Alabama 35201 Tel 205.992.7673 Fax 205.992.7885 February 28, 2012 SOUTHERN'\'

COMPANY Docket Nos.: 50-348 NL-12-0403 50-364 U. S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Unit 1 & 2 Exigent Technical Specification Revision Request for TS 3.5.4 Refueling Water Storage Tank (RWST)

Ladies and Gentlemen:

On February 20, 2012, Southern Nuclear Operating Company (SNC) submitted a letter to the NRC requesting an exigent amendment to Farley Nuclear Plant (FNP) Unit 1 & 2 Technical Specifications (TS). The proposed change to the TS would allow the use of manual operator actions for TS 3.5.4, "Refueling Water Storage Tank." As a result of a subsequent phone call with the NRC on February 23, 2012, the need to define the appropriate period of applicability for the revision was identified, as well as the need to enhance the detail of the discussion of the subject operator action . This letter addresses those identified needs and this submittal supersedes the February 20 submittal (NL-12-0346) in its entirety.

Pursuant to 10 CFR 50.90 and 10 CFR 50.91 (a)(6), SNC hereby requests an exigent amendment to FNP Unit 1 & 2 Technical Specifications (TS), Appendix A to Operating License Nos. NPF-2 and NPF-8. The proposed TS change contained herein would revise 3.5.4, "Refueling Water Storage Tank" such that the non-seismically qualified piping of the Spent Fuel Pool (SFP) purification system may be connected to the RWST's seismic piping by manual operation of a RWST seismically qualified boundary valve under administrative controls for limited periods of time. These limited periods are specified as up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for performance of SR 3.5.4.3 and 30 days per fuel cycle per unit for filtration or remove silica from the RWST water. This change will only be applicable for the next two fuel cycles for each unit. The change cannot be used after Refueling Outages 1R26 (Spring 2015) and 2R24 (Spring 2016).

A description of the proposed changes and bases for the changes are provided in to this letter. The revised proposed TS and TS Bases changes are noted on annotated copies of the subject pages provided in Enclosures 2 and 3.

The responses to the NRC's request for additional information are provided in Enclosures 4 and 5.

SNC has determined that the proposed changes meet the requirements of 10 CFR 50.92(c) and do not involve a significant hazards consideration . This

U. S. Nuclear Regulatory Commission t\lL-12-0403 Page 2 request should be processed as an exigent change to minimize the amount of time the Containment Spray system is inoperable because of realignment to recirculate RWST water for the purposes discussed in Enclosure 1. In the matter of the filtration and silica removal prior to refueling, please note that the Farley Unit 1 outage is scheduled to begin April 1, 2012. SNC requests this TS change submittal be approved by March 19, 2012.

Mr. M. J. Ajluni states he is the Nuclear Licensing Director 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 contact Doug McKinney at (205) 992-5982.

Respectfully submitted, M. J. Ajluni Nuclear licensing Director Sw n to and s scribed before me this~,q t~ day of r~ ,2012.

QM.A..~ ~

Notary Public My commission expires: I(- 2 ~ 13*

MJAlEMW : Description and Evaluation of the Proposed Change : Marked-Up Technical Specifications and Bases Pages : Clean Technical Specifications and Bases Pages : Responses to Requests for Additional Information : Requested Procedures cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski , Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. T. A. Lynch, Vice President - Farley Mr. B. L. Ivey, Vice President - Regulatory Affairs Mr. B. J. Adams, Vice President - Fleet Operations RTYPE: CFA04.054 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Project Manager - Farley Mr. E. L. Crowe, Senior Resident Inspector - Farley

Joseph M. Farley Nuclear Plant Unit 1 & 2 Exigent Technical Specification Revision Request for TS 3.5.4 Refueling Water Storage Tank (RWST)

Enclosure 1 Description and Evaluation of the Proposed Change

Enclosure 1 Description and Evaluation of the Proposed Change Table of Contents 1.0 Summary Description 2.0 Detailed Description 3.0 Technical Evaluation 4.0 Regulatory Evaluation 4.1 Significant Hazards Consideration 4.2 Applicable Regulatory Requirements/Criteria 4.3 Conclusions 5.0 Environmental Consideration 6.0 References Page 2 of 13

Enclosure 1 Description and Evaluation of the Proposed Change 1.0 Summary Description This license amendment request is to amend Operating License Nos. NPF-2 and NPF-8 for Farley Nuclear Plant (FNP) Unit 1 & 2, respectively.

The proposed change involves:

The following Notes are being added to Technical Specification (TS) 3.5.4 "Refueling Water Storage Tank" "RWST piping may be unisolated from non-safety related piping for :5 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months under administrative controls to perform SR 3.5.4.3.*

RWST piping may be unisolated from non-safety related piping for :5 30 days per fuel cycle under administrative controls for filtration or silica removal. *"

These Notes can only be applied during the next two fuel Cycles for each Unit. These Notes cannot be used after Refueling Outages 1 R26 (Spring 2015) and 2R24 (Spring 2016).

In addition, the Technical Specification Bases will be revised to clarify administrative controls.

2.0 Detailed Description Historically, until February 15, 2012, Ff\lP was periodically using the Spent Fuel Pool (SFP) Purification Loop to filter the Refueling Water Storage Tank (RWST) water while in plant conditions and modes for which the RWST was required to be operable. This alignment was utilized for RWST water mixing prior to weekly surveillance sampling of the boron concentration as required by TS surveillance requirements (SR) 3.5.4.3 and typically for removal of silica from the RWST water prior to refueling outages. It was known that this system alignment could render the RWST inoperable during a seismic event since the SFP Purification Loop consisted of non-seismically qualified piping. To maintain operability, procedure changes were made to direct manual operator action to isolate the RWST from the SFP Purification Loop in the event of a Reactor Trip or at the direction of the Shift Supervisor. After reviewing Information Notice (IN) 2012-01, "Seismic Considerations- Principally Issues Involving Tanks," Southern Nuclear Operating Company (SNC) concluded that manual actions should not be credited for this purpose without prior NRC approval and subsequently discontinued this practice.

However, the original Ff\lP design of the RWST system affords no other way to re-circulate the RWST through seismically qualified piping without making an Engineering Safety Features (ESF) train inoperable to meet TS sampling requirements.

It is operationally desirable to take suction from the RWST through an existing tank drain line to facilitate RWST recirculation through the SFP Purification Loop Page 3 of 13

Enclosure 1 Description and Evaluation of the Proposed Change and a non-seismically qualified reverse osmosis system for the purposes of boron sampling and refueling water filtration. To accommodate this recirculation of the RWST water while the RWST is required to be operable, this License Amendment Request (LAR) proposes to allow the crediting of operator action to close a seismically qualified manual ASME code boundary valve connected to the subject RWST piping should a reactor trip occur or the Shift Supervisor directs the valve to be closed, thereby isolating the RWST from non-seismically qualified piping and maintaining its seismic qualification and operability.

A non-seismically qualified safety-related reverse osmosis system, identified as the Boric Acid Recovery System (BARS), is used to remove silica from the RWST water. Removal of silica is necessary to maintain Reactor Coolant System (RCS) chemistry within fuel requirements and to improve water clarity during refueling to prevent delays in fuel movement and facilitates safe handling of fuel. At FNP, the most practical method of ensuring RWST inventory is maintained, should a seismic event occur while removing silica from the RWST water is to credit operator action for manually isolating the BARS piping from the RWST piping.

Because the RWST water will also be required to be re-circulated through the SFP Purification Loop every seven days to perform required surveillance sampling of its boron concentration, the proposed change will also credit similar operator action during this system alignment as well.

During plant operations in Modes 1 through 4, the RWST is required to be operable to maintain a borated water supply for accident mitigation purposes.

The RWST is aligned to the suction of the residual heat removal pumps and the containment spray pumps during normal operation (Modes 1 through 4). The suction of the charging pumps is automatically aligned to the RWST on a safety injection signal. During refueling operation (Modes 5 and 6), the RWST is required to be operable as a borated water supply should the boric acid storage system not be operable. The contents of the RWST are also used to flood the refueling cavity during refueling operation. The water in the RWST is borated to a concentration sufficient to ensure that shutdown margin is maintained when the reactor is at cold shutdown conditions should RWST water be added to the reactor.

The SFP Purification Loop is a subsystem of the spent fuel pool cooling system that is connected to portions of the RWST piping. The SFP Purification Loop piping is non-safety grade and not seismically qualified. During an evaluation of a seismic event, the failure of the non-seismic SFP Purification Loop piping must be considered. Such a failure could potentially result in a loss of RWST inventory should the ASME code boundary valve between the RWST and the SFP Purification Loop be open with the SFP Purification Loop aligned to the RWST.

The primary function of the SFP Purification Loop is to maintain the optical clarity of the spent fuel pool water avoiding delays and providing for safer handling of the fuel. This system is also used to purify the refueling water in the refueling canal and the RWST. Prior to refueling outages, the SFP Purification Loop is used to filter the RWST prior to filling the refueling cavity. Further, the SFP Purification Loop is also used to re-circulate the RWST water to ensure a representative sample for the required boron concentration surveillance.

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Enclosure 1 Description and Evaluation of the Proposed Change The surveillance testing of the RWST boron concentration requires the sampling of the tank contents every seven days. In order to have proper mixing of the tank for accurate sample results, the tank must be re-circulated for approximately one hour. The alignment for recirculation requires unisolating the RWST piping from the SFP Purification Loop which is non-safety related and not seismically qualified. In order to perform this alignment, it is operationally desirable to credit operator action to close the RWST piping's seismically qualified manual code boundary valve in the event of a seismic event, thereby maintaining the RWST's seismic qualification.

The non-seismically qualified skid-mounted BARS system is to be used to reduce RWST silica concentration levels during power operation (a plant mode for which the RWST is required to be operable). Circulation of the RWST contents through the SFP Purification Loop is required when placing BARS in service. The BARS system is expected to be used for 30 days or less during each Unit's cycle to reduce RWST silica concentration.

Prior to February 15, 2012, interconnection of the SFP Purification Loop and the RWST piping was allowed under administrative controls while the RWST was required to be operable for the filtration and demineralization of the RWST inventory. To justify this configuration, operator action to close the seismically qualified manual code boundary valve was credited should a Loss of Coolant Accident (LOCA), Main Steam Line Break (MSLB), or seismic event occur. This operator action was intended to prevent a loss of RWST inventory below the Technical Specification (TS) limits if the postulated seismic event caused a system pressure boundary failure of the SFP Purification Loop piping while the code boundary valve was open. This closure of the subject boundary valve can be taken in sufficient time to ensure that the TS required volume of water is maintained in the RWST and the injection of sufficient coolant can be performed following a Reactor trip or at the direction of the Shift Supervisor.

In addition to the administrative controls, the TS will limit the amount of time the RWST can be unisolated from non-safety related piping. The RWST-associated piping may be unisolated for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to perform SR 3.5.4.3. In addition, in each fuel cycle the RWST-associated piping may be unisolated for up to 30 days to allow RWST water filtration or silica removal. These allowances are only applicable during the next two fuel cycles for each unit to allow physical modifications to be made to the subject systems eliminating the need for manual operator action. These notes cannot be used after Refueling Outages 1R26 (Spring 2015) and 2R24 (Spring 2016). The Notes in TS 3.5.4 will be annotated to reflect the limitations for usage.

Refueling Water Purification System The TS required RWST volume of water must be maintained to mitigate the consequences of a LOCA or MSLB event concurrent with a seismic event when the plant is in Modes 1 through 4. This requirement applies regardless of the RWST's possible alignment to the SFP Purification Loop.

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Enclosure 1 Description and Evaluation of the Proposed Change As part of the surveillance requirements to verify RWST operability, weekly boron samples are required to be taken and analyzed. In order to obtain representative samples, the tank contents must be sufficiently re-circulated to have thorough mixing . The SFP Purification Loop has been used in the past at FNP to perform this mixing. To allow this historic use of the SFP Purification Loop while the RWST was required to be operable; credit was taken for operator action to close the code boundary valve between the RWST and the SFP Purification Loop following a LOCA or MSLB coincident with a seismic event.

If the existing SFP Purification Loop is not used, then in order to take a sample representative of the tank, the Containment Spray (CS) or Residual Heat Removal (RHR) systems must be used. USing these systems for this purpose can result in alignment issues that make them inoperable while they re-circulate RWSTwater.

For future plant operations under the proposed revision to the TS, by similarly crediting this operator action, FNP may continue to use the SFP Purification Loop in plant Modes 1 through 4 up to four hours to facilitate the proper mixing necessary for accuracy in the required boron concentration surveillance. This determination of boron concentration is in turn necessary to provide the assurance that the RWST water is capable of fulfilling its function of accident mitigation.

Temporary Reverse Osmosis Skid Used To Support RWST Cleanup The RWST silica concentrations have been increasing due to silica migration from the spent fuel pool to the reactor cavity during refueling outage fuel transfer operations. Increasing silica levels in the RWST mix with reactor coolant each refueling outage in the reactor cavity, thus increasing silica concentrations in the reactor coolant system (RCS). The RCS silica concentration limit is less than or equal to 1 ppm based on current Westinghouse fuel warranty limits. Previously, FNP removed silica by use of the BARS system . Silica can also be reduced using dilution however this creates large quantities of liquid radioactive waste that must be processed. Also, the removal of silica from the RWST is preferred to removing silica from the spent fuel pool. Industry experience has shown that removal of silica from the spent fuel pool leads to further deterioration of the Boroflex material in the storage racks and possibly a return to even higher silica concentrations in the spent fuel pool.

Further, pre-refueling outage treatment of the RWST contents ensures that refueling water clarity requirements are maintained for fuel transfer and inspection purposes. The water clarity is both a personnel and equipment safety consideration.

For future plant operations under the proposed revision to the TS, by similarly crediting the operator action to close the manual code boundary valve should a Reactor Trip occur or the Shift Supervisor direct the closure, FNP may continue to use the SFP Purification Loop in plant Modes 1 through 4 for up to 30 days per Page 6 of 13

Enclosure 1 Description and Evaluation of the Proposed Change fuel cycle to filter the RWST contents through the in-series BARS system, spent fuel pool demineralizer, and SFP filter. This processing of the RWST contents through the SFP Purification Loop will continue to enhance water quality and enable the removal of radiological impurities to facilitate maintenance activities and promote radiation exposure rates which are within 10 CFR 20 limits and As Low As Reasonably Achievable (ALARA).

3.0 Technical Evaluation Extracted from Updated Final Safety Analysis Report (FSAR) 6.2.2.2.1 Containment Spray System Refueling Water Storage Tank The RWST serves as a source of emergency borated cooling water for injection. It is normally used to fill the refueling canal for refueling operations. However, during all other plant operating periods, it is aligned to the suction of the residual heat removal pumps and the containment spray pumps. The charging pumps are aligned to the suction of the RWST upon receipt of the Safety Injection Signal. The capacity of the tank is 66,850 ft3. The tank is fabricated from stainless steel and is designed and constructed in accordance with Code ASME III, Class 2. Water in the tank is borated to a concentration which assures reactor shutdown by at least 10% b.k/k, when all RCC assemblies are inserted and the core cooled down for refueling.

Spent Fuel Pool Cooling and Purification System The Spent Fuel Pool Cooling and Purification System (SFPCPS) is deSigned to remove the decay heat generated by stored fuel assemblies from the spent fuel pool water. This cooling is accomplished by taking high temperature water from the pool, pumping it through a heat exchanger, and returning cooled water to the pool. A secondary function of the SFPCPS is to clarify and purify the spent fuel pool, transfer canal, and refueling water. A portion of the hot water discharged by the pump can be diverted through a water cleanup system and returned to the pool.

The purification function of the SFPCPS does not meet Seismic Category 1 requirements.

This qualitative assessment addresses the proposed change to TS 3.5.4, "Refueling Water Storage Tank." Currently, under the interpretation of seismic qualification of systems provided by IN 2012-01, TS 3.5.4, "Refueling Water Storage Tank" has no allowance for re-circulating the contents of the RWST for the purposes of facilitating sampling or the removal of silica during Modes 1 through 4 when the RWST is required to be operable. The following justification is presented for the acceptability of the proposed change to the TS which provides for operator action to close the seismically qualified manual code boundary valve should a LOCA, MSLB, or seismic event occur to assure RWST operability when re-circulating the tank through non-safety related piping.

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Enclosure 1 Description and Evaluation of the Proposed Change Surveillance Requirement (SR) 3.5.4.2 requires sampling of the RWST water every seven days to verify boron concentrations . In order to receive an accurate sample, the tank contents must be re-circulated to ensure proper mixing of the tank contents. However, the RWST was not designed to be re-circulated through seismically qualified piping for this purpose of sampling.

The RWST can be aligned through the containment spray system to accomplish this re-circulation. However, this alignment renders the containment spray train inoperable, requiring voluntary entry into a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Required Action Statement.

Routinely aligning in this manner is non-conservative since it requires a train of ESF equipment be made inoperable for a period of approximately three hours and thereby unavailable to mitigate the consequences of an accident. Thus, this option for re-circulation presents an undesirable potential challenge to the design of the ESF as described in the UFSAR.

As an alternative to rendering an ESF train inoperable, the RWST can be re circulated by using the SFP Purification Loop. However, this system alignment circulates the RWST water through non-safety related piping. In order to maintain operability of the RWST, timely operator action would be utilized to close a single seismically qualified code manual boundary valve. SNC prefers this method due to the ability to maintain all ESF equipment operable and available during the alignment.

SNC has confidence in the successful cornpletion of manual actions due to the extensive training program completed for all system operators. Detailed procedures have been developed to further ensure successful performance of this task. The procedures require the individual designated to perform the manual action to be briefed. This brief covers the method of communication the operator will have with the control room, the limitations on movement of the assigned operator (remain within the Auxiliary Building), the location of the valve to be manipulated, ingress and egress path, and the initiating conditions which required securing the valve. In addition, the control room will monitor the RWST level during operation of the BARS system and during RWST re-circulation.

Refer to Enclosure 4 for further information on manual operator action.

A combination of design and administrative controls ensure that both the SFP Purification Loop and BARS systems maintain RWST boron concentration and water volume requirements whenever the contents of the RWST are processed through these systems. Prior to initiating BARS system operation, the RWST volume margin will be verified to be adequate to compensate for postulated BARS system line losses and process losses which may occur through the BARS system reject waste stream. Further, the waste stream losses will be monitored throughout BARS system operation. The BARS system is designed to maintain a high boron recovery rate. Potential boron dilution during use of the BARS system is prevented through verifying RWST boron margin prior to BARS system operation, calculating the estimated dilution, and monitoring the BARS system boron recovery rate by grab samples taken from the system inlet and outlet points approximately one hour after placing it in service and at least every 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Page 8 of 13

Enclosure 1 Description and Evaluation of the Proposed Change thereafter. Following each operation of the BARS system, RWST sampling will be performed to verify the RWST boron concentration, and boron additions will be made to the RWST, accordingly.

Documentation Of Engineering Judgment (DOEJ) DOEJ-FRC092028601-M001 ,

which was developed as part of the Request for Engineering Review (RER)

C092028601, "Refueling Water Purification Interface with RWST Review,"

determined that if the SFP Purification Loop line breaks during normal operations, the RWST volume will not drop below the TS minimum for approximately 35 minutes. However, the proposed manual operator action would have the operator stationed inside the seismically qualified Auxiliary Building and within ten minutes of the boundary valve allowing it to be isolated well within the 35 minutes, thus assuring the minimum RWST water inventory will be maintained. The DOEJ further evaluated the case of a puri"fication line break concurrent with a large break LOCA. In this case, the volume loss due to the SFP Purification Loop line break would not affect the ability of the RWST to perform its safety function since the bulk of its volume would reach the containment sump and be available for the low pressure recirculation mode of core cooling. Regardless of this acceptable conclusion, the proposed operator action would still be performed to maximize the available inventory to mitigate the accident. The final scenario evaluated by the DOEJ was a small break LOCA concurrent with a SFP Purification Loop line break. In this more slowly evolving scenario, if the manual operator action is performed as proposed the loss of RWST inventory due to the purification line break again would not affect the ability of the RWST to perform its safety function.

The failure of the boundary valve to close would be considered a credible single failure. Per 10CFR50 Appendix A, a single failure is defined as an occurrence which results in the loss of capability of a component to perform its intended safety function. Fluid and electric systems are considered to be designed against an assumed single failure if neither (1) a Single failure of any active component nor (2) a Single failure of a passive component results in a loss of capability of the system to perform its safety function. The active failure in a fluid system means (1) the failure of a component which relies on mechanical movement for its operation to complete its intended function on demands, or (2) an unintended movement of the component.

If the valve was first tested before placing in service by opening and then closing the valve and monitoring RWST level or other reliable indication, it could be determined that the common failure mechanisms are not present. Therefore, it would be highly unlikely that another unforeseen failure of the valve to close would occur. Consequently, the valve should be counted on to reliably perform its function when needed. Guidance to perform a pre-operational test would be included in the procedure to perform every time the RWST is unisolated from the SFP purification system. To address any unintended movement, plant procedures require the valve to be sealed closed when not in use.

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Enclosure 1 Description and Evaluation of the Proposed Change 4.0 Regulatory Evaluation 4.1 Significant Hazards Consideration The proposed change adds Notes to the FNP Unit 1 & 2 Technical Specifications 3.5.4, "Refueling Water Storage Tank," to allow administrative control of the seismic RWST/non-seismic SFP Purification Loop interface.

SNC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by evaluation of the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No. The use of the BARS system and the SFP Purification Loop to re-circulate the RWST does not involve any changes or create any new interfaces with the reactor coolant system or main steam system piping. Therefore, the connection of the SFP Purification Loop to the RWST and use of the BARS system would not affect the probability of these accidents occurring.

Neither the SFP Purification Loop nor the BARS system are credited for safe shutdown of the plant or accident mitigation. A combination of design and administrative controls ensure that both the SFP Purification Loop and BARS systems maintain RWST boron concentration and water volume requirements whenever the contents of the RWST are processed through these systems. RWST volume margin will be verified to be adequate to compensate for postulated BARS system line losses and process losses which may occur through the BARS system reject waste stream. The BARS system is designed to maintain a high boron recovery rate. Potential boron dilution during use of the BARS system is prevented through verifying RWST boron margin prior to BARS system operation and monitoring the BARS system boron recovery rate by grab samples taken from the system inlet and outlet pOints approximately one hour after placing it in service and at least every 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months thereafter. Following each operation of the BARS system, RWST sampling will be performed to verify the RWST boron concentration, and boron additions will be made to the RWST, accordingly.

Since the RWST will continue to perform its safety function and meet all surveillance requirements, overall system performance is not affected, assumptions previously made in evaluating the consequences of the accident are not altered, and the consequences of the accident are not increased.

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Enclosure 1 Description and Evaluation of the Proposed Change Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No. Contingent upon manual operator action as described above, a SFP Purification Loop line break will not result in a loss of the RWST safety function. Similarly, an active or passive failure in the BARS system will not result in loss of the RWST safety function.

Adequate RWST volume and boron margin will be verified prior to BARS system operation. The BARS system boron recovery rate will be monitored by grab samples taken of the system inlet and outlet one hour after placing the system in service and at least every 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months thereafter. In addition, the DOEJ evaluation supports that the operator action can be taken within sufficient time to isolate the BARS system from the RWST during postulated accidents.

Calculations were reviewed for potential internal flooding from this non seismic pipe break, and it was concluded that the break would have no affect on safe shutdown equipment in the affected areas.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No. Neither the SFP Purification Loop nor the BARS systems are credited for safe shutdown of the plant or accident mitigation. Adequate RWST volume and boron margin will be verified prior to BARS system operation and timely operator action can be taken to isolate the BARS system from the RWST. The BARS system waste stream losses will also be monitored throughout BARS system operation.

The potential boron dilution of the RWST inventory during tank processing through the SFP Purification Loop is minimized by administratively maintaining closed all manual boundary valves within the SFP Purification Loop while the SFP Purification Loop is connected to the RWST. The BARS system is designed to maintain a high boron recovery rate, which will be verified through testing prior to initial start up of the system. Potential boron dilution during every operation of the BARS system is prevented through verification of the RWST boron margin prior to BARS system operation, calculating the expected rate of dilution, and monitoring the BARS system boron recovery rate by grab Page 11 of 13

Enclosure 1 Description and Evaluation of the Proposed Change samples taken from the system inlet and outlet at least every 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

Following operation of the BARS system, RWST sampling will be performed to verify the RWST boron concentration, and boron additions to the RWST will be made accordingly. These measures will ensure the TS minimum RWST boron concentration is available to mitigate the short term consequences of a small break LOCA, large break LOCA, or MSLB accident.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, SNC concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.2 Applicable Regulatory Requirements/Criteria The changes proposed by this license amendment request have been evaluated based on the following criteria:

Information Notice (IN) 2012-01, "Seismic Considerations - Principally Issues Involving Tanks."

Generic Design Criterion 2 requires that structures, systems, and components important to safety be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without the loss of the capability to perform their safety functions.

Generic Design Criterion 35-Emergency core cooling . A system to provide abundant emergency core cooling shall be provided. The system safety function shall be to transfer heat from the reactor core following any loss of reactor coolant at a rate such that (1) fuel and clad damage that could interfere with continued effective core cooling is prevented and (2) clad metal-water reaction is limited to negligible amounts.

Suitable redundancy in components and features, and suitable interconnections, leak detection, isolation, and containment capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure.

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Enclosure 1 Description and Evaluation of the Proposed Change 4.3 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 Environmental Consideration SNC has evaluated the proposed amendment change and determined the changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51 .22(c)(9). Therefore, pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 References

1. Farley FSAR, Rev. 24, January 2012, Sections: 3.1, 6.3.2.17, 6.3.3.12, 9.1.3

2. Farley Unit 1 & 2 Technical Specifications, Rev. 186/181, Section 3.5.4, "Refueling Water Storage Tank"

3. Farley Unit 1 and 2 Environmental Protection Plans, Rev. 90/83, Including Appendix "B".

4. DOEJ-FRC0902028601-M001, Version 2.0, "Effect of a Refueling Water Purification line Break on RWST Level, ECCS Pumps NPSH and ECCS Screen Vortexing"

5. RER C092028601 , Sequence 2.0, "Refueling Water Purification Interface with RWST Review"

6. BM-99-1932-001, "Internal Flooding Assessment."

Page 13 of 13

Joseph M. Farley Nuclear Plant Unit 1 & 2 Exigent Technical Specification Revision Request for TS 3.5.4 Refueling Water Storage Tank (RWST)

Enclosure 2 Marked-Up Technical Specifications and Bases Pages

RWST 3.5.4 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.4 Refueling Water Storage Tank (RWST)

NOT ES ------------

LCO 3.5.4 The RWST shall be OPERABLE.

Insert 1 APPLICABILITY: MODES 1,2, ,and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. RWST boron A.1 Restore RWST to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months concentration not within OPERABLE status.

limits.

OR RWST borated water temperature not within limits.

B. RWST inoperable for B.1 Restore RWST to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months reasons other than OPERABLE status.

Condition A.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND C.2 Be in MODE5 . 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

These Notes can only be applied during the next two fuel Cycles for each Unit. These Notes cannot be used after Refueling Outages 1 R26 (Spring 2015) and 2R24 (Spring 2016).

Farley Units 1 and 2 3.5.4-1 Amendment No. -+4e (Unit 1)

Amendment No. -+37- (Unit 2)

BASES APPLICABLE injected water for the small break LOCA and higher containment SAFETY ANALYSES pressures due to reduced containment spray cooling capacity. For (continued) the containment response following an MSLB, the lower limit on boron concentration and the upper assumption on RWST water temperature are used to maximize the total energy release to containment.

The RWST satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The RWST ensures that an adequate supply of borated water is available to cool and depressurize the containment in the event of a Design Basis Accident (DBA), to cool and cover the core in the event of a LOCA, to maintain the reactor subcritical following a DBA, and to ensure adequate level in the containment sump to support ECCS and Containment Spray System pump operation in the recirculation mode.

To be considered OPERABLE, the RWST must meet the water volume, boron concentration, and temperature limits established in the SRs.

APPLICABILITY In MODES 1, 2, 3, and 4, RWST OPERABILITY requirements are dictated by ECCS and Containment Spray System OPERABILITY requirements. Since both the ECCS and the Containment Spray System must be OPERABLE in MODES 1,2,3, and 4, the RWST must also be OPERABLE to support their operation. Core cooling requirements in MODE 5 are addressed by LCO 3.4.7, "RCS Loops

-MODE 5, Loops Filled," and LCO 3.4.8, "RCS Loops-MODE 5, Loops Not Filled." MODE 6 core cooling requirements are addressed by LCO 3.9.4, "Residual Heat Removal (RHR) and Coolant Circulation - High Water Level," and LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level.

ACTIONS With RWST boron concentration or borated water temperature not within limits, they must be returned to within limits within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

Insert 2 Under these conditions neither the ECCS nor the Containment Spray (continued)

Farley Units 1 and 2 B 3.5.4-4 Revision sa

Insert 1:

AWST piping may be unisolated from non-safety related piping for::; 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months under administrative controls to perform SA 3.5.4.3.*

AWST piping may be unisolated from non-safety related piping for::; 30 days per fuel cycle under administrative controls for filtration or silica removal.

Insert 2:

The ACTIONS are modified by Notes that allow RWST piping flow paths to be unisolated from non-safety related piping under administrative controls for limited periods of time. The piping may be unisolated from non-safety related piping for::; 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months under administrative controls to perform SR 3.5.4.3 and for::; 30 days per fuel cycle under administrative controls for filtration or silica removal. These administrative controls consist of (1) Stroking valve Q1 (2)G31 V01 0 open and then closed prior to circulating the RWST water through the Spent Fuel Pool Purification System (2) establishing a designated operator to control the valve and (3) establishing a preplanned communication method between the operator and Shift Supervisor. In this way, the flow path can be rapidly isolated in the event of a Reactor Trip or at the direction of the Shift Supervisor. These Notes are to allow recirculation and sampling of the RWST through the Spent Fuel Pool Purification System for filtering as well as operation of the reverse osmosis system to remove silica. These Notes can only be applied during the next two fuel Cycles for each Unit. These Notes cannot be used after Refueling Outages 1R26 (Spring 2015) and 2A24 (Spring 2016).

Joseph M. Farley Nuclear Plant Unit 1 & 2 Exigent Technical Specification Revision Request for TS 3.5.4 Refueling Water Storage Tank (RWST)

Enclosure 3 Clean Technical Specifications and Bases Pages

RWST 3.5.4 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.4 Refueling Water Storage Tank (RWST)

LCO 3.5.4 The RWST shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS

NO-rES---------------------------------------------------------------

1. RWST piping may be unisolated from non-safety related piping for ~ 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months under administrative controls to perform SR 3.5.4.3. *

2. RWST piping may be unisolated from non-safety related piping for ~ 30 days per fuel cycle under administrative controls for filtration or silica removal.

CONDITION REQUIRED ACTION COMPLETION TIME A RWST boron Ai Restore RWST to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months concentration not within OPERABLE status.

limits.

OR RWST borated water temperature not within limits.

B. RWST inoperable for 8.1 Restore RWST to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months reasons other than OPERABLE status.

Condition A.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months "These Notes can only be applied during the next two fuel Cycles for each Unit.

These Notes cannot be used after Refueling Outages 1R26 (Spring 2015) and 2R24 (Spring 2016).

Farley Units 1 and 2 3.5.4-1 Amendment No. (Unit 1)

Amendment No. (Unit 2)

BASES APPLICABLE injected water for the small break LOCA and higher containment SAFETY ANALYSES pressures due to reduced containment spray cooling capacity. For (continued) the containment response following an MSLB, the lower limit on boron concentration and the upper assumption on RWST water temperature are used to maximize the total energy release to containment.

The RWST satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The RWST ensures that an adequate supply of borated water is available to cool and depressurize the containment in the event of a Design Basis Accident (DBA), to cool and cover the core in the event of a LOCA, to maintain the reactor subcritical following a DBA, and to ensure adequate level in the containment sump to support ECCS and Containment Spray System pump operation in the recirculation mode.

To be considered OPERABLE, the RWST must meet the water volume, boron concentration, and temperature limits established in the SRs.

APPLICABILITY In MODES 1,2, 3, and 4, RWST OPERABILITY requirements are dictated by ECCS and Containment Spray System OPERABILITY requirements. Since both the ECCS and the Containment Spray System must be OPERABLE in MODES 1,2,3, and 4, the RWST must also be OPERABLE to support their operation. Core cooling requirements in MODE 5 are addressed by LCO 3.4.7, "RCS Loops

-MODE 5, Loops Filled," and LCO 3.4.8, "RCS Loops-MODE 5, Loops Not Filled." MODE 6 core cooling requirements are addressed by LCO 3.9.4, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level," and LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level.

ACTIONS The ACTIONS are modified by i'Jotes that allow RWST piping flow paths to be unisolated from non-safety related piping under administrative controls for limited periods of time. The piping may be unisolated from non-safety related piping for ~ 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months under administrative controls to perform SR 3.5.4.3 and for ~ 30 days per fuel cycle under administrative controls for filtration or silica removal.

These administrative controls consist of (1) Stroking valve Q1 (2)G31 V01 0 open and then closed prior to circulating the RWST water through the Spent Fuel Pool Purification System (2) establishing a designated operator to control the valve and (3) establishing a preplanned communication method between the operator and Shift Supervisor. In this way, the flow path can be rapidly isolated in the event of a Reactor Trip or at the direction of the Shift Supervisor. These Notes are to allow recirculation and sampling of the RWST through the Spent Fuel Pool Purification System for filtering as well as operation of the reverse osmosis system to remove silica. These Notes can only be applied during the next two fuel Cycles for each Unit. These Notes cannot be used after Refueling Outages 1R26 (Spring 2015) and 2R24 (Spring 2016).

(continued)

Farley Units 1 and 2 B 3.5.4-4 Revision

Joseph M. Farley Nuclear Plant Unit 1 & 2 Exigent Technical Specification Revision Request for TS 3.5.4 Refueling Water Storage Tank (RWSTl Enclosure 4 Responses to Requests of Additional Information

Enclosure 4 Responses to Requests for Additional information The following questions were provided to Southern Nuclear Operating Company by the NRC requesting further information for the License Amendment Request submittal for TS 3.5.4, "Refueling Water Storage Tank."

(1) the specific operator actions required, both in the Control Room and the Auxiliary Building; The operator designated to perform the manual action will be part of the normal shift complement. However, per procedure, the operator will not be allowed to be a member of the fire brigade and will be required to stay within the seismically qualified Auxiliary Building. The designated operator can be a licensed operator or a fully qualified system operator.

The control room operator is required to participate in a brief with the designated operator. The control room operator will be responsible for contacting the designated operator and direct performance of the action. The method of communication will be discussed in the required brief.

The specific operator actions required in the Auxiliary Building by the designated operator are to secure the Refueling Water Purification (RWP) pump by a handswitch, and manually close the Refueling Water Purification pump suction from the RWST Isolation valve Q1 /2G31 V01 O. Both the handswitch and the valve are located in the same room .

(2) any potentially harsh or inhospitable environmental conditions expected in the Auxiliary Building or the ingress/egress paths; In referencing the radiation zone drawings to assess post-accident accessibility, the designated operator will need to pass through a room that is expected to have elevated dose (::; 100 millirem). The room is only required to be walked through to access the valves and therefore the time spent in the room will be minimized. The dose expected will be within acceptable limits.

For pressure and temperature conditions, the ingress and egress paths will be accessible when manual action is required.

The most limiting environmental conditions in the ingress/egress path would be a result of a Steam Generator Blowdown line break. However, the operator action is not required to be performed in the case of a SGBD line break. The impact to the RCS volume from a SGBD is not Significant and the RWST volume would not be challenged.

The designated operator will not come into contact with potentially hazardous chemicals on the route used to perform the manual action. Potentially hazardous chemicals are controlled per Chemistry procedures and Material Safety Data Sheets.

Further, these chemicals are maintained in the chemistry labs on the 139' elevation.

The designated operator will not ingress or egress on this elevation to access the valve to be manipulated. Periodically gas cylinders are transported throughout the Auxiliary Building, but detailed guidance for safe handling of gas cylinders is provided in the Safety and Health Manual.

1

Enclosure 4 (3) a general discussion of the ingress/egress paths taken by the operator(s) to accomplish functions, including timing; The designated operator is briefed to be readily available and able to secure the RWP pump and close Q1/2G31 V01 0 within 10 minutes. Per procedure, the designated operator is required to stay within the seismically qualified Auxiliary Building. Typically the operators are located in their assigned work stations located on the 100' or 121' elevation. These work stations are located in close proximity to the stairwell leading to the 130' elevation. The pump and valve are located on the 130' elevation of each unit and require no additional support equipment such as ladders or scaffolding to operate.

Per procedure, system operators are required to carry flashlights at all times in case of lighting problems.

(4) the procedural guidance for required actions; FNP-1-S0P-54.0 Appendix 8, FNP-2-S0P-54.0 Appendix 7, FNP-1-S0P-54.4 Appendix 5, and FNP-2-S0P-54.4 Appendix 4 are included in Enclosure 5.

Ff\lP-1-S0P-54.0 Appendix 8 and FNP-2-S0P-54.0 Appendix 7 apply when the RWST is being re-circulated through the SFP Purification Loop.

FNP-1-S0P-54.4 Appendix 5 and FNP-2-S0P-54.4 Appendix 4 apply when the BARS system is in service.

(5) the specific operator training necessary to carry out actions, including any operator qualifications required to carry out actions; The operator must be a fully qualified system operator and be briefed on performing the required task. The operator is not required to be a licensed operator. The system operators are trained on the systems in the classroom during their initial qualification training. In addition, prior to becoming fully qualified operators, they are required to successfully perform on the job training tasks called Task Performance Evaluations (TPE). These TPE's are developed and evaluated based on the Systematic Approach to Training. Although there is not a specific task for isolating the RWST from the SFP Purification Loop, the operators perform two related TPE's for the SFP Purification Loop and BARS which require them to have system familiarity. The first is to place the RWST Purification (Recirculation) in Operation and the other is to place BARS in service. The valve to be manipulated is identified in the field with labels for the deSignated operator to correctly identify the valve. There are no unique requirements to operate the valve.

(6) any additional support personnel and/or equipment required by the operator(s) to carry out the required actions; none 2

Enclosure 4 (7) a description of the information required by the control room staff to determine whether the proposed action is required, including qualified instrumentation used to diagnose the situation, and, later, to verify that the required action has successfully been taken; The initiating events requiring closure of 01/2G31 V01 0 are the following:

1. a Reactor Trip,

2. any unexplained Auxiliary Building sump or tank level increase,

3. any unexplained RWST level decrease, or

4. direction of the SS.

The instrumentation and alarms used to diagnose the initiating events include:

Multiple Main Control Board Annunciators on Panel G alert the operator of a Reactor Trip

Main Control Board Annunciator, BE5, BOP PANELS ALARM will alert the control room of an unexplained Auxiliary Building sump or tank level increase

Main Control Board Annunciator, MK4, UO OR GAS PROC PNL ALARM, will alert the operator in the main control room of an alarm on the local Liquid Waste Processing Panel. The Liquid Waste Process Panel has alarms for High level in the Waste Holdup Tank and Floor Drain Tank.

Main Control Board Annunciators: EG4 RWST MIN TECH SPEC LVL A TRN will alert the control room of any Unexplained RWST level decrease o MCB Alarm is fed from safety related level transmitters 01 F16LT501

Main Control Board Annunciator, MK5, SEISMIC PANEL ALARM

Alarm comes from Solid State Accelograph

The Seismic Instrumentation is described in the UFSAR section 16.1.1 After one of the above initiating conditions is met, the control room would communicate to the designated operator in the method determined by the brief. After the action is completed successfully, the designated operator would contact the control room to report the required action is complete.

(8) the ability to recover from credible errors in performance of proposed manual actions, and the expected time required to make such a recovery; Procedure FNP-1/ 2-S0P-54.0 Appendix 8/7 or FNP-1/2-S0P-54.4 Appendix 5/4 is the applicable procedure when the RWST piping is unisolated from non-safety related piping. These procedures have guidance for manipulating 01 /2G31 V01 O.

Several items are provided in the Appendices. The most significant required action is the pre-job brief which will cover the method of communication between the control room and the designated operator, the limitations on movement of the designated operator, the location of the RWP and the valve to be operated, the ingress/egress path and the initiating conditions which require action to be taken. This brief is an effective method to verify understanding of the task and the set of pre-event conditions which will initiate the manual operator action.

3

Enclosure 4 It is to be noted that communication is specifically addressed in the brief, and it is this function between the control room and the valve operator that will direct the valve closure based on the following initiating events.

1. a Reactor Trip,

2. any unexplained Aux Bldg sump or tank level increase,

3. any unexplained RWST level decrease, or

4. direction of the Shift Supervisor The control room operators have various alarms as stated in the response to Question 7 to diagnose the previously mentioned four events.

In addition, the control room operators are required per the Appendices of FI\IP-11 2 SOP-54.0 and FNP-1/2-S0P-54.4 to monitor RWST level while unisolated from non safety related piping.

If the designated operator had physical problems, the remaining operating crew compliment would be available to respond. The Shift Supervisor directive enhances the chance of recovery because of his overall plant outlook. If the operator assigned in the control room to work with the Q1/2G31V010 designated operator did not communicate in a timely fashion, the Shift Supervisor will have the oversight to acknowledge this and direct such communication.

(9) consideration of the risk significance of the proposed operator actions, and A quantitative risk assessment was not prepared for this manual action.

(10) the method(s) used to validate the feasibility of completing required actions within the time available.

The feasibility of completing the action of manually closing Q1/2G31 V010 was not specifically validated by walkdown. The required operator actions were viewed to be simple actions that would not challenge a qualified system operator. Given the pre-job briefing and operator familiarity with the task, 10 minutes to complete the required valve manipulation is considered a conservative time. Therefore, completion of the required action is feasible based on operator experience and engineering judgment.

A walk down was performed by a design engineering group which included a civil engineer. The purpose of the walk down was to identify items which could potentially fall in a seismic event such that they could impede operator actions to close valves Q1/2G31V010.

Per procedure, the deSignated operator is required to stay within the seismically qualified Auxiliary Building. The deSignated operator is typically positioned in three areas of the Auxiliary Building: 1) the Control Room, 2) Operations work station on the 100' elevation, 3) Operations work station on the 121' elevation. Also from these recommendations, numerous rooms were walked down to evaluate possible impediments to operator ingress path caused by a seismic event.

The walk down consisted of visual inspection of permanent plant structures, systems and components (SSCs), stored materials (Le. scaffolding, boxes, skid pans, tool 4

Enclosure 4 boxes, etc.} and unanchored objects. SSCs were also visually inspected for any type of degradation. Also, this inspection included the doors accessing the valve to see if any objects could block the door and prevent it from being opened by the operator. All safety-related SSCs in the auxiliary building are mounted/anchored in accordance with Seismic Category I criteria. Typically, non safety-related SSCs are mounted to Seismic Category 11/1 requirements.

Unit 1 Walk Down Results:

There were no conditions found to be a potential threat to preventing the operator from accessing and operating valve 01 G31 V01 O. There are no recommendations from engineering regarding further evaluation for Unit 1.

Unit 2 Walk Down Results:

The Unit 2 walk down revealed a small freestanding liquid rad waste enclosure on the 100' elevation which was not installed to SeismiC Category I requirements. There is a potential that this enclosure could collapse during a seismic event and prevent the operator from gaining access to 02G31 V01 O. However, an alternate walk path is available. This alternate walk path, avoiding the small enclosure, contained no potential obstructions to the operator's walk path. In addition, the alternate path does not require the operator to pass through areas of high radiation. All areas will be :s 15 millirem.

(11) In addition, discuss whether the NSR piping could fail in such a way as to prevent the operator from completing the isolation task, e.g. bending or fragmenting within the valve body in such a way as to prevent full closure. If the NSR piping should fail in this way, does the operator have another feasible success path?

01 G31 V01 0 and 02G31 V01 0 provide the boundary between the seismic category I piping to the RWST and the downstream attached non safety-related piping. These valves are N-Stamped for class 2 piping and are seismically qualified.

For Unit 1, 01 G31 V01 0 is located in the vertical piping run . Two seismic supports are provided for since there is tee 1'0" downstream of the valve. There is one support on each leg of the tee. Anchor SS-3640 on the vertical run is 18 inches from the end of the valve. Seismic Support SS-3641 is located 25 inches from the tee connection to provide anchorage support on this leg of pipe. By review of the piping configuration, a failure of the seismic category 2 portion of this 2" piping cannot prevent adequate performance of the valve's safety function. The valve will remain intact and meet all ASME code requirements for the required loading conditions.

For Unit 2, 02G31V010 has Seismic Support SS-14989 located three inches downstream of the seismic valve. By review of the piping configuration, a failure of the seismic category 2 portion of this piping cannot prevent adequate performance of the valves safety function. The valve will remain intact and meet all ASME code requirements for the required loading conditions. Furthermore, the small 2" subject piping cannot fail in a manner that could impede the operator's access to the valve.

5

Joseph M. Farley Nuclear Plant Unit 1 & 2 Exigent Technical Specification Revision Request for TS 3.5.4 Refueling Water Storage Tank (RWST)

Enclosure 5 Requested Procedures

02/23/12 11:40:10 FNP-1-S0P-S4.0 APPENDIX 8 APPENDIX 8 ESTABLISHING ADMINISTRATIVE CONTROLS FOR OPENING THE RWP PUMP SUCTION FROM THE RWST ISO QIG31VOlO IN MODES 1-4 This appendix consists of 2 pages Version 64.0 E5-1

02123112 11:40:18 FNP-I-S0P-54.0 APPENDIX 8 PENDIX 8 ESTABLISHING ADMINISTRATIVE CONTROLS FOR OPENING THE RWP PUMP SUCTION FROM THE RWST ISO QIG31 VOlO IN MODES 1-4 1.0 Initial Conditions 1.1 Verify the version of this procedure is the current version. (OR 1-98-498) l.2 Verify this procedure is the correct unit for the task. (OR 1-98-498) cAtinON: .

. ~.

The RWST and piping upstream of QIG31VOIO is safetY:-related' ..

and seismic category,:I.; theSFP purification loop downstream of QIG31VOI0'is non~seismicand noit-safetYrelated.- Failure toclose this v~lve ,when' requiredcouldresultiil the RWST being unable to

,'. .' . fulfill its SR,function.: .

NOTE: When RWP Pump Suction from RWST Iso QIG31VOI0 is open, the following compensatory actions must be taken to maintain the operability of the RWST.

2.0 Administrative Controls and Compensatory Measures 2.1 Check RWST level greater than 39.1' .

2.2 Establish a trend of RWST level in the Control Room.

2.3 Establish an IPC temporary alarm for decreasing RWST level at 39.1'.

,CAUTION: ' ' Operatof'assigned. to c1ose ,QIG3i.VOlO n,us.t remain within"the seismiCally open. .

qualified "Aux Building at

,all times ~hile QIG31VOIO is .

The assigned operator cannot be a membe~ of the Fire Brig~de. ,

(CR 2010101919) ' " , ' , " ,: . . . . . ,- .. '; ;

2.4 Assign an operator to be readily available and able to secure the RWP pump and close QIG31VOlO within 10 minutes.

2.4.1 Make AUTO-LOG entry to record name of assigned operator.

2.5 Establish a method of commWlication between the assigned operator and the Control Room.

2.5.1 Make AUTO-LOG entry to record method of communication.

2.6 Conduct a pre-job brief with the assigned operator and operating crew. The prejob brief must cover, at a minimum:

Page 1 of2 Version 64.0 ES-2

02123/12 11:40:26 1. FNP-l-S0P-54.0 APPENDIX 8

Identity of operator assigned to secure the RWP pump and close QIG31 VOlO,

Method of communication between the assigned operator and Control Room,

Limitations on movement of assigned operator between locations (ability to respond within 10 minutes and requirement to remain within the Aux. Bldg.),

Location of RWP pump and valve QIG31 VOlO and ingress 1 egress path,

Actions to take upon receipt of seismic alarm,

Initiating conditions which require securing the RWP pump and closing QIG31VOlO:

o a RX trip o any unexplained Aux. Bldg. sump or tank level increase o unexplained RWST level decrease o direction of the SS.

2.7 IF required to relieve the assigned operator with a different assigned operator, THEN perform step 2.7.1 and 2.7.2.

2.7.1 Make Control Room Log entry to record transfer of responsibilities and the name of the newly assigned operator 2.7.2 Perform a prejob brief in accordance with step 2.6 with the newly assigned operator and operating crew.

2.8 IF any of the initiating conditions identified in step 2.6 occur, THEN perform steps 2.8.1 and 2.8.2 within 10 minutes.

2.8.1 Secure the RWP pump (130' Room 609).

2.8.2 Close RWP Pump Suction from RWST Iso QIG31VOlO (130' room 609).

2.9 IF a seismic alarm is received, THEN perform step 2.9.1 OR step 2.9.2 within 10 minutes.

2.9.1 Station an operator at the valve until the alarm is reset.

2.9.2 Perform step 2.9.2.1 and 2.9.2.2.

2.9.2.1 Secure the RWP pump (130' Room 609).

2.9.2.2 Close RWP Pump Suction from RWST Iso QIG31VOlO (130' room 609).

2.10 IF RWST Iso QIG31 VOlO is closed, THEN perform BARS Emergency Shutdown as time and plant priorities permit.

Page 2 of2 Version 64.0 ES-3

Enclsoure S 02123/12 11:40:58 T-~ v J FNP-1-S0P-54.4 I \ j ~~ _~

1"

APPENDIX 5 APPENDIX 5 ESTABLISHING ADMINISTRATIVE CONTROLS FOR OPENING THE RWP PUMP SUCTION FROM THE RWST ISO Q1G31VOlO IN MODES 1-4 This appendix consists of 2 pages Page 1 of 1 Version 17.0 ES-4

02/23/1211:41:0S FNP-1-S0P-S4.4 APPENDIXS APPENDIXS ESTABLISHING ADMINISTRATIVE CONTROLS FOR OPENING THE R WP PUMP SUCTION FROM THE RWST ISO Q1G31 VOlO IN MODES 1-4 1.0 Initial Conditions 1.1 Verify the version of this procedure is the current version. (OR 1-98-498) 1.2 Verify this procedure is the correct unit for the task. (OR 1-98-498)

CAUTION: . Th~RWST and'piping upstrea~ of QIG3lYOlO is safety-related and s~ismic category' l;tlie ' SFP'purificationloopdow~stre~m of .

Qi(;3lYOlO is non-seismiC and non;.safetf related. Failtiretoclose,'

this valve when required could result iii theR\ySTbeing unable to '

fulfill its SR function: ',' .

NOTE: When RWP Pump Suction from RWST Iso Q1G3l YOlO is open, the following compensatory actions must be taken to maintain the operability of the RWST.

2.0 Administrative Controls and Compensatory Measures 2.1 Check R WST level greater than 39.1' .

2.2 Establish a trend of RWST level in the Control Room.

2.3 Establish an IPC temporary alarm for decreasing RWST level at 39.1'.

CAUTION:

Operato~ assigned to close Ql~3l VQ1() must remain within the

" seism~callyqualit:ioo Aux Building at alltimeswhile,Q1G31VOlO is open. .

. . Th,e aSsignec:l ope~tor 'cannot be a'member of tlle,Fir,e Brigade* .

(CR 201010101.9)" ~,," -s 2.4 Assign an operator to be readily available and able to secure the RWP pump and close Q1G31 VOlO within 10 minutes.

2.4.1 Make AUTO-LOG entry to record name of assigned operator.

2.S Establish a method of communication between the assigned operator and the Control Room.

2.S.1 Make AUTO-LOG entry to record method of communication.

ES-S Page 1 of2 Version 17.0

02123/12 11:41:12 FNP-I-S0P-54.4 APPENDIX 5 2.6 Conduct a pre-job brief with the assigned operator and operating crew. The prejob brief must cover, at a minimum:

Identity of operator assigned to secure the RWP pump and close Q IG31 VOlO,

Method of communication between the assigned operator and Control Room,

Limitations on movement of assigned operator between locations (ability to respond within 10 minutes and requirement to remain within the Aux. Bldg.),

Location ofRWP pump and valve QIG31VOlO and ingress 1 egress path,

Actions to take upon receipt of seismic alarm,

Initiating conditions which require securing the RWP pump and closing QIG31VOlO:

o a RX trip o any unexplained Aux. Bldg. sump or tank level increase o unexplained R WST level decrease o direction of the SS.

2.7 IF required to relieve the assigned operator with a different assigned operator, THEN perform step 2.7.1 and 2.7.2.

2.7.1 Make AUTO-LOG entry to record transfer of responsibilities and the name of the newly assigned operator 2.7.2 Perform a prejob brief in accordance with step 2.6 with the newly assigned operator and operating crew.

2.8 IF any of the initiating conditions identified in step 2.6 occur, THEN perform steps 2.8.1 and 2.8.2 within 10 minutes.

2.8.1 Secure the RWP pump (130' Room 609).

2.8.2 Close RWP Pump Suction from RWST Iso QIG31VOlO (130' room 609).

2.9 IF a seismic alarm is received, THEN perform step 2.9.1 OR step 2.9.2 within 10 minutes.

2.9.1 Station an operator at the valve until the alarm is reset.

2.9.2 Perform step 2.9.2.1 and 2.9.2.2.

2.9.2.1 Secure the RWP pump (130' Room 609).

2.9.2.2 Close RWP Pump Suction from RWST Iso Q1G31VOlO (130' room 609).

2.10 IF RWST Iso Q1G31 VOlO is closed, THEN perform BARS Emergency Shutdown as time and plant priorities permit.

E5-6 Page 2 of2 Version 17.0

02/23/12 11:41:43 FNP-2-S0P-54.0 APPENDIX 7 APPENDIX 7 ESTABLISHING ADMINISTRATIVE CONTROLS FOR OPENING THE RWP PUMP SUCTION FROM THE RWST ISO Q2G31VOlO IN MODES 1-4 This appendix consists of 2 pages Version 63.1 E5-7

02123/12 11:41:50 FNP-2-S0P-54.0 APPENDIX 7 APPENDIX 7 ESTABLISHING ADMINISTRATIVE CONTROLS FOR OPENING THE RWP PUMP SUCTION FROM THE RWST ISO Q2G31VOlO IN MODES 1-4 1.0 Initial Conditions 1.1 Verify the version of this procedure is the current version. (OR 1-98-498) 1.2 Verify this procedure is the correct unit for the task. (OR 1-98-498)

CAUTION:- The RWST and piping upstreaDtof Q2G31V()10 is safety-related ,

and seismic 'category l;the SFPpurification loop'downstream of:

Q2G31VOIO is non*~seismic andnon-safetyreJated. Failure to close _

this valve -when- required could, result in- the RWST beingunabltdi>

I fulfill its SR function.- ,- ,- - _

NOTE: When RWP Pump Suction from RWST Iso Q2G31VOIO is open, the following compensatory actions must be taken to maintain the operability of the RWST.

2.0 Administrative Controls and Compensatory Measures 2.1 Check RWST level greater than 39.1' .

2.2 Establish a trend of RWST level in the Control Room.

2.3 Establish an IPC temporary alarm for decreasing RWST level at 39.1'.

CAUTION; Operator assigned to close Q2G31VOIO Ihust r~niain _ withiil the .

'seismically quafifi~d AuK Bld;,plt ~Il tim~swhile_ Q2G31yOlO is '"

~pen. ,

The~igned- operator:cannot be a membero{ the Fire Brigade. .'

_-(CR 20,lOlO!'O l?t ~:,' .-~ , .- . . , ,: .'.

2.4 Assign an operator to be readily available and able to secure the RWP pump and close Q2G31 VOlO within 10 minutes.

2.4.1 Make AUTO-LOG entry to record name of assigned operator.

2.5 Establish a method of communication between the assigned operator and the Control Room.

2.5.1 Make AUTO-LOG entry to record method of communication.

Page 1 of2 Version 63.1 E5-8

02123/12 11:41:57 FNP-2-S0P-54.0 APPENDIX 7 2.6 Conduct a pre-job brief with the assigned operator and operating crew. The prejob brief must cover, at a minimum:

Identity of operator assigned to secure the RWP pump and close Q2G31 VO 10,

Method of communication between the assigned operator and Control Room,

Limitations on movement of assigned operator between locations (ability to respond within 10 minutes and requirement to remain within the Aux. Bldg.),

Location of RWP pump and valve Q2G31 VO 10 and ingress / egress path,

Actions to take upon receipt of seismic alarm,

Initiating conditions which require securing the RWP pump and closing Q2G31VOlO:

o a RX trip o any unexplained Aux. Bldg. sump or tank level increase o unexplained R WST level decrease o direction of the SS.

2.7 IF required to relieve the assigned operator with a different assigned operator, THEN perform step 2.7.1 and 2.7.2.

2.7.1 Make AUTO-LOG entry to record transfer of responsibilities and the name of the newly assigned operator 2.7.2 Perform a prejob brief in accordance with step 2.6 with the newly assigned operator and operating crew.

2.8 IF any of the initiating conditions identified in step 2.6 occur, THEN perform steps 2.8.1 and 2.8.2 within 10 minutes.

2.8.1 Secure the RWP pump (130' Room 609).

2.8.2 Close RWP Pump Suction from RWST Iso Q2G31VOlO (DO' room 609).

2.9 IF a seismic alarm is received, THEN perform step 2.9.1 OR step 2.9.2 within 10 minutes.

2.9.1 Station an operator at the valve until the alarm is reset.

2.9.2 Perform step 2.9.2.1 and 2.9.2.2.

2.9.2.1 Secure the RWP pump (130' Room 609).

2.9.2.2 Close RWP Pump Suction from RWST Iso Q2G31 VOlO (130' room 609).

2.10 IF RWST Iso Q2G31 VOlO is closed, THEN perform BARS Emergency Shutdown as time and plant priorities permit.

Page 2 of2 Version 63.1 E5-9

UNIT 2 Enclsoure 5 Farley Nuclear Plant A Procedure Number FNP-2-S0P-S4.4 Ver 21.1 RWST SILICA REMOVAL BY THE BORIC ACID RECOVERY Page Number 2/23/2012 11:42:24 SYSTEM (BARS) 74 of 84 APPENDIX 4 ADMINISTRATIVE CONTROLS FOR RWST ISO Q2G31V010 IN MODES 1-4 This appendix consists of 3 pages ES-10

UNIT 2 Farley Nuclear Encl~~ure 5 ant A Procedure Number FNP-2-S0P-54.4 Ver 21.1 RWST SILICA REMOVAL BYTHE BORIC ACID RECOVERY Page Number 2/23/2012 11:42:31 SYSTEM (BARS) 75 of 84 APPENDIX 4 Page 1 of 3 ADMINISTRATIVE CONTROLS FOR RWST ISO Q2G31V010 IN MODES 1-4 1.0 Purpose Establishing administrative controls for opening the RWP Pump Suction from the RWST ISO Q2G31V010 in Modes 1-4.

2.0 Initial Conditions 2.1 Verify the version of this procedure is the current version. (OR 1-98-498) 2.2 Verify this procedure is the correct unit for the task. (OR 1-98-498)

CAUTION The RWST and piping upstream of Q2G31 VOlO is safety-related and seismic category 1; the SFP purification loop downstream of Q2G31 V010 is non-seismic and non-safety related. Failure to close this valve when required could result in the RWST being unable to fulfill its SR function.

3.0 Administrative Controls and Compensatory Measures 3.1 When RWP Pump Suction from RWST Iso Q2G31 VOlO is open, the following compensatory actions must be taken to maintain the operability of the RWST.

3.2 Administrative Controls and Compensatory Measures 3.2.1 Check RWST level greater than 39.1 ' . o 3.2.2 Establish a trend of RWST level in the Control Room . o 3.2.3 Establish an IPC temporary alarm for decreasing RWST level at 39.1'. o 3.2.4 Assign an operator to be readily available and able to secure the RWP pump and close Q2G31V010 within 10 minutes.

3.2.4.1 Make AUTO-LOG entry to record name of assigned operator. o E5-11

UNIT 2 Farley Nuclear EnclT>~ure 5 ant A Procedure Number FNP-2-S0P-54.4 Ver 21.1 RWST SILICA REMOVAL BY THE BORIC ACID RECOVERY Page Number 2/23/2012 11:42:39 SYSTEM (BARS) 76 of 84 3.2.4.2 Operator}lssigned to close Q2G31VOlO must remain within the seismically qualified Aux Building at all times while Q2G31V010 is open. D 3.2.4.3 The assigned operator cannot be a member of the Fire Brigade. (CR 2010101019) D APPENDIX 4 Page 2 of 3 3.2.5 Establish a method of communication between the assigned operator and the Control Room. D 3.2.5.1 Make AUTO-LOG entry to record method of communication. D 3.2.6 Conduct a pre-job brief with the assigned operator and operating crew. The prejob brief must cover, at a minimum: D

Identity of operator assigned to secure the RWP pump and close Q2G31V010,

Method of communication between the assigned operator and Control Room,

Limitations on movement of assigned operator between locations (ability to respond within 10 minutes and requirement to remain within the Aux. Bldg.),

Location of RWP pump and valve Q2G31VOlO and ingress / egress path,

Actions to take upon receipt of seismic alarm,

Initiating conditions which require securing the RWP pump and closing Q2G31 VOlO:

a RX trip

any unexplained Aux. Bldg. sump or tank level increase

unexplained RWST level decrease

direction of the SS.

E5-12

UNIT 2 Farley Nuclear EnClp~urft5 an A Procedure Number FNP-2-S0P-54.4 Ver 21.1 RWST SILICA REMOVAL BY THE BORIC ACID RECOVERY Page Number 2/23/201211:42:46 SYSTEM (BARS) 77 of84 3.2.7 !E required to relieve the assigned operator with a different assigned operator, THEN perform following: o 3.2.7.1 Make AUTO-LOG entry to record transfer of responsibilities and the name of the newly assigned operator 3.2.7.2 Perform a prejob brief in accordance with step 3.2 .6 with the newly assigned operator and operating crew. o E5-13

UNIT 2 Farley Nuclear Encl~~ure 5 ant A Procedure Number FNP-2-S0P-54.4 Ver 21.1 Page Number RWST SILICA REMOVAL BY THE BORIC ACID RECOVERY 2/23/2012 11:42:53 SYSTEM (BARS) 78 of 84 APPENDIX 4 Page 3 of 3 3.2.8 !E any of the initiating conditions identified in Step 2.6 occur, TH EN perform steps 2.8.1 and 2.8.2 within 10 minutes. D 3.2.8.1 Secure the RWP pump (130' Room 609). D 3.2.8.2 Close RWP Pump Suction from RWST Iso Q2G31VOlO (130' room 609).

3.2.9 !E a seismic alarm is received, THEN perform Step 3.2.9.1 OR Step 3.2.9.2 within 10 minutes. D 3.2.9.1 Station an operator at the valve until the alarm is reset . D 3.2.9.2 Perform the following. D 3.2.9.2.1 Secure the RWP pump (130' Room 609). D 3.2.9.2.2 Close RWP Pump Suction from RWST Iso Q2G31V010 (130' room 609).

3.2.10 !.E. RWST Iso Q2G31 VOlO is closed, THEN perform BARS Emergency Shutdown as time and plant priorities permit D 4.0 References None.

E5-14

v t e Letter Sequence Request
TAC:ME8005, (Approved, Closed)
Initiation Request, Request, Request Acceptance... Administration Questions Answers Results Approval Other: ML12053A144, ML12053A145, NRC-2012-0053, FRN - Joseph M. Farley Nuclear Plant, Units 1 and 2 - Individual Notice of Consideration
MONTHYEAR2012-02-29 [Table View]

NL-12-0403, Exigent Technical Specification Revision Request for TS 3.5.4 Refueling Water Storage Tank (RWST)

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NL-12-0403, Exigent Technical Specification Revision Request for TS 3.5.4 Refueling Water Storage Tank (RWST)

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