NL-15-1665, Response to Request for Additional Information Regarding SNC License Amendment Request for TSTF-523, Revision 2

Response to Request for Additional Information Regarding SNC License Amendment Request for TSTF-523, Revision 2

ML15258A535
Person / Time
Site:	Farley
Issue date:	09/15/2015
From:	Pierce C Southern Co, Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-15-1665
Download: ML15258A535 (10)

Text

Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7872 SOUTHERN * \

Fax 205.992.7601 NUCLEAR A SOUTHERN COMPANY SEP 1 5 2015 Docket Nos.: 50-348 NL-15-1665 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant- Units 1 and 2 Response to Request for Additional Information Regarding SNC License Amendment Request for TSTF-523. Revision 2

References:

1. SNC Letter NL-15-0421, Joseph M. Farley Nuclear Plant- Units 1 and 2 License Amendmen t Request to Revise Technical Specifications Regarding Generic Letter 2008-01, Managing Gas Accumulation in accordance with TSTF-523, Revision 2, Using the Consolidated Line Item Improvement Process (CL/IP), dated May 12, 2015.

2. NRC Letter, Joseph M. Farley Nuclear Plant, Units 1 and 2- Request for Additional Information (TAG NOS. MF6211 AND MF6212), dated August 20, 2015.

Ladies and Gentlemen:

On May 12, 2015, in accordance with the provisions of 10 CFR 50.90 Southern Nuclear Operating Company (SNC) submitted a request for an amendment to the technical specifications (TS) for Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2 (Reference 1).

The proposed amendment would modify TS requirements related to Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray systems," as described in TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation."

Following the submittal of the FNP License Amendmen t Request, SNC received a request for additional information by the NRC on August 20, 2015 (Reference 2). provides the requested information. Enclosure 2 provides the replacement pages for the affected LAR FNP Technical Specification Marked Up Pages. Enclosure 3 provides the replacement pages for the affected LAR FNP Technical Specification Clean Typed Pages.

U.S. Nuclear Regulatory Commission NL-15-1665 Page2 This letter contains no new NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.

Mr. C. R. Pierce states he is Regulatory Affairs 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.

c.t.r; Respectfully ~mitted, C. R. Pierce Regulatory Affairs Director CRP/GLS/Iac Sworn to and subscribed before me this /6 day of.!p~ ,2015.

Notary Public My commission expires: I 6 - t ' ..:Z.o r1

Enclosures:

1 . Response to Request for Additional Information - TSTF-523

2. FNP Technical Specification Marked Up Replacement Pages

3. FNP Technical Specification Clean Typed Replacement Pages cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. M. D. Meier, Vice President- Regulatory Affairs Ms. C. A. Gayheart, Vice President - Farley Mr. D. R. Madison, Vice President- Fleet Operations Mr. B. J. Adams, Vice President- Engineering Ms. B. L. Taylor, Regulatory Affairs Manager- Farley RType: CFA04.054 U.S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. L. D. Wert, Regional Administrator (Acting)

Mr. S. A. Williams, NRR Project Manager- Farley Mr. P. K. Niebaum, Senior Resident Inspector- Farley Alabama Department of Public Health Dr. D. E. Williamson, State Health Officer

Joseph M. Farley Nuclear Plant - Units 1 and 2 Response to Request for Additional Information Regarding SNC License Amendment Request for TSTF-523, Revision 2 Enclosure 1 Response to Request for Additional Information - TSTF-523

Enclosure 1 to NL-15-1665 Response to Request for Additional Information- TSTF-523 Page 1 The NRC staff has reviewed the Joseph M. Farley Nuclear Plant, Units 1 and 2 license amendment request and determined that additional information is necessary as noted below.

RAI No.1 TSTF-523, Revision 2, has been approved by the NRC, and the licensee stated in their submittal that the proposed amendment was consistent with TSTF-523, Revision 2. In Enclosure 2 of the submittal, new Surveillance Requirements 3.4.8.3 and 3.9.5.3 use the phrase "Verify required RHR loop locations ... " versus the approved TSTF verbiage, "Verify RHR loop locations ...." The wording in the submittal is inconsistent with TSTF-523 and Limiting Conditions for Operation (LCOs) 3.4.8 and 3.9.5, which specify that two RHR loops shall be OPERABLE.

TSTF-523 uses the qualifier "required" in the surveillance language when the associated LCO calls for only one RHR loop to be operable.

Please revise the submittal to use language that is consistent with the approved traveler and LCOs 3.4.8 and 3.9.5 or provide a technical justification for the deviation.

SNC Response to RA1:

The new Surveillance Requirements (SA's) 3.4.8.3 and 3.9.5.3 will remove the word "required to ensure consistency with TSTF-523, Revision 2. The SA's will now use the approved verbiage "Verify RHR loop locations susceptible to gas accumulation are sufficiently filled with water." Enclosure 2 will include the pages to replace in the LAR for FNP Technical Specification Marked Up Pages sent in the original SNC letter NL-15-0421. Enclosure 3 will include the pages to replace in the LAR for the FNP Technical Specification Clean Typed Pages sent in the original SNC letter NL-15-0421. This change ensures that the proposed amendment is now consistent with TSTF-523, Revision 2.

Joseph M. Farley Nuclear Plant - Units 1 and 2 Response to Request for Additional Information Regarding SNC License Amendment Request for TSTF-523. Revision 2 Enclosure 2 FNP Technical Specification Marked Up Replacement Pages

Enclosure 2 to NL-15-0421 FNP Technical Specification Marked Up Pages RCS Loops- MODE 5, Loops Not Filled 3.4.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required RHR loops B.1 Suspend all operations Immediately inoperable. involving reduction in RCS boron concentration.

AND No RHR loop in operation. B.2 Initiate action to restore Immediately one RHR loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR loop is in operation. In accordance with the Surveillance Frequency Control Program SR 3.4.8.2 Verify correct breaker alignment and indicated power In accordance with are available to the required RHR pump that is not in the Surveillance operation. Frequency Control Program

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SR 3.4.8.3 Verify RHR loop locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Farley Units 1 and 2 3.4.8-2 Amendment No. .:tg§ (Unit 1)

Amendment No. 4-W (Unit 2)

E2-4 to NL-15-0421 FNP Technical Specification Marked Up Pages RHR and Coolant Circulation- Low Water Level 3.9.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 Verify one RHR loop is in operation and circulating In accordance with reactor coolant at a flow rate of 2: 3000 gpm. the Surveillance Frequency Control Program SR 3.9.5.2 Verify correct breaker alignment and indicated power In accordance with available to the required RHR pump that is not in the Surveillance operation. Frequency Control I Program I

SR 3.9.5.3 Verify RHR loop locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Farley Units 1 and 2 3.9.5-3 Amendment No. .:t.8a (Unit 1)

Amendment No. 400 (Unit -2)

E2-11

Joseph M. Farley Nuclear Plant - Units 1 and 2 Response to Request for Additional Information Regarding SNC License Amendment Request for TSTF-523. Revision 2 Enclosure 3 FNP Technical Specification Clean Typed Replacement Pages

RCS Loops- MODE 5, Loops Not Filled 3.4.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required RHR loops B.1 Suspend all operations Immediately inoperable. involving reduction in RCS boron concentration.

OR AND No RHR loop in operation. B.2 Initiate action to restore Immediately one RHR loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR loop is in operation. In accordance with the Surveillance Frequency Control Program SR 3.4.8.2 Verify correct breaker alignment and indicated power In accordance with are available to the required RHR pump that is not in the Surveillance operation. Frequency Control Program SR 3.4.8.3 Verify RHR loop locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Farley Units 1 and 2 3.4.8-2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

RHR and Coolant Circulation- Low Water Level 3.9.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 Verify one RHR loop is in operation and circulating In accordance with reactor coolant at a flow rate of~ 3000 gpm. the Surveillance Frequency Control Program SR 3.9.5.2 Verify correct breaker alignment and indicated power In accordance with available to the required RHR pump that is not in the Surveillance operation. Frequency Control Program SR 3.9.5.3 Verify RHR loop locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Farley Units 1 and 2 3.9.5-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)