Text

Units 1 and 2 - Response to Third Request for Additional Information Regarding SNC License Amendment Request for TSTF-523, Revision 2
	ML16028A475
Person / Time
Site:	Vogtle, Farley
Issue date:	01/28/2016
From:	Pierce C; Southern Co, Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-16-0086, TSTF-523, Rev. 2
	Download: ML16028A475 (6)
	v • d • e

Charles R. Pierce Regulatory Affairs Director January 28, 2016 Southern Nuclear Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7872 Fax 205.992.7601 Docket Nos.: 50-348, 50-364 50-424, 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 SOUTHERN<<\\

NUCLEAR A SOUTHERN COMPANY NL-16-0086 Joseph M. Farley Nuclear Plant-Units 1 and 2

References:

Vogtle Electric Generating Plant-Units 1 and 2 Response to Third Request for Additional Information Regarding SNC License Amendment Request for TSTF-523, Revision 2

1.

SNC Letter NL-15-0421, Joseph M. Farley Nuclear Plant-Units 1 and 2 License Amendment 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 (CLIIP),

dated May 12, 2015.

2.

SNC Letter NL-15-0422, Vogtle Electric Generating Plant-Units 1 and 2 License Amendment 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 (CLIIP},

dated May 12, 2015.

3.

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

4.

NRC Letter, Vogtle Electric Generating Plant, Units 1 and 2-Request for Additional Information on License Amendment Request (TAG NOS. MF6213 AND MF6214), dated August 24, 2015.

5.

SNC Letter NL-15-1665, Joseph M. Farley Nuclear Plant-Units 1 and 2-Request for Additional Information Regarding SNC License Amendment Request for TSTF-523, Revision 2, dated September 15, 2015, ML15258A535.

6.

SNC Letter NL-15-1739, Vogtle Electric Generating Plant-Units 1 and 2-Response to Request for Additional Information Regarding SNC License Amendment Request for TSTF-523, Revision 2, dated September 21, 2015, ML15264A738.

7.

NRC Letter, Joseph M. Farley Nuclear* Plant, Units 1 and 2 and Vogtle, Units 1 and 2-Request for Additional Information (GAG NOS. MF6211, MF6212, MF6213, AND MF6214}, dated October 29, 2015.

8.

SNC Letter NL 2062, Joseph M. Farley Nuclear Plant, Units 1 and 2 and Vogtle, Units 1 and 2-Response to Second Request for Request for Additional Information for TSTF-523, Revision 2, dated November 25, 2015.

9.

NRC E-mail, Joseph M. Farley Nuclear Plant, Units 1 and 2 and Vogtle, Units 1 and 2-Request for Additional Information for Summary of Clarification Telecon with SNC, dated 1/14/16.

Ladies and Gentlemen:

On May 12, 2015, in accordance with the provisions of 1 0 CFR 50.90 Southern Nuclear Operating Company (SNC) submitted a request for an amendment to the technical

U.S. Nuclear Regulatory Commission NL-16-0086 Page 2 specifications (TS) for Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2 and Vogtle Electric Generating Plant (VEGP), Units 1 and 2 (References 1 and 2).

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 and VEGP License Amendment Requests, SNC received a request for additional information by the NRC on August 20, 2015 (Reference

3) and on August 24, 2015 (Reference 4). The response to this set of RAis was addressed in SNC Letters NL-15-1665 and NL-15-1739 (Reference 5 and 6).

A second request for a follow-up set of RAis was sent by the NRC combined for both FNP and VEGP on October 29, 2015 (Reference 7). The response to this set of RAis was addressed in SNC Letter NL-15-2062 (Reference 8).

The NRC has asked per an E-mail summarizing a Telecon dated 1/14/16, a third request for follow-up clarification of RAis asking the same type information for FNP and VEGP (Reference 9). Enclosure 1 provides the requested information.

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.

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Enclosure:

Response to Request for Additional Information-TSTF-523

U.S. Nuclear Regulatory Commission NL-16-0086 Page 3 cc:

Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Best, Executive Vice President & Chief Nuclear Officer Mr. M. D. Meier, Vice President-Regulatory Affairs Ms. C. A. Gayheart, Vice President - Farley Mr. B. K. Taber, Vice President-Vogtle 1 & 2 Mr. D. R. Madison, Vice President-Fleet Operations Mr. B. J. Adams, Vice President - Engineering Ms. B. L. Taylor, Regulatory Affairs Manager - Farley Mr. G. W. Gunn, Regulatory Affairs Manager - Vogtle 1 & 2 RTypes: CFA04.054; CVC7000 U.S. Nuclear Regulatory Commission Ms. C. Haney, Regional Administrator Mr. S. A. Williams, NRR Project Manager-Farley Mr. R. E. Martin, NRR Senior Project Manager-Vogtle 1 & 2 Mr. P. K. Niebaum, Senior Resident Inspector-Farley Mr. L. M. Cain, Senior Resident Inspector-Vogtle 1 & 2 Alabama Department of Public Health Dr. T. M. Miller, MD, State Health Officer State of Georgia Mr. J. H. Turner, Director-Environmental Protection Division

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

Enclosure to NL-16-0086 Response to Request for Additional Information - TSTF-523 Page E-1 Per a telecon on January 14, 2016 between Southern Nuclear Operating Company (SNC) and the NRC staff concerning the Vogtle Electric Generating Plant (VEGP) and Joseph M.

Farley Nuclear Plant (FNP) License Amendment Requests (LARs) for the adoption of TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation," the following clarifications concerning the LAR were requested:

RAI No.1 In regard to the licensee's response to RAI No.2 via SNC letter NL-15-2062 dated November 25, 2015, the licensee discussed "low flow system operation." In the response, the licensee justified that certain surveillance requirements (SRs) associated with both the VEGP and FNP Residual Heat Removal (RHR) systems could be considered met if the RHR system was operating. The licensee also clarified that the operating RHR system could only be credited to meet the SRs if it was not operating in a configuration of "low flow system operation." During the telecon, the NRC staff requested a clarification of what was meant by "low flow system operation." The licensee agreed to provide the specific definition of "low flow system operation."

SNC Response to RA 1:

FNP and VEGP Residual Heat Removal (AHA) systems low flow system operation is defined to ensure gas voids are transported through the system and not allowing stagnant branch lines in the RHR operating system to be susceptible to gas accumulation. RHR low flow system operation is determined by engineering judgment to be when the RHR system flow is below the system minimum flow valve setpoint (allowing the miniflow valve to be open). When the RHR loop flow system is above the closing miniflow setpoint and the minimum flow valve closes due to the RHR loop system flow increasing, the system operation is not in low flow system operation as pertaining to gas accumulation. Flow of the RHR system is assured to sweep voids away in the system while the RHR loop system is running above the minimum flow setpoint. The Technical Specification (TS) Bases will be updated with this definition of RHR system "low flow system operation" during the implementation period.

Per the operating procedures, FNP-112-SOP-7.0, Unit 1 I Unit 2 Residual Heat Removal System operation and VEGP 13011-112, Unit 1 I Unit 2 Residual Heat Removal System operation, the operating guidance directs the RHR loop flow to be~ 3000 gpm flow either set manually or by an automatic controller. This value is the normal operation of RHR loop in the decay heat removal mode as provided by operating procedure guidance.

The minimum flow valve closing setpoints for each of the units are:

FNP Unit 1 RHR miniflow valves closing setpoints: (nominally 1500 gpm)

FNP Unit 2 RHR miniflow valves closing setpoints: (nominally 2200 gpm)

VEGP Unit 1 and Unit 2 RHR miniflow valves closing setpoints: (nominally 1841 gpm)

For FNP, per both operating procedures, when operating an RHR pump at a reduced flowrate, the time operating less than 2750 GPM should be minimized, when practical, to reduce thrust loading of the RHR pump thrust bearing.

For VEGP, per both operating procedures it states, if the RCS is under vacuum, a minimum flow rate of about 1200 gpm for 3 minutes is needed to refill the voided section of RHR discharge piping.

Enclosure to NL-16-0086 Response to Request for Additional Information-TSTF-523 Page E-2 Therefore, as discussed above, when the RHR loop is in its normal operation it is not in low flow system operation and the RHR loop running in this mode can be justified to satisfy the SR.

RAI No.2 In the LARs for both VEGP and FNP the licensee self-identified a deviation in the Technical Specification (TS) bases for VEGP and FNP SRs 3.5.2.2 and 3.6.6.1. The deviation for the subject SRs concerns a note in the TS that allows vent flow paths to be opened under administrative controls, which are defined in the TS bases. In regard to the administrative controls the TS bases for TSTF-523 specifies that a "dedicated" individual will be stationed at the system vent flow path so that it can be isolated rapidly if necessary. The VEGP and FNP LAR submissions remove the qualifier "dedicated" and state that an individual will be stationed at the vent flow path. The licensee agreed to answer how VEGP and FNP will ensure that the system vent flow path can be isolated rapidly if a "dedicated" individual is not assigned to the sole task of being ready to rapidly close the system vent flow path if directed.

Also, in regard to the same TS bases describing the administrative controls, TSTF-523 states the following in regard to the dedicated individual, who is in continuous communication with the operators in the control room." This language indicates the dedicated individual will remain in continuous communication with the control room operators so that the vent flow path can be isolated rapidly if necessary. This language was not included in the VEGP and FNP proposed TS bases. During the telecon the licensee agreed to describe how the communication requirements at VEGP and FNP will ensure that the vent flow path can be isolated rapidly when needed if the dedicated individual stationed at the vent flow path is not in continuous communication with the control room operators.

SNC Response to RA2:

Per the operating venting procedures for FNP and VEGP, an assigned operator is stationed to perform the venting process for the section of piping to be vented. Prior to opening the vent, the operator notifies the control room and health physics for his intent of opening the vent valve(s) required to be opened. It states in the procedures that the operator should close the vent valves immediately upon notification by the control room. In fact, at FNP this caution also directs the operator to close the vent valve immediately by notification of sounding of the Plant Emergency Alarm. A note in the procedures also states the venting requires an operator to open the applicable isolation valve(s) and to observe a solid stream of water flow from the vent ensuring he is locally stationed at the vent valve(s). By adhering to this note in the procedure, this step also assures that the assigned operator will stay focused on his task not allowing ancillary duties to interfere. The operating venting procedures for the sites also require the operator to notify the control room and health physics when the evolution is complete.

While performing the venting evolution, the assigned operator can stay in contact with control room by a radio if the areas where the vent valves are located are feasible for use of the radio.

Otherwise, the assigned operator will listen for instructions from the plant GAI-Tronics system for urgent instructions from the control room. At the end of routine venting evolutions, the assigned operator may also use a plant phone land line to notify control room of completion.