Text

Supplement to License Amendment Request for Technical Specification 3.3.2 Regarding Steam Flow Isolation on High Steam Flow and Response to Request for Additional Information
	ML18158A579
Person / Time
Site:	Farley
Issue date:	06/07/2018
From:	Gayheart C; Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EPID L-2017-LLA-0428, NL-18-0733
	Download: ML18158A579 (48)
	v • d • e

A, Southern Nuclear Cheryl A. Gayheart Regulatory Affairs Director 3535 Colonnade Parkway Birmingham, AL 35243 205 992 5316 tel 205 992 7601 fax JUN 0 7 2018 cagayhea@ southernco.com Docket Nos. : 50-348 NL-18-0733 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant- Unit 1 and 2 Supplement to License Amendment Request for Technical Specification 3.3.2 Regarding Steam Flow Isolation on High Steam Flow and Response to Request for Additional Information Ladies and Gentlemen:

References:

1. Letter from J.J. Hutto (SNC) to Document Control Desk (NRC) dated December 21, 2017, "License Amendment Request for Technical Specification 3.3.2 Regarding Steam Flow Isolation on High Steam Flow (NRC ADAMS Accession No. ML17355A516)

2. Email from S. Williams (NRC) to K. Lowery (SNC) dated February 23, 2018, 12:02 PM, "

Subject:

RE: RE: December 21, 17, Farley TS 3.3.2 application"

3. Email from M. Orenak (NRC) to N. Jackson and K. Lowery (SNC) dated April 13, 2018, 12:47 PM, "

Subject:

Additional RAis for Farley TS 3.3.2"

4. Letter from S. A. Williams (NRC) to C. A. Gayheart (SNC) dated May 1, 2018, "Joseph M. Farley Nuclear Plant, Units 1 and 2 - Request for Additional Information RE: TS 3.3.2, 'Engineered Safety Feature Actuation System (ESFAS) Instrumentation' (EPID L-2017-LLA-0428)"

(NRC ADAMS Accession No. ML18087A146)

Ladies and Gentlemen:

By letter dated December 21, 2017 (Reference 1), Southern Nuclear Operating Company (SNC) requested a license amendment to revise Farley Nuclear Plant (FNP) Units 1 and 2 Technical Specification (TS) 3.3.2, .. Engineered Safety Feature Actuation System (ESFAS) Instrumentation, .. to add TS Actions that allow time to restore one high steam flow channel per steam line to Operable status before requiring a unit shutdown in the event two channels in one or more steam lines are discovered inoperable due to the trip setting not within Allowable Value. On February 23, 2018, via electronic mail (Reference 2), the NRC provided a request for supplemental information to support the NRC staff's development of the Federal Register Notice for the FNP ESFAS High Steam Flow Instrumentation License Amendment Request (LAR) and the analysis that shows the LAR

U.S. Nuclear Regulatory Commission NL-18-0733 Page 2 involves no significant hazards consideration (NSHC) pursuant to Paragraph (c), Section 50.92 of Title 10 of the Code of Federal Regulations (1 0 CFR). By teleconferences on March 6 and 28, 2018, SNC discussed the request for supplemental information with the NRC staff to confirm an understanding of the information being requested. On April 13, 2018, via electronic mail (Reference 3), the NRC provided proposed request for additional information (RAI) to support the review of the FNP ESFAS High Steam Flow Instrumentation LAR. By teleconference on April 24, 2018, SNC discussed the proposed RAI with the NRC staff to confirm an understanding of the information being requested.

By letter dated May 1, 2018 (Reference 4), the NRC provided formal RAI to support the review of the FNP ESFAS High Steam Flow Instrumentation LAR. provides a revised basis for the proposed change, including a revised proposed NSHC analysis. Enclosures 2 and 3 contain revised marked-up TS pages and clean-typed TS pages, respectively. Enclosure 4 contains revised TS Bases pages marked to show the accompanying proposed changes for information only. These revised enclosures supplant the original enclosures in the FNP ESFAS High Steam Flow Instrumentation LAR (Reference 1). Enclosure 5 provides SNC responses to the NRC staff RAI included in letter dated May 1, 2018 (Reference 4).

The following summarizes the changes to the original enclosures:

Enclosure 1, Section 2.2 is revised to describe the new proposed action to immediately verify that one manual initiation channel per steam line is Operable when below the ESFAS Tavg low low interlock and clarifies that proposed Condition M is limited to no more than one week after reaching 1OOo/a rated thermal power following a unit startup from refueling consistent with wording of Note 2 in proposed Condition M.

Additionally, proposed Action M is split into two actions, Action M and N to facilitate the new required action.

Information is added to Enclosure 1, Sections 3.2 and 3.5 to clarify the primary ESFAS steam isolation instrument functions that are assumed in the previously evaluated accidents, including full spectra of steam line break accidents and that the proposed condition does not represent a loss of safety function.

The 10 CFR 50.36, Technical specifications," portion of Enclosure 1, Section 4.1 is revised to clarify that the ESFAS high steam flow instrumentation does not represent a limiting safety system setting and does not meet any 10 CFR 50.36(c)(2)(ii) criteria.

GDC-29 discussion in Enclosure 1, Section 4.1 is revised to clarify that the ESFAS high steam flow instrumentation is not credited to isolate the steam lines in any anticipated operational occurrence specified in the FNP Final Safety Analysis Report and that the ESFAS instrumentation that is credited to isolate the steam lines is not impacted by this license change.

Responses to Questions 1 and 3 of the NSHC analysis in Enclosure 1, Section 4.2 are revised to further clarify how the probability and consequences of previously evaluated accidents are not increased and the margin of safety is not reduced.

Enclosure 2 is revised to: update the TS pages to the most recent approved TS pages; and incorporate changes to proposed Action M, including the addition of Action N, as described in Enclosure 1, Section 2.2.

U.S. Nuclear Regulatory Commission NL-18-0733 Page 3 .

Enclosures 3 and 4 are revised to incorporate changes to proposed Action M, including the addition of Action N. Additional clarifications related to the steam line isolation functions are added to the TS 3.3.2 Bases as shown in revised Enclosure 4.

The information provided herein does not change the intent or the justification for the requested license amendment (Reference 1). Although editorial changes are proposed for the 10 CFR 50.92 evaluation associated with the FNP ESFAS High Steam Flow Instrumentation LAR, SNC has determined that this supplement does not affect the conclusion that the proposed license amendment does not involve a significant hazards consideration. Revised wording of the 10 CFR 50.92 evaluation provided in the December 21, 2017 submittal (Reference 1) is included in Enclosure 1.

This letter contains no NRC commitments.

In accordance with 10 CFR 50.91, SNC is notifying the State of Alabama of this license amendment request by transmitting a copy of this letter and enclosures to the designated State Official.

If you have any questions, please contact Jamie Coleman at 205.992-6611.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the l day of June 2018.

Respectfully submitted, Cheryl A. art Director, Regulatory Affairs Southern Nuclear Operating Company CAG/kgl/sm

Enclosures:

1. Revised Basis for Proposed Change

2. Revised Technical Specification Marked-up Pages

3. Revised Clean Typed Technical Specification Pages

4. Revised Technical Specification Bases Marked-up Pages (For Information Only)

5. Response to Request for Additional Information to Support NRC Staff Review of the ESFAS High Steam Flow- Steam Line Isolation LAR cc: Regional Administrator, Region II NRR Project Manager- Farley Senior Resident Inspector- Farley Director, Alabama Office of Radiation Control RTYPE: CFA04.054

Joseph M. Farley Nuclear Plant - Unit 1 and 2 Supplement to License Amendment Request for Technical Specification 3.3.2 Regarding Steam Flow Isolation on High Steam Flow and Response to Request for Additional Information Enclosure 1 Revised Basis for Proposed Change

Enclosure 1 - Revised Basis for Proposed Change

1. Summary Description The proposed amendment to Farley Nuclear Plant (FNP) - Units 1 and 2 operating licenses would revise Technical Specification (TS) 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation," by adding TS Actions that allow time to restore one high steam flow channel per steam line to Operable status before requiring a unit shutdown in the event two channels in one or more steam lines are discovered inoperable due to the trip setting not within the Allowable Value. The proposed TS Actions would only be applicable prior to the completion of the steam flow channel normalization and limited to 7 days after reaching 100°/o rated thermal power (RTP) following refueling.

Steam flow transmitters associated with the High Steam Flow in Two Steam Lines function are calibrated each refueling outage utilizing predicted instrument scaling tables based on previous operational steam flow scaling data. Following the initial post-refueling power ascension, the steam flow transmitters are normalized, as needed, utilizing beginning-of-cycle (BOC) steam flow scaling data. The proposed amendment is needed because the channel normalization for the ESFAS High Steam Flow in Two Steam Lines channels cannot be performed until after steam flow scaling data has been obtained and could result in the channels not being within the proper instrument accuracy requiring the channels to be declared inoperable. Currently, there are no TS Actions provided for two high steam flow channels inoperable in one or more steam lines requiring application of limiting condition for operation (LCO) 3.0.3 and resulting in a unit shutdown. Previous events associated with normalization of the ESFAS High Steam Flow in Two Steam Lines channels have resulted in unnecessary unit shutdowns and Licensee Event Reports (LERs) in accordance with 10 CFR 50.73.

2. Detailed Description 2.1 Current Technical Specification Requirements TS 3.3.2 requires the High Steam Flow in Two Steam Lines Coincident with Tavg - Low Low function (Table 3.3.2-1, Function 4.e) to be Operable in Mode 1, and Modes 2 and 3 except when one main steam isolation valve (MSIV) is closed in each steam line. Table 3.3.2-1 provides the requirements for the high steam flow channels, which include the applicable Modes and other specified conditions, Required Channels, Conditions, Surveillance Requirements, Allowable Value, and Trip Setpoint. With one channel inoperable, TS 3.3.2, Required Action 0.1 requires the channel to be placed in trip within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . With multiple channels inoperable, LCO 3.0.3 is applied since there are no TS Actions specified for two inoperable channels of the High Steam Flow in Two Steam Lines Coincident with Tavg - Low Low function in one or more steam lines.

2.2 Description of the Proposed Change The proposed amendment would add TS Condition M, which states:

"One or more steam lines with two channels inoperable due to trip setting not within Allowable Value."

Two Notes to proposed Condition M are provided to limit the Condition use to only prior to completion of steam flow channel normalization and no more than a week after reaching 100°/o RTP following a unit startup from refueling.

E1-1

Enclosure 1 - Revised Basis for Proposed Change Note 1 states:

"Only applicable prior to steam flow channel normalization."

Note 2 states:

"Only applicable within 7 days after reaching 100°/o RTP following refueling."

Required Action M.1 states:

"Verify one Manual Initiation channel per steam line is OPERABLE;" with a Completion Time of Immediately and a Note that states, "Only applicable when below P-12 interlock."

Required Action M.2 states:

"Restore one channel per steam line to OPERABLE status;" with a Completion Time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

The proposed amendment would add TS Condition N, which states:

"Required Action and associated Completion Time of Condition M not met."

The proposed Required Actions for Condition N would require placing the unit in a condition where the High Steam Flow in Two Steam Lines Coincident with Tavg- Low Low Function is no longer required. Required Actions N.1 .1 and N.1 .2, each with a Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , state:

"Be in MODE 2.

OR Be in MODE 3."

Required Action N.2, states:

"Isolate steam lines;" with a Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Additionally, the proposed amendment would link TS Action M to the High Steam Flow in Two Steam Lines function by adding a reference to Table 3.3.2-1, Function 4.e.

2.3 Reason for the Proposed Change To ensure that the high steam flow channels associated with Function 4.e accurately track with steam line flow following a refueling outage, the measured steam flow scaling data is compared to the predicted steam flow scaling data derived from previous operating cycles. Following the comparison, high steam flow channel adjustment may be required to normalize the channels with the measured steam flow scaling data. Prior to channel normalization, the trip setting of the steam flow transmitters may not be calibrated to within the required as-found tolerance band based on the new measured steam flow scaling data. This could result in the channel trip setting being less conservative than the Allowable Value, thus rendering the associated channel inoperable.

In 2013, two LEAs were transmitted to the NRC communicating events that led to the Completion Time associated with the applicable TS 3.3.2 Required Action not being met as a result of discovering an instrument channel of the ESFAS High Steam Flow in Two E1-2

Enclosure 1 - Revised Basis for Proposed Change Steam Lines function outside of Technical Specification Allowable Value requirements (Refs. 1 and 2).

Apparent causal analysis of the channel out-of-tolerance condition indicated that the condition could be due to steam flow transmitter issues such as equalizing valve leak-by or partial clogging of the flow transmitter sensing lines. Enhanced apparent causal analysis later determined that the direct cause of the channel out-of-tolerance condition was due to instrument drift in the steam flow transmitter possibly as a result of temperature changes between operating cycles.

Additionally, several more LEAs were transmitted to the NRC in 2014 and 2017 related to instrument channel out-of-tolerance conditions associated with High Steam Flow in Two Steam Lines function (Refs. 3 and 4). As indicated in the LEA transmitted in 2017, entry into TS LCO 3.0.3 was required at FNP Unit 1 due to multiple inoperable High Steam Flow in Two Steam Lines channels inoperable resulting in a unit shutdown.

The proposed amendment is needed because, as noted, this condition can result in an unnecessary unit shutdown in accordance with TS LCO 3.0.3 if normalization is required on multiple channels.

3. Technical Evaluation 3.1 System Design and Operation The ESFAS initiates necessary safety systems, based on the values of selected unit parameters, to protect against violating core design limits and the Reactor Coolant System (RCS) pressure boundary, and to limit the consequences of accidents and transients specified in Chapter 15 of the Final Safety Analysis Report (FSAR).

Steam line isolation is provided by three ESFAS instrumentation functions:

Steam* Line Isolation -High Steam Flow in Two Steam Lines Coincident with Tavg

-Low Low,

Containment Pressure - High 2, and

Steam Line Pressure Low.

These functions initiate closure of the MSIVs during a steam line break (SLB) accident or inadvertent opening of a steam generator (SG) relief or safety valve, to maintain at least one unfaulted SG as a heat sink for the reactor and to limit the mass and energy release to containment from a rupture inside containment. Safety injection is also initiated by the Steam Line Pressure Low function. The Steam Line Pressure Low function consists of three pressure channels, one per steam line, arranged in a two-out-of-three logic and may be manually blocked by the operator below the ESFAS Tavg low low (P-12) interlock setpoint.

High steam flow channels provide input to the ESFAS main steam line isolation logic circuitry. Main steam flow transmitters associated with each SG sense flow by measuring the differential pressure (~p) across the flow restrictor that is an integral part of each SG. The flow restrictors create a nozzle effect, so that flow is measured by a venturi-type flow element. Two steam line flow transmitters in each steam line input into the ESFAS steam line flow channels. The steam line flow channels are combined in a E1-3

Enclosure 1 - Revised Basis for Proposed Change one-out-of-two logic to sense high steam flow in one steam line. Steam line isolation on high steam flow in two steam lines results from a single steam line fault due to the increased steam flow in the remaining intact steam lines. The increased steam flow in the remaining intact lines actuates the required high steam flow MSIV isolation. The Steam Line Isolation - High Steam Flow in Two Steam Lines function actuates on one-out-of-two logic in any two of three steam lines coincident with a Tavg- Low Low actuation on a one-out-of-one logic in any two of three RCS loops.

The trip setpoint for the Steam Line Isolation - High Steam Flow in Two Steam Lines function is a linear function that varies with power level as determined by turbine impulse chamber pressure. The ilp function corresponds to 40°/o of full steam flow between 0°/o and 20o/o load to 11 Oo/o of full steam flow at 100°/o load. The accuracy of the steam flow instrumentation that provides input signals to ESFAS is provided in Westinghouse Topical ReportWCAP-13751 (Ref. 5) with a maximum rated steam flow of 122.7°/o. The uncertainty calculations and scaling documents associated with the High Steam Flow in Two Steam Lines function are governed by the FNP Setpoint Control Program and the ESFAS steam line flow channels are designated as Group 1 instruments; the highest level of importance. The FNP Setpoint Control Program methodology is derived from American National Standard ANSI/ISA-S67.04, Part I (Ref. 6) and is in accordance with Westinghouse Topical Report WCAP-13751 (Ref. 5), which has been previously approved by the NRC.

3.2 Current Licensing Basis and Accident Analysis The ESFAS initiates necessary safety systems to limit the consequences of American Nuclear Society (ANS) Condition Ill events (i.e., infrequent faults such as primary coolant spillage from a small rupture which exceeds normal charging system makeup and requires actuation of the safety injection system) and mitigate ANS Condition IV events (i.e., limiting faults which include the potential for significant release of radioactive material).

Each of the analyzed accidents can be detected by one or more ESFAS functions. One of the ESFAS functions is the primary actuation signal for that accident. An ESFAS function may be the primary actuation signal for more than one type of accident. An ESFAS function may also be a secondary or additional actuation signal for one or more other accidents.

As described in FSAR Subsection 7.3.2.9.2 "Steam Break Protection", the ESFAS instrumentation actuates the Emergency Core Cooling System (ECCS) in order to protect the core against an SLB. Following sensing high steam line differential pressure or low steam line pressure, an ESFAS actuation signal is generated. Analysis of steam break accidents, assuming a time delay for signal generation, shows that the ECCS is actuated for an SLB in time to limit or prevent damage in the core. In addition, a reactor trip is initiated from either an overpower trip or an ESFAS safety injection signal and core reactivity is further reduced by the highly borated water injected by the ECCS.

Additional protection against the effects of an SLB accident is provided by feedwater isolation, which occurs upon actuation of the ECCS, and closure of the MSIVs. FSAR Subsection 15.4.2 "Major Secondary System Pipe Rupture", indicates that the steam line isolation is a primary assumption in a major secondary system pipe rupture accident which bounds minor secondary system pipe breaks and the accidental opening of a secondary system steam dump, relief, or safety valve as described in FSAR Subsections E1-4

Enclosure 1 - Revised Basis for Proposed Change 15.3.2 "Minor Secondary System Pipe Breaks", and 15.2.13 "Analysis Effects and Consequences", respectively. FSAR Subsection 15.4.2, Paragraph 15.4.2.1.1 states, in part:

"The following functions provide the necessary protection against a steam pipe rupture: ...

D. Trip of the fast-acting main steam line isolation valves ... or main steam line isolation bypass valves ... after receipt of an ECCS or main steam line isolation signal on:

1. High steam flow in two out of three main steam lines (one of two per line) in coincidence with two out of three low-low RCS average temperature signals.

2. Low steam line pressure signal in any two out of three steam lines.

3. Two out of three high-high (hi-2) containment pressure signals."

Although the High Steam Flow in Two Steam Lines Coincident with Tavg- Low Low ESFAS function does provide protection against a steam pipe rupture, the instrument function is not credited to isolate the steam lines in any accident or transient specified in FSAR Chapter 15, including the full spectra of SLBs inside and outside containment.

WCAP-14722 (Ref. 7) and WCAP-15098 (Ref. 8) provide a summary of the steam line rupture non-loss of coolant accident (LOCA) analysis and the mass and energy (M&E) release analysis for power uprate of FNP Units 1 and 2 and replacement of the FNP Unit 1 and 2 steam generators, respectively. These analyses include the protective functions credited to isolate the steam lines for various spectra of SLBs. WCAP-15560 (Ref. 9) provides a summary of the main steam valve room environmental qualification analysis associated with SLBs outside containment and includes the protective functions assumed to isolate the steam lines consistent with the assumptions in WCAP-14722 and WCAP-15098.

The time sequence of the non-LOCA main steam line break shows a steam line isolation on the Steam Line Pressure Low function in two of three steam lines. The cases for an SLB accident inside and outside containment were analyzed at several power levels between Oo/o RTP and 102°/o RTP with Tavg ~ 547°F and assume the Steam Line Pressure Low function in two of three steam lines initiates a steam line isolation.

Additionally, the main steam line break inside containment analysis also assumes the Containment Pressure - High 2 function initiates a steam line isolation as indicated in FSAR Table 6.2-11. For smaller break size spectra of an SLB, ESFAS manual initiation signals are assumed to initiate a steam line isolation with a timing assumption of 1800 seconds (i.e., 30 minutes).

The SLB accident analyses were evaluated for the condition when RCS Tavg is below the P-12 interlock and the automatic Steam Line Pressure Low function is manually blocked during a plant startup following refueling. SNC determined that core response and dose consequences are not adversely impacted in this condition. At BOC, the RCS is highly borated and the moderator temperature coefficient is close to zero precluding a return to power during an SLB accident. Therefore, the steam line rupture non-LOCA analysis of record at end-of-cycle is bounding. Also, the SLB dose analysis of record assumes 100°/o power equilibrium source terms, including pre-existing radionuclides in the secondary system at the initiation of the SLB accident. These source terms bound E1-5

Enclosure 1 - Revised Basis for Proposed Change those present at BOC startup conditions. Additionally, the dose analysis assumes a conseNatively high flow rate from the faulted generator to the environment, releasing the secondary side activity before manual steam line isolation would occur. Since no credit is taken for isolation of the faulted generator, the SLB dose analysis of record remains bounding over this operating condition.

To confirm the environmental qualification temperature profiles in the main steam valve room are not exceeded during an SLB outside containment when RCS Tavg is below the P-12 interlock and the automatic Steam Line Pressure Low function is manually blocked, a sensitivity case was performed crediting manual initiation actuation at 1800 seconds.

This case assumed the largest postulated break size, which bounds smaller break sizes at this condition. No credit was taken for automatic steam line isolation. Based on the results of this sensitivity case, temperatures in the main steam valve room do not exceed the environmental qualification temperature profiles. Therefore, manual initiation actuation to close the MSIVs is considered acceptable when RCS Tavg is below the P-12 interlock and the automatic Steam Line Pressure Low function is manually blocked for a SLB outside containment.

This proposed amendment does not alter the ESFAS containment pressure, low steam line pressure, or manual initiation instrumentation channels and the Steam Line Pressure Low, Containment Pressure - High 2, and Manual Initiation functions continue to be capable of isolating the main steam lines in the event of an SLB accident.

Since the ESFAS Containment Pressure - High 2, Steam Line Pressure Low, and Manual Initiation functions continue to provide steam line isolation protection during an SLB accident, which also bounds minor secondary system pipe breaks and the accidental opening of a secondary system steam dump, relief, or safety valve, failure of the ESFAS High Steam Flow in Two Steam Lines Coincident with Tavg - Low Low function to close the MSIVs due to channel inaccuracies associated with the steam flow instrumentation has been determined to be of low risk significance.

3.3 Channel Normalization Process To verify and, if required, re-establish the accuracies of certain ESFAS signal processing equipment, BOC full power scaling data of steam flow, steam pressure, feed flows, and impulse pressure channels are collected at various power levels during the initial unit startup following each refueling. Channel calibration of the High Steam Flow in Two Steam Lines channels is dependent on accurate steam flow scaling data for calibration of the inputs to the high steam flow channels. Steam line flow is measured during the power ascension to obtain more accurate steam flow scaling data. Steam flow scaling data is collected at five reactor power ranges between 15°/o and 100°/o RTP. Steam flow testing at various power values produces a different set of steam flow variables. As power is escalated, these values are used to produce an increasingly accurate proportionality constant. Data collected at 1OOo/o RTP result in a higher instrument accuracy because 100°/o RTP is the normal operating level and because measurements of flow and .Llp are more accurate at higher flow rates. The data collected is used to determine the scaling of the turbine impulse pressure protection/control loop, which provides input to the ESFAS high steam flow trip bistables and allows the channel steam flow voltages to be calibrated to 40°/o steam line flow at 20°/o load pressure and 11 Oo/o steam line flow at 100°/o load pressure. The gain of the instrument channel loop is E1-6

Enclosure 1 - Revised Basis for Proposed Change adjusted, as necessary, so that the pressure values at 20°/o and 1OOo/o load correspond to the bop values at 40°/o and 11 0°/o steam flow, respectively.

Operational experience has shown that it takes up to 80 hours9.259259e-4 days 0.0222 hours 1.322751e-4 weeks 3.044e-5 months after reaching 100°/o RTP and steady state steam flow to finalize data collection, analyze the data, input the full power scaling data into the steam flow calculations, revise the applicable channel calibration procedures, and implement the procedures to normalize affected channels of the High Steam Flow in Two Steam Lines function. A proposed TS Action to restore one of the two channels per steam line to Operable status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (i.e., 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time of current Required Action 0.1) to restore the other channel to Operable status provides sufficient time to adjust multiple high steam flow instrument channels upon discovery of the steam flow calculation results exceeding the allowed acceptance criteria. Note 2 limits the use of Condition M to within 7 days after reaching 100°/o RTP following a unit startup from refueling. This provides adequate time during the unit startup to discover the inoperable channels and calibrate them to within the proper accuracy while limiting the time period a loss of steam line isolation capability from the High Steam Flow in Two Steam Lines Coincident with Tavg -

Low Low function is allowed.

3.4 Risk Insights The proposed period of time allowed for two high flow steam channels inoperable per steam line is deterministically based on the time required to accomplish the task; i.e.

restore one of two channels per steam line to Operable status. As such, this LAR is not considered a risk informed submittal. The following risk insights are provided for information only.

The ESFAS and steam line isolation are included in the FNP probabilistic risk assessment internal events (including internal flooding) model and external events models. However, the models do not credit the ESFAS high steam flow instrument signal to actuate the steam line isolation. Therefore, the proposed amendment to allow 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore one of two channels per steam line to Operable status will not result in any change to core damage frequency or large early release frequency.

3.5 Acceptability of the Proposed Change The proposed TS Actions would allow 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore one high steam flow channel per steam line upon discovery of multiple channels not within the proper instrument accuracy after obtaining new scaling data during a unit startup from refueling or the unit must be placed in a condition where the High Steam Flow in Two Steam Lines function is not required. Restoring the channels to Operable status includes ensuring the channel trip setting is adjusted to within the as-left tolerance band of the Trip Setpoint based on the normalized steam flow scaling data and the channel is not otherwise known to be incapable of performing its function.

To ensure steam line isolation capability is available when below the P-12 interlock, proposed Required Action M.1 requires an immediate verification that at least one manual initiation channel per steam line is Operable. The verification may be performed as an administrative check, by examining logs or other information, to determine E1-7

Enclosure 1- Revised Basis for Proposed Change if the minimum required Manual Initiation channels are out of service for testing or other reasons. It does not mean it is necessary to perform the surveillances needed to demonstrate the Operability of the Manual Initiation channels. Action to verify sufficient channels of Steam Line Pressure Low and Containment Pressure - High 2 functions are Operable is not provided because LCO 3.0.3 is currently entered when the number of Operable channels is insufficient to provide steam line isolation capability. When the number of inoperable channels associated with an ESFAS function results in a loss of the associated trip function, the unit may be outside the safety analysis. Therefore, action is currently required in accordance with LCO 3.0.3 when the number of inoperable channels is not addressed by the associated TS condition or combination of conditions.

Because the high steam flow instrument channel normalization only needs to be performed following a refueling outage, proposed Condition M is modified by two notes; limiting its use to; 1) only prior to completion of the instrument channel normalization, and 2) only within 7 days after reaching 100°/o RTP following a unit startup from refueling. The steam flow scaling data comparison and channel normalization uses current procedures, methods, and processes already established and currently in use and, therefore, does not constitute a new type of test.

This proposed amendment is acceptable because the High Steam Flow in Two Steam Lines Coincident with Tavg - Low Low function is not credited to isolate the steam lines in any accident or transient specified in FSAR Chapter 15, including the full spectra of SLBs inside and outside containment. The Containment Pressure - High 2, Steam Line Pressure Low, and Manual Initiation functions continue to provide steam line isolation protection during an SLB accident, which also bounds minor secondary system pipe breaks and the accidental opening of a secondary system steam dump, relief, or safety valve. Therefore, the potential failure of the High Steam Flow in Two Steam Lines Coincident with Tavg - Low Low function to close the MSIVs during this time period due to channel inaccuracies associated with the steam flow instrumentation has been determined to be of low risk significance and the proposed condition does not represent a loss of a safety function assumed in the accident analysis as described in TS 5.5.15, "Safety Function Determination Program (SFDP)."

In addition, the complete loss of the MSIV closure function is currently allowed in Mode 1, and Modes 2 and 3 for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months per TS 3.7.2 Required Actions 8.1 and E.1, respectively. The proposed amendment only allows a potential loss of function to one of three ESFAS automatic closure signals to the MSIVs; an automatic closure signal not credited in the safety analysis.

If both channels are discovered inoperable in one or more steam lines for reasons other than the trip setting not within the Allowable Value, or both channels in one or more steam lines are discovered inoperable for any reason following steam flow channel normalization or after 7 days of reaching 100°/o RTP from a unit startup after refueling, LCO 3.0.3 is entered, as applicable.

If one required manual initiation channel in one or more steam lines is discovered inoperable concurrent with Condition M when below the P-12 interlock or the inoperable high steam flow channels cannot be restored to Operable status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , proposed Action N requires the unit to be placed in either Mode 2 or 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and the steam lines isolated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach Mode 2 or Mode 3 from full power conditions in E1-8

Enclosure 1 - Revised Basis for Proposed Change an orderly manner and without challenging plant systems. The Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is reasonable to isolate all the steam lines with at least one MSIV closed in each steam line. In Mode 2 or 3 with at least one MSIV closed in each steam line (i.e.,

steam lines isolated), the High Steam Flow in Two Steam Lines function (Function 4.e) is no longer required to be Operable. These Completion Times (i.e., 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) are similar to other TS Actions requiring a unit shutdown to Mode 2 or 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and Mode 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . For example: TS 3.2.1 Required Action C.1 and TS 3.2.2 Required Action 8.1 require being in Mode 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; TS 3.3.1 Required Action U .2 requires being in Mode 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months from not meeting Required Action U.1 (7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months total); TS 3.3.2, Required Actions 0.2.1 and 0.2.2, E.2.1 and E.2.2, F.2.1 and F.2.2, K.2.1 and K.2.2 require being in Mode 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and Mode 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from not meeting Required Actions 0.1, E.1, F.1, and K.1, respectively; TS 3.7.2 Required Actions C.1, F.1, and F.2 require being in Mode 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , Mode 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and Mode 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , respectively.

To summarize, the proposed amendment to add TS Actions that allow time to restore the high steam flow channels to Operable status in the event two channels in one or more steam lines are discovered inoperable due to the trip setting not within the Allowable Value is acceptable because, during the proposed 48-hour period of time to restore at least one channel per steam line to Operable status, the ESFAS automatic steam line isolation continues to be provided by the ESFAS instrumentation assumed in the FNP safety analysis; i.e., from either a containment high pressure signal or a low steam pressure signal, which are not impacted by the proposed license change. In addition, manual steam line isolation continues to be provided by the ESFAS manual channels, which are not impacted by the proposed license change. If at least one channel in each steam line cannot be restored to Operable status within the allowed time period or manual steam line isolation capability is not available when below the P-12 interlock, the unit must be placed in a condition where the High Steam Flow in Two Steam Lines function (Function 4.e) is no longer required to be Operable; i.e., either Mode 2 or 3 and the steam lines isolated.

4. Regulatory Evaluation 4.1 Applicable Regulatory Requirements/Criteria The ESFAS design satisfies 10 CFR 50.36, Technical specifications," paragraph (c)(2)(ii), Criterion 3. Steam line isolation from associated ESFAS functions is considered a primary success path to mitigate SLB accidents, including an inadvertent opening of an SG relief or safety valve. The ESFAS Steam Line Pressure Low and Containment Pressure - High 2 functions and Manual Initiation function are the primary functions assumed in the FNP safety analyses to isolate the steam lines to mitigate SLB accidents, including an inadvertent opening of an SG relief or safety valve. The High Steam Flow in Two Steam Lines Coincident with Tavg- Low Low function is an additional instrument signal provided by the Westinghouse plant design and is not credited in any accident or transient specified in the FNP Unit 1 and 2 FSARs.

Instrumentation safety margin is established by ensuring the limiting safety system settings (LSSSs) automatically actuate the applicable design function to correct the abnormal situation before a safety limit is exceeded. Safety analysis limits (SALs) are established for reactor trip system and ESFAS instrumentation functions related to those variables having significant safety functions. WCAP-13751 (Ref. 5) defines a SAL as the E1-9

Enclosure 1 - Revised Basis for Proposed Change limiting parameter value in the safety and transient analysis at which a reactor trip or ESFAS function is assumed to be initiated. At FNP, containment pressure and steam line pressure provide the limiting parameter values assumed in the safety analyses for SLB accidents. As indicated in WCAP-13751 , the High Steam Flow in Two Steam Lines function is not used in the safety analysis and a SAL is not specified for this trip function.

Therefore, the ESFAS High Steam Flow in Two Steam Lines function does not represent an LSSS as defined in 10 CFR 50.36(c)(1 )(ii)(A) because this instrumentation does not monitor a plant variable on which a safety limit has been placed. In addition, the ESFAS High Steam Flow in Two Steam Lines function is not a primary ESFAS instrument signal assumed in the mitigation of a SLB accident and does not meet any 10 CFR 50.36(c)"(2)(ii) criteria requiring a limiting condition for operation (LCO).

The proposed amendment does not delete requirements associated with the ESFAS instrumentation and LCO 3.3.2 continues to maintain requirements associated with structures, systems, and components that are part of the primary success path and actuate to mitigate the related design basis accidents and transients. The proposed amendment does not alter the remedial actions or shutdown requirements required by 10 CFR 50.36(c)(2)(i) for any ESFAS instrumentation requiring an LCO pursuant the criteria of 10 CFR 50.36(c)(2)(ii).

The ESFAS design complies with the requirements of 10 CFR 50.55a(h)(2), Protection and safety systems, and meets the requirements of the applicable Institute of Electrical and Electronics Engineers standard pursuant to 10 CFR 50.55a(2). The proposed amendment does not alter the design of any protection or safety system, including the ESFAS. Therefore, the protection and safety system design continues to meet the requirements of 10 CFR 50.55a.

In addition, the following 10 CFR Part 50, Appendix A General Design Criteria (GDCs) are related to the ESFAS design:

GDC 10: Reactor design. The proposed amendment does not alter the design of the reactor core and associated coolant, control, and protection systems, including the ESFAS. The change adds TS Actions that allow time to normalize the high steam flow channels associated with the ESFAS steam line isolation before requiring a unit shutdown in the event multiple channels are discovered inoperable due to the trip settings not within the required accuracy.

GDC 13: Instrumentation and control. The proposed amendment does not alter the design of the instrumentation that is provided to monitor variables and systems over their anticipated ranges for normal operation for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety. The change adds TS Actions that allow time to normalize the high steam flow channels associated with the ESFAS steam line isolation before requiring a unit shutdown in the event multiple channels are discovered inoperable due to the trip settings not within the required accuracy.

GDC 20: Protection system functions. The proposed amendment does not alter the design of reactivity control protection systems or instrumentation that sense accident conditions to initiate systems or components important to safety. The change adds TS Actions that allow time to normalize the high steam flow channels associated with the ESFAS steam line isolation before requiring a unit shutdown. This ensures the E1-10

Enclosure 1 - Revised Basis for Proposed Change associated ESFAS instrumentation more accurately senses the associated parameter required to initiate a closure of the MSIVs; components important to safety.

GDC 21: Protection system reliability and testability. The proposed amendment does not alter the design of any protection system, including the ESFAS. Therefore, the protection system design continues to provide high functional reliability and inservice testability commensurate with the safety functions to be performed and continues to be sufficient to assure that (1) no single failure results in loss of the protection function and (2) removal from service of any component or channel does not result in loss of the required minimum redundancy. In the event multiple channels are discovered inoperable due to the trip settings not within the required accuracy, this change adds TS Actions that allow time to normalize the high steam flow channels to restore the minimum required redundancy before requiring a unit shutdown. The ESFAS design continues to permit periodic testing of its functioning when the reactor is in operation as previously licensed and approved by the NRC.

GDC 22: Protection system independence. The proposed amendment does not alter the design of any protection system, including the ESFAS. Therefore, the protection system design continues to assure that the effects of natural phenomena, and of normal operating, maintenance, testing, and postulated accident conditions on redundant channels do not result in loss of the protection function to the extent previously licensed and approved by the NRC.

GDC 23: Protection system failure modes. The proposed amendment does not alter the design of any protection system, including the ESFAS. Therefore, the protection system design continues to fail into a safe state or into a state demonstrated to be acceptable as previously licensed and approved by the NRC.

GDC 24: Separation of protection and control systems. The proposed amendment does not alter the design of any protection system, including the ESFAS. Therefore, the protection system design continues to be separated from control systems as previously licensed and approved by the NRC.

GDC 27: Combined reactivity control systems capability. The proposed amendment does not alter the design of the reactivity control systems. Therefore, the reactivity control systems continue to have combined capability, in conjunction with poison addition by the ECCS, of reliably controlling reactivity changes to assure that under postulated accident conditions and with appropriate margin for stuck rods the capability to cool the core is maintained.

GDC 28: Reactivity limits. The proposed amendment does not alter the design of the reactivity control systems. Therefore, the reactivity control systems will continue to limit the potential amount and rate of reactivity increase to assure that the effects of postulated reactivity accidents will not adversely affect the reactor coolant pressure boundary or impair the capability to cool the core.

GDC 29: Protection against anticipated operational occurrences. The proposed amendment does not alter the design of any protection or reactivity control system, including ESFAS. The change adds TS Actions that allow time to normalize the high steam flow channels associated with the ESFAS steam line isolation before requiring a unit shutdown in the event multiple channels are discovered inoperable due to the trip E1-11

Enclosure 1 - Revised Basis for Proposed Change setting not within the required accuracy. This ensures the associated ESFAS instrumentation more accurately senses the associated parameter required to initiate a closure of the MSIVs during secondary pipe ruptures or an inadvertent opening of an SG relief or safety valve. Additionally, the ESFAS high steam flow instrument function is not credited to isolate the steam lines in any accident or anticipated operational occurrence specified in the FSAR, including the full spectra of SLBs inside and outside containment.

The ESFAS instrumentation credited in the safety analyses; i.e., Containment Pressure -

High 2, Steam Line Pressure Low, and Manual Initiation functions, are not altered by this change and continue to provide steam line isolation protection during an SLB accident, which also bounds minor secondary system pipe breaks and the accidental opening of a secondary system steam dump, relief, or safety valve. Therefore, the ESFAS design will continue to assure an extremely high probability of accomplishing its function in the event of anticipated operational occurrences.

4.2 No Significant Hazards Consideration Analysis Pursuant to 10 CFR 50.90, Southern Nuclear Operating Company (SNC) hereby requests an amendment to Farley Nuclear Plant (FNP) Unit 1 Operating License NPF-2 and Unit 2 Operating License NPF-8. The proposed amendment revises Technical Specification 3.3.2, "Engineered Safety Feature Actuation System (ESFAS)

Instrumentation," by adding actions that allow time to normalize the high steam flow channels associated with the ESFAS steam line isolation before requiring a unit shutdown in the event multiple channels are discovered inoperable due to the trip settings not within the required accuracy. The proposed actions would only be applicable prior to the completion of the steam flow channel normalization and limited to 7 days after reaching 100°/o rated thermal power following refueling.

SNC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on 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 proposed amendment does not affect accident initiators or precursors nor adversely alter the design assumptions, conditions, and configuration of the facility.

The proposed amendment does not alter any plant equipment or operating practices with respect to such initiators or precursors in a manner that the probability of an accident is increased.

The proposed amendment does not involve a physical change to the ESFAS, nor does it change the safety function of the ESFAS instrumentation or the equipment supported by the ESFAS instrumentation. The ESFAS high steam flow channels are not assumed in the mitigation of any previously evaluated accident or transient.

Automatic steam line isolation on containment high pressure or low steam pressure is assumed in the mitigation of a major secondary system pipe rupture accident which bounds minor secondary system pipe breaks and the accidental opening of a secondary system steam dump, relief, or safety valve. Manual steam line isolation E1-12

Enclosure 1 - Revised Basis for Proposed Change capability is also assumed in the mitigation of spectra of smaller secondary system pipe ruptures. During the time proposed to normalize the high steam flow channels, automatic ESFAS steam line isolation continues to be provided from either a containment high pressure signal or a low steam pressure signal, which are not impacted by the proposed license change. Additionally, manual steam line isolation continues to be provided by the ESFAS manual channels, which are not impacted by the proposed license change. As a result, the proposed amendment does not alter assumptions relative to the mitigation of an accident or transient event and the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No With respect to a new or different kind of accident, there are no proposed design changes to the ESFAS; nor are there any changes in the method by which safety related plant structures, systems, and components perform their specified safety functions. The proposed amendment will not affect the normal method of plant operation or revise any operating parameters. No new accident scenarios, transient precursor, failure mechanisms, or limiting single failures will be introduced as a result of this proposed change and the failure modes and effects analyses of SSCs important to safety are not altered as a result of this proposed change.

The proposed amendment does not alter the design or performance of the ESFAS, rather, it adds actions that allow time to normalize the high steam flow channels associated with the ESFAS steam line isolation before requiring a unit shutdown in the event multiple channels are discovered inoperable due to the trip settings not within the required accuracy. The process to normalize the high steam flow channels uses current procedures, methods, and processes already established and currently in use and, therefore, does not constitute a new type of test.

No changes are being proposed to the procedures that operate the plant equipment and the change does not have a detrimental impact on the manner in which plant equipment operates or responds to an actuation signal.

Therefore, the proposed change will not create the possibility of a new or different accident previously evaluated.

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

Response: No.

The margin of safety is related to the ability of the fission product barriers to perform their design functions during and following an accident. These barriers include the fuel cladding, the reactor coolant system, and the containment. The performance of these fission product barriers is not affected by the proposed change.

Instrumentation safety margin is established by ensuring the limiting safety system settings (LSSSs) automatically actuate the applicable design function to correct an E1-13

Enclosure 1 - Revised Basis for Proposed Change abnormal situation before a safety limit is exceeded. Safety analysis limits are established for reactor trip system and ESFAS instrumentation functions related to those variables having significant safety functions. Containment pressure and steam line pressure provide the limiting parameter values assumed in the safety and transient analyses for mitigation of previously evaluated accidents and transients, including steam line break accidents. The high steam flow in two steam lines instrument function is not used in the safety analysis and a safety analysis limit is not specified for this trip function. Therefore, the high steam flow in two steam lines instrument function does not represent an LSSS because this instrumentation does not monitor a plant variable on which a safety limit has been placed.

The controlling parameters established to isolate the steam lines during an accident or transient are not affected by the proposed amendment and no design basis or safety limit is altered as a result of the proposed change. 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.

4.3 Conclusions In conclusion, based on the considerations discussed herein, (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. Environmental Consideration SNC has determined that the proposed amendment does not change a suNeillance requirement. The proposed amendment adds actions that allow time to perform a channel normalization of the steam flow instruments associated with the ESFAS steam line isolation following unit startup in the event multiple channels are discovered inoperable due to the trip setting not within the required accuracy. The proposed actions would only be applicable prior to the completion of the steam flow channel normalization and limited to 7 days after reaching 100°/o rated thermal power following refueling. The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released off site, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criteria 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 to be prepared in connection with the proposed amendment.

6. References

1. Letter from T.A. Lynch (SNC) to Document Control Desk (NRC), "Joseph M. Farley Nuclear Plant- Unit 2 Licensee Event Report 2013-001-01 2C Steam Generator Flow Transmitter Inoperable Longer Than Allowed By Technical Specifications," dated E1-14

Enclosure 1 - Revised Basis for Proposed Change September 13, 2013. (NRC Agencywide Documents Access and Management System (ADAMS) Accession No. ML13259A030)

2. Letter from C.A. Gayheart (SNC) to Document Control Desk (NRC), "Joseph M. Farley Nuclear Plant- Unit 1 Licensee Event Report 2013-003-01 1C Steam Generator Flow Transmitter Inoperable Longer Than Allowed By Technical Specifications," dated February 21, 2014. (NRC ADAMS Accession No. ML14052A438)

3. Letter from C.A. Gayheart (SNC) to Document Control Desk (NRC), "Joseph M. Farley Nuclear Plant- Units 1 and 2 Licensee Event Report 2014-003-00 Scaling Errors Result in Inoperable Steam Flow Channels for Durations Longer Than Allowed by Technical Specifications," dated June 2, 2014. (NRC ADAMS Accession No. ML14153A684)

4. Letter from C.R. Pierce (SNC) to Document Control Desk (NRC), "Joseph M. Farley Nuclear Plant- Unit 1 Licensee Event Report 2016-007-00 Plant Shutdown Required by Technical Specifications due to Inoperable Steam Flow Transmitters," dated June 13, 2017. (NRC ADAMS Accession No. ML17013A394)

5. Westinghouse Topical Report WCAP-13751, 'Westinghouse Setpoint Methodology for Protection Systems Farley Nuclear Plant Units 1 and 2 (Model 54F Steam Generators and 2785 MWt NSSS Power)," Rev. 1, October 2002. (Proprietary)

6. American National Standard ANSI/ISA-S67.04, Part I, "Setpoints for Nuclear Safety-Related Instrumentation," September 1994.

7. Westinghouse Topical Report WCAP-14722, "Farley Nuclear Plant Units 1 and 2 Power Uprate Project NSSS Engineering Report," November 1997.

8. Westinghouse Topical Report WCAP-15098, "Farley Nuclear Plant Units 1 and 2 Replacement Steam Generator Program NSSS Licensing Report," November 1998.

9. Westinghouse Topical Report WCAP-15560, "Joseph M. Farley Nuclear Station Units 1 and 2 Main Steam Valve Room Analysis for Steam line Breaks Outside Containment,"

February 2001 .

E1-15

Joseph M. Farley Nuclear Plant- Unit 1 and 2 Supplement to License Amendment Request for Technical Specification 3.3.2 Regarding Steam Flow Isolation on High Steam Flow and

Response to Request for Additional Information Enclosure 2 Revised Technical Specification Marked-up Pages

ESFAS Instrumentation 3.3.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME L. (continued) L.2 ------------N 0 TE-----------

One train may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for Surveillance testing, provided the other train is OPERABLE.

Restore train to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE status.

OR L.3.1 Be in MODE 3. 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months r11nsert ACTIONS M and N 1 AND L.3.2 Be in MODE 5 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months I

SURVEILLANCE REQUIREMENTS

N0 T E---------------------------------------------------------

Refer to Table 3.3.2-1 to determine which SRs apply for each ESFAS Function.

SURVEILLANCE FREQUENCY SR 3.3.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.2.2 Perform ACTUATION LOGIC TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.3 Perform MASTER RELAY TEST. In accordance with the Surveillance Frequency Control Program Farley Units 1 and 2 3.3.2-6 Amendment No. 185 (Unit 1)

Amendment ~Jo . 180 (Unit 2)

Insert ACTIONS M and N M. --------NOTES--------- M.1 -------------NOTE-------------

1. Only applicable prior Only applicable when to steam flow below P-12 interlock.

channel -------------------------------

normalization. Verify one Manual Immediately Initiation channel per

2. Only applicable steam line is OPERABLE.

within 7 days after reaching 100% RTP AND following refueling.

M.2 Restore one channel per 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months steam line to OPERABLE One or more steam lines status.

with two channels inoperable due to trip setting not within Allowable Value.

N. Required Action and N.1.1 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition M not OR met.

N.1.2 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND N.2 Isolate steam lines. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 3 of 4)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER NOMINAL SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE TRIP FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE SETPOINT

4. Steam Line Isolation 1 per steam

a. Manual Initiation 1,2(d),3(d) line F SR 3.3.2.6 NA NA

b. Automatic 1,2(d) ,3(d) 2 trains G SR 3.3.2.2 NA NA Actuation Logic SR 3.3.2.3 and Actuation SR 3.3.2.8 Relays

c. Containment 1,2(d). 3(d) 3 0 SR 3.3.2.1 s 17.5 psig 16.2 psig Pressure - High 2 SR 3.3.2.4 SR 3.3.2.7 SR 3.3.2.9

d. Steam Line 1,2(d) ,3(b)(d) 1 per steam D SR 3.3.2.1 ~ 575(c) psig 585(c) psig Pressure Low line SR 3.3.2.4

~ SR 3.3.2.7 SR 3.3.2.9

e. High Steam Flow 1,2(d) ,3(d) 2 per steam 0 SR 3.3.2.1 {e) (f) in Two Steam line SR 3.3.2.4 lines SR 3.3.2.7 Coincident with 1,2(d),3(d) 1 per loop D SR 3.3.2.1 ~ 542.6*F 543°F Tavg - LOW Low SR 3.3.2.4 SR 3.3.2.7 (b) Above the P-12 (Tavg- Low Low) interlock.

(c) Time constants used in the leadnag controller are t1 ~ 50 seconds and t2 ~ 5 seconds.

(d) Except when one MSIV is closed in each steam line.

(e) Less than or equal to a function defined as 6P corresponding to 40.3% full steam flow below 20% load, .1.P increasing linearly from 40.3% full steam flow at 20% load to 110.3% full steam flow at 100% load.

(f) Less than or equal to a function defined as .1.P corresponding to 40% full steam flow between 0% and 20% load and then a .1.P increasing linearly from 40"/o steam flow at 20% load to 11 OGfo full steam flow at , 00% loa a.

Farley Units 1 and 2 3.3.2-11 AmeAdmeAt No. 203 (Unit 1)

AmcAdmeAt No. 199 (Unit 2)

Joseph M. Farley Nuclear Plant- Unit 1 and 2 Supplement to License Amendment Request for Technical Specification 3.3.2 Regarding Steam Flow Isolation on High Steam Flow and Response to Request for Additional Information Enclosure 3 Revised Clean Typed Technical Specification Pages

ESFAS Instrumentation 3.3.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME L. (continued) L.2 ------------NOTE-----------

One train may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for Surveillance testing, provided the other train is OPERABLE.

Restore train to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE status.

OR L.3.1 Be in MODE 3. 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months AND L.3.2 Be in MODE 5 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months M. ------------NOTES----------- M.1 ------------N0 TE ------------

1. Only applicable prior Only applicable when to steam flow channel below P-12 interlock. .,. __

normalization.

Verify one Manual Immediately

2. Only applicable within Initiation channel per 7 days after reaching steam line is 100% RTP following OPERABLE.

refueling.

AND One or more steam lines M.2 Restore one channel 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months with two channels per steam line to inoperable due to trip OPERABLE status.

setting not within Allowable Value.

Farley Units 1 and 2 3.3.2-6 Amendment No. (Unit 1)

Amendment No. (Unit 2)

ESFAS Instrumentation 3.3.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME N. Required Action and N.1.1 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition M not OR met.

N.1.2 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND N.2 Isolate steam lines. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS

N0 T E---------------------------------------------------------

Refer to Table 3.3.2-1 to determine which SRs apply for each ESFAS Function .

SURVEILLANCE FREQUENCY SR 3.3.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.2.2 Perform ACTUATION LOGIC TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.3 Perform MASTER RELAY TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.4 Perform COT. In accordance with the Surveillance Frequency Control Program SR 3.3.2.5 Perform TADOT. In accordance with the Surveillance Frequency Control Program Farley Units 1 and 2 3.3.2-7 Amendment No. (Unit 1)

Amendment No. (Unit 2)

ESFAS Instrumentation 3.3.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.2.6 -------------------------------N0 TE-------------------------------

Verification of setpoint not required.

Perform T ADOT. In accordance with the Surveillance Frequency Control Program SR 3.3.2.7 -------------------------------N0 TE-------------------------------

This Surveillance shall include verification that the time constants are adjusted to the prescribed values.

Perform CHANNEL CALIBRATION . In accordance with the Surveillance Frequency Control Program SR 3.3.2.8 Perform SLAVE RELAY TEST In accordance with the Surveillance Frequency Control Program SR 3.3.2.9 -------------------------------N0 TE-------------------------------

Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after SG pressure is

~ 1005 psig.

Verify ESFAS RESPONSE TIMES are within limit. In accordance with the Surveillance Frequency Control Program SR 3.3.2.10 -------------------------------N0 TE ------------------------------- ------------N 0 TE ----------

Verification of setpoint not required . Only required when not

performed within previous 92 days.

Perform TADOT. Prior to reactor startup Farley Units 1 and 2 3.3.2-8 Amendment No. (Unit 1)

Amendment No. (Unit 2)

ESFAS Instrumentation 3.3.2 Table 3.3.2-1 (page 3 of 4)

Engineered Safety Feature Actuation System Instrumentation APPLICABLE MODES OR OTHER NOMINAL SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE TRIP FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE SETPOINT

4. Steam Line Isolation 1 per steam

a. Manual Initiation 1,2(d) ,3(d) line F SR 3.3.2.6 NA NA

b. Automatic 1,2(d) ,3(d) 2 trains G SR 3.3.2.2 NA NA Actuation Logic SR 3.3.2.3 and Actuation SR 3.3.2.8 Relays

c. Containment 1,2(d), 3(d) 3 D SR 3.3.2 .1 :; 17.5 psig 16.2 psig Pressure- High 2 SR 3.3.2.4 SR 3.3.2.7 SR 3.3.2.9

d. Steam Line 1,2(d),3(b)(d) 1 per steam D SR 3.3.2 .1 .2:: 575(c) psig sas(c) psig Pressure Low line SR 3.3.2.4 SR 3.3.2 .7 SR 3.3.2.9

e. High Steam Flow 1,2(d) ,3(d) 2 per steam D, M SR 3.3.2 .1 (e) (f) in Two Steam line SR 3.3.2.4 Lines SR 3.3.2 .7 Coincident with 1,2(d),3(d) 1 per loop D SR 3.3.2.1 .2:: 542 .6°F 543°F T avg - Low Low SR 3.3.2.4 SR 3.3.2.7 (b) Above the P-12 (Tavg- Low Low) interlock.

(c) Time constants used in the lead/lag controller are t1 .2:: 50 seconds and t2 :; 5 seconds .

(d) Except when one MSIV is closed in each steam line.

(e) Less than or equal to a function defined as f1P corresponding to 40.3% full steam flow below 20% load, f1P increasing linearly from 40.3% full steam flow at 20% load to 11 0.3% full steam flow at 100% load .

(f) Less than or equal to a function defined as f1P corresponding to 40% full steam flow between 0% and 20% load and then a f1P increasing linearly from 40% steam flow at 20% load to 11 0% full steam flow at 100% load .

Farley Units 1 and 2 3.3.2-11 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Joseph M. Farley Nuclear Plant- Unit 1 and 2 Supplement to License Amendment Request for Technical Specification 3.3.2 Regarding Steam Flow Isolation on High Steam Flow and Response to Request for Additional Information Enclosure 4 Revised Technical Specification Bases Marked-up Pages (For Information Only)

ESFAS Instrumentation B 3.3.2 BASES APPLICABLE e. Safety Injection -Steam Line Pressure SAFETY ANALYSES, LCO, and (1) Steam Line Pressure- Low APPLICABILITY (continued) Steam Line Pressure - Low provides protection against the following accidents:

SLB;and

Feed line break.

Three OPERABLE channels, one on each steam line, are sufficient to satisfy the protective requirements with a two-out-of-three logic.

With the transmitters located outside the main steam valve room, the Trip Setpoint reflects only steady state instrument uncertainties.

This Function is anticipatory in nature and has a lead/lag ratio of 50/5.

Steam Line Pressure - Low must be OPERABLE in MODES 1, 2, and 3 (above P-12) when a secondary side break or stuck open valve could result in the rapid depressurization of the steam lines. This signal may be manually blocked by the operator below the P-12 setpoint.

Automatic Sl actuation is provided by containment pressure

- High 1 and/or High Differential Pressure between steam lines. Inside containment SLB will be terminated by automatic MSLI actuation via Containment Pressure-High 2, and outside containment SLB will be terminated by the High Steam flow in two steam lines coincident with Low-Low- Tavg signal for steam line isolation. This Function is not required to be OPERABLE in MODE 4, 5, or 6 because there is insufficient energy in the secondary side of the unit to cause an accident.

(2) Steam Line Pressure- High Differential Pressure Between Steam Lines Steam Line Pressure- High Differential Pressure Between Steam Lines provides protection against the following accidents:

SLB; (continued)

Farley Units 1 and 2 B 3.3.2-11 Revision 77

ESFAS Instrumentation B 3.3.2 BASES APPLICABLE 4. Steam Line Isolation SAFETY ANALYSES, LCO, and Isolation of the main steam lines provides protection in the event APPLICABILITY of an SLB inside or outside containment. Rapid isolation of the (continued) steam lines will limit the steam break accident to the blowdown from one SG, at most. For an SLB upstream of the main steam isolation valves (MSIVs), inside or outside of containment, closure of the MSIVs limits the accident to the blowdown from only the affected SG. For an SLB downstream of the MSIVs, closure of the MSIVs terminates the accident as soon as the steam line header depressurizes. Steam Line Isolation mitigates the effects of a feed line break and ensures a source of steam for the turbine driven AFW pump during a feed line break.

a. Steam Line Isolation- Manual Initiation Manual initiation of Steam Line Isolation can be accomplished from the control room. There are six switches in the control room and each switch can initiate action to immediately close the associated MSIV. The LCO requires one channel per steam line to be OPERABLE. Although two MSIVs per steam line are required OPERABLE by LCO 3.7.2, the Manual Initiation funotion for these 't'alves is not oredited in the safety analyses and redundant Manual Initiation per steam line is not required . .

b. Steam Line Isolation -Automatic Actuation Logic and Actuation Relays Automatic Actuation Logic and Actuation Relays consist of the same features and operate in the same manner as described for ESFAS Function 1.b, paragraph 1.

Manual and automatic initiation of steam line isolation must be OPERABLE in MODES 1, 2, and 3 when there is sufficient energy in the RCS and SGs to have an SLB or other accident. This could result in the release of significant quantities of energy and cause a cooldown of the primary system. The Steam Line Isolation Function is required in MODES 2 and 3 unless one MSIV in each Steam Line is closed. In MODES 4, 5, and 6, there is insufficient energy in the RCS and SGs to experience an SLB or other accident releasing significant quantities of energy.

(continued)

Farley Units 1 and 2 B 3.3.2-19 Revision 0

ESFAS Instrumentation B 3.3.2 BASES APPLICABLE SAFETY ANALYSES ,

LCO, and This Function closure of the MSIVs in the event of APPLICABILITY a LOCA or an SLB inside containment to maintain at least (continued) one unfaulted SG as a heat sink for the reactor, and to limit the mass and energy release to containment. The transmitters (d/p cells) are located outside containment with the sensing line (high pressure side of the transmitter) located inside containment. Containment Pressure -

High 2 provides no input to any control functions. Thus, three OPERABLE channels are sufficient to satisfy protective requirements with two-out-of-three logic. The transmitters and electronics are located outside of containment. Thus, they will not experience any adverse environmental conditions, and the Trip Setpoint reflects only steady state instrument uncertainties.

Containment Pressure - High 2 must be OPERABLE in MODES 1, 2, and 3, when there is sufficient energy in the primary and secondary side to pressurize the containment following a pipe break. This would cause a significant increase in the containment pressure, thus allowing detection and closure of the MSIVs. The Steam Line Isolation Function remains OPERABLE in MODES 2 and 3 unless one MSIV in each Steam Line is closed. In MODES 4, 5, and 6, there is not enough energy in the primary and secondary sides to pressurize the containment to the Containment Pressure- High 2 setpoint.

d. Steam Line Isolation- Steam Lin Steam Line Pressure - Low provides closure of the MSIVs in the event of an SLB to maintain at least one unfaulted SG as a heat sink for the actor, and to limit the mass and energy re ease to containment. This Function provides closure of the MSIVs in the event of a feed line break to ensure a supply of steam for the turbine driven AFW pump.

Steam Line Pressure- Low Function must be OPERABLE in MODES 1, 2, and 3 (above P-12), when a secondary (continued)

Farley Units 1 and 2 B 3.3.2-20 Revision 0

ESFAS Instrumentation 8 3.3.2 BASES APPLICABLE d. Steam Line Isolation -Steam Line Pressure- Low SAFETY ANALYSES, (continued)

LCO, and APPLICABILITY side break could result in the rapid depressurization of the steam lines. This signal may be manually blocked by the operator below the P-12 setpoint. Below P-12, an inside containment SLB will be terminated by automatic actuation via Containment Pressure- High 2. Stuck valve transients and outside containment SLBs will be terminated by the Steam Line High flow in Two Steam Lines coincident with Tavg Low- Low signal fef Steam Line Isolation below P-12 when Sl has been man lly blocked. The Steam Line Isolation Function is req ired in MODES 2 and 3 unless one MSIV in each Steam Lin is closed . This Function is not required to be OPERAS E in MODES 4, 5, and 6 because there is insufficient energy in the secondary side of the unit to have an accident with any significant adverse consequences.

e. Steam Line Isolation - High Steam Flow in Two Steam The High Steam Flow in Two Lines Coincident with TSY9.- Low Low Steam Lines Coincident with Tavg - Low Low Function is This function provides closure of the MSIVs during an SLB an additional instrument or inadvertent opening of an SG relief or safety valve, to signal provided by the maintain at least one unfaulted SG as a heat sink for the Westinghouse plant design. reactor and to limit the mass and energy release to As indicated in Reference 6, containment.

the High Steam Flow in Two Steam Lines Coincident with wo steam line flow channels per steam line are required Tavg - Low Low Function is OPERABLE for this Function. The steam line flow channels not used in the safety are combined in a one-out-of-two logic to indicate high analysis and an analytical steam flow in one steam line. Therefore, two channels are limit is not specified for this sufficient to satisfy redundancy requirements. The one-out-trip function . Therefore, this of-two configuration allows on-line testing because trip of ESFAS Function does not one high steam flow channel is not sufficient to cause represent an LSSS as initiation. Steam line isolation on high steam flow in two defined in 10 CFR 50.36(c) steam lines is acceptable in the case of a single steam line (1 )(ii)(A) because this fault due to the fact that the steam flow in the remaining instrumentation does not intact steam lines will increase due to the fault in the other monitor a plant variable on line. The increased steam flow in the remaining intact lines which a safety limit has been will actuate the required high steam flow trip. The Function placed . trips on one-out-of-two high steam flow in any two-out-of-three steam lines if there is a one-out-of-one low low Tavg trip in any two-out-of- three RCS loops. The one channel per (continued)

Farley Units 1 and 2 8 3.3.2-21 Revision 0

ESFAS Instrumentation B 3.3.2 BASES APPLICABLE d. Engineered Safety Feature Actuation System SAFETY ANALYSES , Interlocks- T ~-Low Low. P-12 (continued)

LCO, and APPLICABILITY steam isolation on Steam Line Pressure - Low. On decreasing temperature with two-out-of-three T avg channels below the setpoint, the P-12 interlock pafety function is to provide main steam isolation on hig earn flow in two steam lines coincident with T avg - Low Low. Another P-function on a decreasin tern erature is for the P-1 interlock to prevent an excessive cooldown of the RCS due to a malfunctioning Steam Dump Control System. The Trip Setpoint and Reset reflect steady-state instrument uncertainties.

Since Tavg is used as an indication of bulk RCS temperature, this Function meets redundancy requirements with one OPERABLE channel in each loop. These channels are used in two-out-of-three logic.

n MODES 1, 2, and 3 to automatically reinstate Sl and on St~am Line Pressure- Low when RCS Tavg is above the P-12 setpoint and to afford protection when a secondary side break or stuck open valve could result in the rapid depressurization of the steam lines. This Function is OPERABLE when the interlock is in the required state for the unit condition. This assumed in Function does not have to be OPERABLE in MODE 4, 5, or 6 the safety because there is insufficient energy in the secondary side of analyses, as the unit to have a design basis accident.

indicated in The ESFAS instrumentatio satisfies Criterion 3 of 10 CFR Table 3-32 of 50.36(c)(2)(ii)

ACTIONS A Note has been added in the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed on Table 3.3.2-1.

In the event a channel's Trip Setpoint is found nonconservative with respect to the Allowable Value, or the transmitter, instrument Loop, signal processing electronics, or bistable is found inoperable, then all affected Functions provided by that channel must be declared inoperable and the LCO Condition(s) entered for the protection (continued)

Farley Units 1 and 2 B 3.3.2-31 Revision 36

ESFAS Instrumentation B 3.3.2 BASES ACTIONS L.1 L.21 L.3.1 and L.3.2 (continued)

I I MODE 5 within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. Placing the unit in MODE 5 removes all requirements for OPERABILITY of these interlocks and the automatic actuation logic, Sl actuation relays and interlock actuation relays.

This Condition is intended to address an inoperability of the actuation logic or relays associated with a given train which affects the integrated ESFAS response to a pressurizer low pressure Sl (P-11),

steam line low pressure SI/MSLI (P-12), or any auto Sl (P-4) actuation signal. This Condition is applicable whenever more than one ESF system is affected by the inoperable train of logic or relays. However, if one or more inoperable actuation relay(s) in a train affect only a single ESF system, then the ACTIONS Condition of the LCO applicable to the affected ESF component or system should be entered and this Condition is not applicable.

This action addresses the train orientation of the SSPS and the master and slave relays. If one train is inoperable, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are allowed to restore the train to OPERABLE status. The specified Completion Time is reasonable considering that there is another train OPERABLE, and the low probability of an event occurring during this interval. If the train cannot be restored to OPERABLE status, the unit must be placed in a MODE in which the LCO does not apply. This is done by placing the unit in at least MODE 3 within an additional 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months total time) and in MODE 5 within an additional 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months (60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months total time). The Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

The Required Actions are modified by a Note that allows one train to be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing , provided the other train is OPERABLE. This allowance is based on the reliability analysis assumption that 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is the average time required to perform channel surveillance (Ref. 10).

Farley Units 1 and 2 B 3.3.2-41 Revision 46

Insert B ACTIONS M and N M.1 and M.2 This Condition applies to the High Steam Flow in Two Steam Lines Function (Function 4.e) .

With both channels inoperable in one or more steam lines due to the instrument channel trip setting not within the Allowable Value, one channel per steam line must be restored to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and, when below the P-12 interlock, a verification must be immediately made to ensure at least one Manual Initiation channel per steam line is OPERABLE.

To ensure that the high steam flow channels associated with Function 4.e accurately track with steam line flow following a refueling outage, the measured steam flow scaling data is compared to the predicted steam flow scaling data derived from previous operating cycles. Following the comparison, high steam flow channel adjustment may be required to normalize the channels with the measured steam flow scaling data. Prior to channel normalization, the trip setting of the steam flow transmitters may not be calibrated to within the required as-found tolerance band based on the new measured steam flow scaling data. This could result in the channel trip setting being less conservative than the Allowable Value, thus rendering the associated channel inoperable. This Condition provides time to complete the channel normalization of multiple channels to restore at least one channel in each steam line to OPERABLE status. Restoring the channels to OPERABLE status includes ensuring the channel trip setting is adjusted to within the as-left tolerance band of the Trip Setpoint based on the normalized steam flow scaling data and the channel is not otherwise known to be incapable of performing its function.

With one required Manual Initiation channel in one or more steam lines inoperable concurrent with this Condition, steam line isolation capability may not be available when below the P-12 interlock. Therefore, Required Action M.1 requires a verification to be made immediately to ensure at least one Manual Initiation channel per steam line is OPERABLE. This may be performed as an administrative check, by examining logs or other information, to determine if the minimum required Manual Initiation channels are out of service for testing or other reasons. It does not mean it is necessary to perform the Surveillances needed to demonstrate the OPERABILITY of the Manual Initiation channels. If the OPERABILITY of at least one required Manual Initiation channel in each steam line cannot be verified, however, Condition N must be immediately entered. The Note to Required Action M.1 indicates that this Required Action is only applicable when below the P-12 interlock. When above the P-12 interlock, the Containment Pressure- High 2 and Steam Line Pressure Low Functions provide steam line isolation capability.

The Completion Time to restore one channel per steam line to OPERABLE status is acceptable because steam line isolation protection continues to be provided by the ESFAS instrumentation assumed in the safety analysis; i.e., the Containment Pressure- High 2 and the Steam Line Pressure Low Functions. In addition, this Condition does not represent a loss of a safety function assumed in the accident analysis as described in TS 5.5.15, "Safety Function Determination Program (SFDP)."

. Steam flow transmitter normalization is performed following a refueling outage after reaching 100% RTP and establishing steady state steam line flow. Therefore, this Condition is modified by two Notes. Note 1 indicates the Condition is only applicable during the period of time prior to completing normalization of the steam flow channels. Note 2 limits the applicability of the Condition to 7 days after reaching 1OOo/o RTP following a plant startup from refueling. If both channels are discovered inoperable in one or more steam lines for reasons other than the trip

setting not within the Allowable Value, or both channels in one or more steam lines are discovered inoperable for any reason following steam flow channel normalization or after 7 days of reaching 100°/o RTP from a plant startup after refueling, LCO 3.0.3 is entered, as applicable.

N.1.1. N.1 .2. and N.2 If one required Manual Initiation channel in one or more steam lines is discovered inoperable concurrent with Condition M when below the P-12 interlock or the inoperable high steam flow channels cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a condition in which Function 4.e does not apply. To achieve this status, the unit must be placed at least in MODE 2 or MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and the steam lines isolated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 2 or MODE 3 from full power conditions in an orderly manner and without challenging unit systems. The Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is reasonable to isolate all the steam lines with at least one MSIV closed in each steam line. In MODE 2 or 3 with at least one MSIV closed in each steam line (i.e., steam lines isolated), the High Steam Flow in Two Steam Lines Function (Function 4.e) is no longer required to be OPERABLE.

Joseph M. Farley Nuclear Plant- Unit 1 and 2 Supplement to License Amendment Request for Technical Specification 3.3.2 Regarding Steam Flow Isolation on High Steam Flow and Response to Request for Additional Information Enclosure 5 Response to Request for Additional Information to Support NRC Staff Review of the ESFAS High Steam Flow- Steam Line Isolation LAR

Enclosure 5- SNC Response to NRC Request for Additional Information

1. Summary Description By letter dated December 21, 2017 (Reference 1), Southern Nuclear Operating Company (SNC) requested a license amendment to revise Farley Nuclear Plant (FNP) Units 1 and 2 Technical Specification (TS) 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) lnstrumentation,".to add TS Actions that allow time to restore one high steam flow channel per steam line to Operable status before requiring a unit shutdown in the event two channels in one or more steam lines are discovered inoperable due to the trip setting not within Allowable Value. On February 23, 2018, via electronic mail (Reference 2), the NRC provided a request for supplemental information to support the NRC staff's development of the Federal Register Notice for the FNP ESFAS High Steam Flow Instrumentation License Amendment Request (LAR) and the analysis that shows the LAR involves no significant hazards consideration (NSHC) pursuant to Paragraph (c), Section 50.92 of Title 10 of the Code of Federal Regulations (1 0 CFR). By teleconferences on March 6 and 28, 2018, SNC discussed the request for supplemental information with the NRC staff to confirm an understanding of the information being requested .

On April 13, 2018, via electronic mail (Reference 3), the NRC provided proposed request for additional information (RAI) to support the review of the FNP ESFAS High Steam Flow Instrumentation License Amendment Request (LAR). By teleconference on April 24, 2018, SNC discussed the RAI with the NRC staff to confirm an understanding of the information being requested. By letter dated May 1, 2018 (Reference 4), the NRC provided formal RAI to support the review of the FNP ESFAS High Steam Flow Instrumentation LAR.

The following provides the SNC formal response to the RAI as discussed with the NRC staff.

2. NRC Staff Request for Additional information RAI No.1:

Section 2.2, "Description of the Proposed Change," of Enclosure 1 of the license amendment request (LAR) states, in part:

The proposed amendment would add newts Condition M, which states:

"One or more steam lines with two channels inoperable due to trip setting not within Allowable Value."

Two Notes to proposed Condition M are provided to limit the Condition use to only prior to completion of steam flow channel normalization and no more than a week after a unit startup following refueling.

Note 1 states:

"Only applicable prior to steam flow channel normalization."

E5-1

- SNC Response to NRC Request for Additional Information Note 2 states:

"Only applicable within 7 days after reaching 100% RTP following refueling."

The description of the channel normalization process in the LAR states that steam flow, feed flow, and impulse pressure data sets are needed at five power levels between the 15 percent and 100 percent RTP, before the normalization data is complete enough to be used to provide the information necessary to properly revise the channel calibration procedures and calibrate the main steam line flow channels. It is not clear, however, what time limitations would be placed on the applicability of the proposed new Condition M if during a planned startup, continued ascension to 100 percent RTP were to be delayed at any value less than 100 percent RTP for an extended period, due to unforeseen equipment or operational circumstances occurring during startup. It is also not clear why the allowable Completion Time of 7 days (168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months ) was chosen, since it is described within the LAR that approximately 80 hours9.259259e-4 days 0.0222 hours 1.322751e-4 weeks 3.044e-5 months is needed to perform the normalization process after reaching 100 percent RTP, followed by performance of the individual channel calibrations using the revised normalization data, and 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is allowed to correct potential inoperability concerns once channel calibrations are completed (totaling 128 hours0.00148 days 0.0356 hours 2.116402e-4 weeks 4.8704e-5 months ).

a. Please provide a discussion regarding the maximum possible duration that could occur following the initiation of power ascension after a refueling outage, prior to reaching 100 percent RTP, during which time it would not be confirmed as to whether all six main steam line flow monitoring channels are performing within the revised calibration conditions needed to meet the Technical Specification Allowable Value.

b. Please justify why the proposed Condition M does not contain a maximum time cap for operations of the plant after initial startup and prior to reaching 100 percent RTP without confirmation that the channels are within their required operability conditions.

c. Please provide a technical basis for the selection of the 7-day duration limit, when it appears that 5-1 /2 days is sufficient.

SNC Response:

a. SNC cannot provide the maximum possible duration that could occur following the initiation of power ascension after a refueling outage, prior to reaching 100% RTP, during which time it would not be confirmed as to whether all six main steam line flow monitoring channels are performing within the revised calibration conditions needed to meet the Technical Specification Allowable Value because the need to normalize the channels cannot be determined until the full steam flow scaling data is obtained following reaching 100% RTP and steady state steam flow conditions are established. In addition, normalization of the high steam ES-2

- SNC Response to NRC Request for Additional Information flow channels is not necessarily required following each refueling outage because it is dependent on the results of the steam flow scaling data obtained during the plant startup.

b. Currently, there are no TS restrictions or requirements specifying a maximum time cap prior to reaching 100% RTP to obtain the steam flow scaling data and confirm that the channels are within their required operability conditions. As described in Enclosure 1, Section 3.3, of the ESFAS High Steam Flow Instrumentation LAR (Reference 1), the data collected at 100% RTP result in a higher instrument accuracy. Therefore, to determine if channel normalization is necessary, the full power scaling data must be obtained. Current TS 3.3.2, Required Action 0.1 provides 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to normalize one high steam flow channel before a channel trip is required. This required action completion time begins from the point it is discovered that normalization is necessary as a result of any revised steam flow inputs from scaling data obtained during the plant startup.

However, there is currently no time constraint specified in TS on when this determination must be made. Proposed TS 3.3.2, Action M allows 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to normalize multiple high steam flow channels from the point it is discovered that normalization is necessary as a result of any revised steam flow inputs from scaling data obtained during the plant startup and provides limitations on the use of this Action; i.e., Notes 1 and 2.

Consistent with TS surveillance requirement (SR) 3.0.1 and SR 3.0.4, and as further described in the bases of SR 3.0.1, the high steam flow channels are considered Operable during the reactor startup because testing is performed to the extent possible prior to entering Mode 2 or 3 with one or more steam lines not isolated. Necessary unit parameters are then established to confirm the channels are Operable. The limitation afforded by Note 2 of proposed Condition M is more restrictive than current TS requirements, which have no time cap to confirm the channels are within their required operability conditions.

c. As explained in Enclosure 1, Section 3.3, of the ESFAS High Steam Flow Instrumentation LAR, operational experience has shown that the channel normalization process takes up to 80 hours9.259259e-4 days 0.0222 hours 1.322751e-4 weeks 3.044e-5 months after reaching 100% RTP and steady state steam flow conditions are established [emphasis added].

The 7-day duration limit provided in Note 2 to proposed TS 3.3.2 Condition M begins upon reaching 1OOo/o RTP following a plant startup from refueling and accounts for the time needed to establish steady state steam flow conditions, which is dependent on several factors (e.g.,

matched steam generator steam flow and feedwater flow and steady state reactor power conditions), and determining, based on evaluation of the obtained steam flow scaling data, if channel normalization is needed. The 7-day limit from reaching 100% RTP was chosen because it is the next logical time after 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months used in TS and is consistent with similar times to normalize instrument channels; for example: Note 1 to SR 3.3.1.3 and Note 2 to SR 3.3.1.9. Other similar uses of a 7-day duration in TS include the Note to SR 3.4.1.4 and Note 2 toTS 3.6.2 Action A. In addition, the technical basis for the selection of the 7-day duration limit considers that the High Steam Flow in Two Steam Lines Coincident with Tavg- Low ES-3

- SNC Response to NRC Request for Additional Information Low ESFAS function is not credited to isolate the steam lines in any accident or transient specified in Finals Safety Analysis Report (FSAR)

Chapter 15, including the full spectra of steam line breaks (SLBs) inside and outside containment. Therefore, providing sufficient time to determine if channel normalization is needed and performing channel calibrations as required offsets initiating an unnecessary plant transient.

RAI No.2:

Section 3.5, "Acceptability of the Proposed Change," of Enclosure 1 of the LAR states, in part:

This proposed amendment is acceptable because the ESFAS Containment Pressure-High 2, Steam Line Pressure Low, and Manual Initiation Functions continue to provide steam line isolation protection during an SLB [Steam Line Break]

accident, which also bounds minor secondary system pipe breaks and the accidental opening of a secondary system steam dump, relief, or safety valve.

The LAR does not appear to discuss why the proposed change is acceptable if one or more Steam Pressure Low instrument channel(s) become(s) inoperable. Please provide a discussion on why the proposed change to TS 3.3.2 is acceptable if one or more Steam Line Pressure Low instrument channels become(s) inoperable.

Additionally, the proposed Condition M appears to allow for all high steam flow channels to be out of service concurrently for 7 days. Please justify why an additional constraint is not needed within Condition M such that the Condition would be limited to only when at least two channels of the Steam Line Pressure Low function are operable.

SNC Response:

With one Steam Line Pressure Low instrument channel inoperable, steam line isolation on a low steam line pressure signal can still occur because the Steam Line Pressure Low instrument channels are arranged in a two-out-of-three logic configuration. Therefore, the proposed change toTS 3.3.2 concurrent with one Steam Line Pressure Low instrument channel inoperable is acceptable. Currently, TS 3.3.2 Actions allow continued operation with multiple ESFAS channels inoperable and do not require additional restriction when channels of other ESFAS functions are inoperable, provided the number of channels in a trip function can continue to perform the safety function. For example, with one channel of the Steam Line Pressure Low function inoperable concurrent with one channel of the Containment Pressure

- High 2 function and one channel per steam line of High Steam Flow in Two Steam Lines function inoperable, TS 3.3.2, Required Action 0.1 allows continued operation for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months before action is required. There currently is no further TS restriction when one channel of the Steam Line Pressure Low is inoperable concurrent with one inoperable Containment Pressure- High 2 E5-4

- SNC Response to NRC Request for Additional Information channel and one High Steam Flow in Two Steam Lines channel inoperable per steam line; i.e., separate condition entry is allowed for each function per the Note to the TS 3.3.2 Actions. Additionally, with both manual initiation channels in one steam line inoperable concurrent with one inoperable channel of both the Steam Line Pressure Low and Containment Pressure -

High 2 functions, TS 3.3.2, Required Action F.1 allows continued operation for 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months before action is required. No additional TS action restraint currently requires a channel of the Steam Line Pressure Low function on each steam line to be verified Operable in these conditions.

Additionally, action to verify sufficient channels of Steam Line Pressure Low and Containment Pressure - High 2 functions are Operable is not necessary because LCO 3.0.3 is currently entered when the number of Operable channels are insufficient to provide steam line isolation capability irrespective of the status of the high steam flow channels. When the number of inoperable channels associated with an ESFAS function results in a loss of the associated trip function, the unit may be outside the safety analysis.

Therefore, action is currently required in accordance with LCO 3.0.3 when the number of inoperable channels is not addressed by the associated TS condition or combination of conditions.

Also, proposed Condition M does not allow for all high steam flow channels to be out of service concurrently for 7 days. TS SR 3.0.1 and SR 3.0.4 require the SRs associated with the high steam flow channels to be met prior to entering the specified condition of the applicability of LCO 3.3.2 (i.e., Mode 2 or 3 with one or more steam lines not isolated for high steam flow channels) except as provided by LCO 3.0.4. Therefore, the proposed license amendment does not allow a plant startup and operation for 7 days with high steam flow instrumentation inoperable, other than as allowed by LCO 3.0.4.b requirements. LCO 3.0.4.a and c would not apply to proposed Condition M because the actions are limited and an LCO 3.0.4.c noted allowance is not provided. LCO 3.0.4.b would allow entry into the specified condition of the applicability with all high steam flow channels inoperable only if the inoperability was due to trip setting not within Allowable Value, a risk assessment was performed, and the risk managed. In this case, the time would be limited to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , not 7 days, and, pursuant the requirements of 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants," as described in the bases of LCO 3.0.4.b, the risk assessment would require consideration of the synergistic effects associated with two inoperable high steam flow channels in one or more steam lines concurrent with one or more low steam line pressure channels inoperable and provide favorable results. For the reasons described herein, an additional constraint within Condition M is not needed to limit the condition to only when at least two channels of the Steam Line Pressure Low function are operable.

E5-5

- SNC Response to NRC Request for Additional Information RAI No.3:

Section 3.5 of the LAR states, in part:

With both high steam flow channels inoperable in one or more steam lines due to the instrument channel trip setting not within the Allowable Value, the steam line isolation capability on high steam line flow may not occur within the time expected during a design basis event.

Given this statement, main steam isolation valve (MSIV) closure for either a stuck open safety/relief valve transient or a steam line break outside of containment would rely on either the low steam line pressure trip function or manual operator action. Given that these two trips would be expected to occur at different times than a high steam line flow trip (and much later in the case of manual operator action), please discuss how the Final Safety Analysis Report, Chapter 15 safety analyses acceptance criteria will be met if the high steam flow trip does not occur within the time expected, or does not occur at all, during a design basis event.

SNC Response:

Although the High Steam Flow in Two Steam Lines Coincident with Tavg-Low Low ESFAS function does provide protection against a steam pipe rupture, the instrument function is not credited to isolate the steam lines in any accident or transient specified in FSAR Chapter 15, including the full spectra of SLBs inside and outside containment. WCAP-14722 (Ref. 5) and WCAP-15098 (Ref. 6) provide a summary of the steam line rupture non-loss of coolant accident (LOCA) analysis and mass and energy (M&E) release analysis for power uprate of FNP Units 1 and 2 and replacement of the FNP Unit 1 and 2 steam generators, respectively. These analyses include the protective functions credited to isolate the steam lines for various spectra of SLBs and do not include the High Steam Flow in Two Steam Lines Coincident with Tavg -Low Low ESFAS function.

The time sequence of the non-LOCA main steam line break shows a steam line isolation on the Steam Line Pressure Low function in two of three steam lines. The cases for an SLB accident inside and outside containment assume the Steam Line Pressure Low function in two of three steam lines initiates a steam line isolation. Additionally, the main steam line break inside containment analysis also assumes the Containment Pressure- High 2 function initiates a steam line isolation as indicated in FSAR Table 6.2-11.

For smaller break size spectra of an SLB, ESFAS manual initiation signals are assumed to initiate a steam line isolation. A timing of 1800 seconds (i.e.,

30 minutes) is assumed for SLB analysis cases that assume manual initiation channel actuation. Therefore, the FSAR Chapter 15 safety analyses acceptance criteria will not be affected by the proposed license amendment and will continue to be met if the high steam flow trip does not occur within the time expected, or does not occur at all, during a design basis event. It should be noted that revised Enclosure 1 included in this supplement to the ESFAS High Steam Flow Instrumentation LAR supplants the original LAR E5-6

- SNC Response to NRC Request for Additional Information Enclosure 1 and the Section 3.5 statement quoted in RAI No. 3 herein has been deleted.

RAI No.4:

The Technical Specifications Bases section for "Steam Line Isolation-Steam Line Pressure - Low" states, in part:

This signal may be manually blocked by the operator below the P-12 setpoint. Below P-12, an inside containment SLB will be terminated by automatic actuation via Containment Pressure

-High 2. Stuck valve transients and outside containment SLBs will be terminated by the Steam Line High flow in Two Steam Lines coincident with Tavg Low- Low signal for Steam Line Isolation below P-12 when Sl [safety injection] has been manually blocked.

Please discuss how stuck valve transients and outside containment steam line breaks below P-12 will be terminated if the steam line high flow instrumentation channels are inoperable, and the steam line pressure-low signal is manually blocked.

SNC Response:

Stuck valve transients and outside containment steam line breaks below P-12 will be terminated by the ESFAS Manual Initiation channels when one or more steam line high flow instrumentation channels are inoperable, and when the steam line pressure-low signal is manually blocked. It should be noted that revised Enclosures 1, 2, 3, and 4 included in this supplement to the ESFAS High Steam Flow Instrumentation LAR supplants the original LAR enclosures. To ensure manual initiation capability is available to isolate the steam lines if the steam line high flow instrumentation is not available, revised Enclosures 1 and 2 propose an action to immediately verify that one manual initiation channel per steam line is Operable when below the ESFAS P-12 interlock. The verification may be performed as an administrative check, by examining logs or other information, to determine if the minimum required Manual Initiation channels are out of service for testing or other reasons. It does not mean it is necessary to perform the surveillances needed to demonstrate the Operability of the Manual Initiation channels. If the Operability of at least one required Manual Initiation channel in each steam line cannot be verified, proposed Condition N must be immediately entered.

Revised Enclosures 3 and 4 incorporate changes associated with the new proposed required action (Required Action M.1) and include the addition of Action N. Additional clarifications are added to the TS 3.3.2 Bases as shown ES-7

- SNC Response to NRC Request for Additional Information in revised Enclosure 4, including a revision to the TS Bases quoted in RAI No.

4 herein.

No Significant Hazards Consideration RAI:

A significant hazards consideration is present when the three standards in 10 CFR 50.92 are not met in a request for a license amendment. Standard one in 10 CFR 50.92 asks whether the amendment involves a significant increase in the probably or consequences of an accident previously evaluated and standard three asks of the proposed change involves a significant reduction in a margin of safety.

The Farley updated final safety analysis report (UFSAR), Section 15.4.2.1.1 states, in part, that the MSIVs trip after receiving a main steam line isolation signal on:

1. High steam flow in two out of three main steam lines (one of two per line) in coincidence with two out of three low-low RCS average temperature signals. (i.e., the high steam flow isolation signal)

2. Low steam line pressure signal in any two out of three steam lines.

3. Two out of three high-high (hi-2) containment pressure signals In the submittal, the answers to 10 CFR 50.92 standards one and three discuss the available isolation signals (i.e., low steam line pressure, high-high containment pressure, and manual action). However, it is not apparent that certain aspects of the consequences of the loss of function of the high steam flow isolation signal are considered sufficiently for a determination of no significant hazards. Please provide an analysis of the coincidence and timing of the diverse main steam line isolation signals and their impact on the UFSAR Chapter 15 accident analyses assumptions and results, plant equipment response, and the impact on the ability to mitigate consequences and maintain adequate safety margin.

Please provide additional justification for the reliance on manual actions in lieu of automatic actions and discuss how a potential for loss-of-safety function does not result in a significant increase in the consequences of an accident or a significant reduction in a margin of safety.

SNC Response:

The High Steam Flow in Two Steam Lines Coincident with Tavg- Low Low ESFAS function is not credited to isolate the steam lines in any accident or transient specified in FSAR Chapter 15, including the full spectra of SLBs inside and outside containment. WCAP-14722 (Ref. 5) and WCAP-15098 (Ref. 6) provide a summary of the steam line rupture non-LOCA and M&E release analyses for power uprate*of FNP Units 1 and 2 and replacement of the FNP Unit 1 and 2 steam generators, respectively. These analyses E5-8

- SNC Response to NRC Request for Additional Information include the protective functions credited to isolate the steam lines for various spectra of SLBs and include the coincidence and timing of the diverse main steam line isolation signals assumed in the FNP FSAR Chapter 15 accident analyses, assumptions, and results, plant equipment response, and the impact on the ability to mitigate consequences. The time sequence of the steam line rupture non-LOCA analysis shows a steam line isolation on the low steam line pressure signal. The cases for an SLB accident inside and outside containment assume the Steam Line Pressure Low function in two of three steam lines initiates a steam line isolation. Additionally, the main steam line break inside containment analysis also assumes the Containment Pressure -

High 2 function initiates a steam line isolation as indicated in FSAR Table 6.2-11. For smaller break size spectra of an SLB, ESFAS manual initiation signals are assumed to initiate a steam line isolation with a timing assumption of 1800 seconds (i.e., 30 minutes).

In addition, safety analysis limits (SALs) are established for reactor trip system and ESFAS instrumentation functions related to those variables having significant safety functions. WCAP-13751 (Ref. 7) defines a SAL as the limiting parameter value in the safety and transient analysis at which a reactor trip or ESFAS function is assumed to be initiated . This setpoint report verifies adequate safety margin for limiting safety system settings (LSSSs) to confirm that the SALs will be protected by automatic trip setpoints and therefore protect the safety limits as required by 10 CFR 50.36. At FNP, containment pressure and steam line pressure provide the limiting parameter values assumed in the safety analyses for SLB accidents. As indicated in WCAP-13751, the High Steam Flow in Two Steam Lines function is not used in the safety analysis and a SAL is not specified for this trip function.

Therefore, the ESFAS High Steam Flow in Two Steam Lines function does not represent an LSSS as defined in 10 CFR 50.36(c)(1)(ii)(A) because this instrumentation does not monitor a plant variable on which a safety limit has been placed .

For these reasons, the condition of multiple inoperable channels of the High Steam Flow in Two Steam Lines Coincident with Tavg- Low Low function due to steam flow channel inaccuracies does not represent a loss of a safety function assumed in the accident analysis and the ESFAS instrumentation credited in the safety analysis to isolate the steam lines during a design basis accident is not altered by the proposed change. The proposed change does not propose reliance on manual action in lieu of any automatic action assumed in the safety analyses and does not increase the consequences of an accident previously evaluated or reduce the margin of safety.

It should be noted that revised Enclosure 1 included in this supplement to the ESFAS High Steam Flow Instrumentation LAR supplants the original LAR Enclosure 1. Responses to 10 CFR 50.92 standards one and three in Enclosure 1, Section 4.2 are revised to clarify how the consequences of previously evaluated accidents are not increased and the margin of safety is not reduced.

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Enclosure 5- SNC Response to NRC Request for Additional Information

3.

References:

1. Letter from J.J Hutto (SNC) to Document Control Desk (NRC) dated December 21, 2017, "License Amendment Request for Technical Specification 3.3.2 Regarding Steam Flow Isolation on High Steam Flow" (NRC ADAMS Accession No. ML17355A516).

2. Email from S. Williams (NRC) to K. Lowery (SNC) dated February 23, 2018, 12:02 PM, "

Subject:

RE: RE: December 21 , 17, Farley TS 3.3.2 application."

3. Email from M. Orenak (NRC) to N. Jackson and K. Lowery (SNC) dated April13, 2018, 12:47 PM, "

Subject:

Additional RAis for Farley TS 3.3.2."

4. Letter from S. A. Williams (NRC) to C. A. Gayheart (SNC) dated May 1, 2018, "Joseph M. Farley Nuclear Plant, Units 1 and 2- Request for Additional Information RE: TS 3.3.2, 'Engineered Safety Feature Actuation System (ESFAS) Instrumentation' (EPID L-2017-LLA-0428)" (NRC ADAMS Accession No. ML18087A146).

5. Westinghouse Topical Report WCAP-14722, "Farley Nuclear Plant Units 1 and 2 Power Uprate Project NSSS Engineering Report," November 1997.

6. Westinghouse Topical Report WCAP-15098, "Farley Nuclear Plant Units 1 and 2 Replacement Steam Generator Program NSSS Licensing Report,"

November 1998.

7. Westinghouse Topical Report WCAP-13751, "Westinghouse Setpoint Methodology for Protection Systems Farley Nuclear Plant Units 1 and 2 (Model 54F Steam Generators and 2785 MWt NSSS Power)," Rev. 1, October 2002. (Proprietary)

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v t e Letter Sequence Supplement
EPID:L-2017-LLA-0428, Plant Shutdown Required by Technical Specifications due to Inoperable Steam Flow Transmitters, LER 16-007-01 for Joseph M. Farley, Unit 1, Regarding Plant Shutdown Required by Technical Specifications due to Inoperable Steam Flow Transmitters (Approved, Closed)
Initiation Request, Request Acceptance Supplement Administration Questions 1 May 2018 Answers Results Approval Other:
MONTHYEAR2018-01-18 [Table View]

NL-18-0733, Supplement to License Amendment Request for Technical Specification 3.3.2 Regarding Steam Flow Isolation on High Steam Flow and Response to Request for Additional Information

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NL-18-0733, Supplement to License Amendment Request for Technical Specification 3.3.2 Regarding Steam Flow Isolation on High Steam Flow and Response to Request for Additional Information

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