NL-24-0088, Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency
| ML24096B775 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 04/05/2024 |
| From: | Coleman J Southern Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| NL-24-0088 | |
| Download: ML24096B775 (1) | |
Text
Regulatory Affairs 3535 Colonnade Parkway Birmingham, AL 35243 205 992 5000
$SULO , 2024 Docket Nos.: 50-348 NL-24-0088 50-364 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant - Units 1 & 2 Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency Ladies and Gentlemen:
Pursuant to 10 CFR 50.90, Southern Nuclear Operating Company (SNC) requests a license amendment to the Joseph M. Farley Nuclear Plant (FNP) Units 1 and 2 Renewed Facility Operating Licenses NPF-2 and NPF-8 respectively. The proposed amendment revises the surveillance Frequency for containment spray nozzle testing specified by Surveillance Requirement (SR) 3.6.6.8. Specifically, the proposed change would replace the current testing frequency, as specified by the Surveillance Frequency Control Program, with an event-based frequency to verify the spray nozzles are unobstructed following activities that could cause nozzle blockage.
The enclosure provides a basis for the proposed change. Attachment 1 contains marked-up Technical Specification (TS) pages. Attachment 2 contains revised (clean) TS pages. provides the marked-up TS Bases pages for information only.
SNC requests approval of the proposed amendment within 12 months of completion of the NRCs acceptance review. Once approved, the amendment shall be implemented within 60 days.
In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Alabama State Official.
U. S. Nuclear Regulatory Commission NL-24-0088 Page 2 This letter contains no NRC commitments. If you have any questions, please contact Ryan Joyce at 205.992.6468.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the WK day of $SULO 2024.
Respectfully submitted, Jamie M. Coleman Director, Regulatory Affairs Southern Nuclear Operating Company JMC/was/cgb
Enclosure:
Basis for Proposed Changes Attachments: 1. Proposed Technical Specification Changes (Marked-up Pages)
- 2. Revised Technical Specification Pages
- 3. Proposed Technical Specification Bases Pages (Marked-up) - For Information Only cc:
Regional Administrator, Region ll NRR Project Manager - Farley 1 & 2 Senior Resident Inspector - Farley 1 & 2 Director, Alabama Office of Radiation Control RType: CFA04.054
Joseph M. Farley Nuclear Plant - Units 1 & 2 Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency Enclosure Basis for Proposed Changes
Enclosure to NL-24-0088 Basis for Proposed Changes E-1 1.0
SUMMARY
DESCRIPTION In accordance with 10 CFR 50.90, Application for amendment of license, construction permit or early site permit, Southern Nuclear Operating Company (SNC) requests a license amendment to the Joseph M. Farley Nuclear Plant (FNP) Units 1 and 2 Renewed Facility Operating Licenses NPF-2 and NPF-8 respectively. The proposed amendment revises the surveillance Frequency for containment spray nozzle testing specified by Surveillance Requirement (SR) 3.6.6.8. Specifically, the proposed change would replace the current testing frequency, as specified by the Surveillance Frequency Control Program (SFCP), with an event-based frequency to verify the spray nozzles are unobstructed following activities that could cause nozzle blockage.
2.0 DETAILED DESCRIPTION 2.1 System Design and Operation The Containment Spray and Containment Cooling systems provide containment atmosphere cooling to limit post-accident pressure and temperature in containment to less than the design values. Reduction of containment pressure and the iodine removal capability of the spray reduces the release of fission product radioactivity from containment to the environment, in the event of a Design Basis Accident (DBA), to within limits. The Containment Spray and Containment Cooling systems are designed to meet the requirements of 10 CFR 50, Appendix A, General Design Criteria (GDC) 38, "Containment Heat Removal," GDC 39, "Inspection of Containment Heat Removal Systems," GDC 40, "Testing of Containment Heat Removal Systems," GDC 41, "Containment Atmosphere Cleanup," GDC 42, "Inspection of Containment Atmosphere Cleanup Systems," and GDC 43, "Testing of Containment Atmosphere Cleanup Systems".
The Containment Spray System (CSS) consists of two separate trains of equal capacity, each capable of meeting the design bases. Each train includes a containment spray pump, spray headers, nozzles, valves, and piping. The CSS provides a spray of cold borated water into the upper regions of containment to reduce the containment pressure and temperature and to reduce fission products from the containment atmosphere during a DBA. Each train of the CSS provides adequate spray coverage to meet the system design requirements for containment heat removal.
2.2 Current Technical Specification Requirements SR 3.6.6.8 states, Verify each spray nozzle is unobstructed. The Frequency of SR 3.6.6.8 currently states, In accordance with the Surveillance Frequency Control Program. The Technical Specification (TS) Bases for SR 3.6.6.8 provide detail regarding the required spray nozzle testing.
2.3 Reason for Proposed Change The proposed change will eliminate unnecessary testing of the spray nozzles. The design of the CSS and cleanliness controls utilized during maintenance activities ensure that line or nozzle blockage is unlikely. Performance of SR 3.6.6.8 at the current frequency has the potential to result in unwarranted occupational radiation exposure and increased outage costs without a commensurate increase in system reliability or performance. Testing would be performed based on activities or conditions that could potentially cause nozzle blockage.
Enclosure to NL-24-0088 Basis for Proposed Changes E-2 2.4 Description of the Proposed Change The Frequency of SR 3.6.6.8 is revised to state, Following activities that could result in nozzle blockage.
A mark-up of the proposed change to SR 3.6.6.8 is provided in Attachment 1. Attachment 2 provides the clean retyped SR 3.6.6.8. Attachment 3 provides a mark-up of the TS SR 3.6.6.8 Bases for information only.
3.0 TECHNICAL EVALUATION
3.1 Technical Analysis The proposed amendment will modify FNP TS SR 3.6.6.8 to eliminate the SFCP Frequency for verifying the containment spray nozzles are unobstructed. Currently, the surveillance requires the spray nozzles be tested in accordance with the SFCP. SNC proposes to replace the current SR Frequency with a statement that would require verification that each spray nozzle is unobstructed following "activities that could cause nozzle blockage." Since maintenance directly or indirectly involving the CSS nozzles is infrequent, the proposed surveillance will ensure the spray nozzles remain unobstructed following activities that could potentially cause nozzle blockage by requiring testing. The testing methods are described in the TS Bases.
3.1.1. Performance History Periodic in-place air flow tests through the CSS spray nozzles have been conducted in accordance with the interval specified in the TS. Spray nozzles were verified unobstructed by delivering airflow to the nozzles, through the headers, via test lines. Either balloons or streamers are deployed at the nozzle openings or hot air with an infrared camera is used to verify that sufficient airflow is established to the nozzles.
SNC has performed the following tests in accordance with TS SR 4.6.2.1.d (currently SR 3.6.6.8) which had an initial Frequency of 5 years. The results of these tests demonstrated unobstructed flow through the CSS nozzles.
Unit 1 Unit 2 1/12/1982 1/21/1985 11/2/1986 10/29/1990 4/18/1991 3/30/1995 By letter dated March 20, 1995 (Reference 1), the NRC issued a license amendment to extend the surveillance Frequency of the containment spray nozzle test in TS SR 4.6.2.1.d (currently SR 3.6.6.8) from 5 to 10 years, to align with the guidance in NUREG-1366 and Generic Letter 93-05. One additional periodic CSS nozzle flow test has been conducted at each FNP Unit since the implementation of this amendment. On 10/16/2001 (Unit 1) and 3/30/2004 (Unit 2), air flow tests of the containment spray headers were performed to verify that the spray nozzles were unobstructed. The results of these tests demonstrated unobstructed flow through each nozzle.
Enclosure to NL-24-0088 Basis for Proposed Changes E-3 Then by letter dated July 18, 2011 (Reference 2) the NRC issued a License Amendment to move certain SR Frequencies to a SFCP. The Frequency for SR 3.6.6.8 (previously SR 4.6.2.1.d) was moved to the SFCP.
3.1.2. Nozzle Blockage Mechanisms The NRC staff previously performed a comprehensive examination of all TS SRs to identify those that should be improved, as documented in NUREG-1366 (Reference 3). This evaluation considered the purpose of the SR and the effect that the performance of the SR has on personnel and on plant equipment. As it relates to the CSS, the report identified that the only reported problems regarding nozzle blockage were related to construction activities. In general, once the system is tested after construction, it is not subject to blockage. Three cases were identified, and all three cases involved a construction error. This report was published in December of 1992. A search of Licensee Event Reports (LERs submitted after December 1992 identified two relevant LERs (References 4 and 5), both from the same unit. Both LERs describe spray nozzle obstructions caused by boric acid solution which was not removed from system low points that entrapped water in the spray headers after the headers were filled with borated water during previous spray header overfill events. The entrapped borated water subsequently evaporated, causing boric acid to precipitate and form obstructions in the nozzles. The number of blocked nozzles was low.
There have been no occurrences of inadvertent flow through the spray nozzles subsequent to the performance of the last nozzle flow test on each FNP Unit. The CSS spray headers are isolated from system flow during normal operation and pump testing, therefore minimizing the potential for boric acid accumulation. In the event of inadvertent fluid flow through the nozzles, such as the result of spurious actuation, SNC would evaluate testing to determine if the nozzles have remained unobstructed.
3.1.3. Foreign Material Exclusion (FME)
The FME program at FNP is governed by a nuclear fleet procedure. The FME fleet procedure specifies appropriate precautions to minimize inadvertent and uncontrolled introduction of foreign materials into plant systems and components. The FME procedure requires that personnel perform and document an "as found" inspection when a system, component, or process is opened or breached. The procedure also includes FME practices for maintaining cleanliness of plant systems and components during maintenance activities. Final cleanliness inspections verify the system, component, or process is free of foreign material prior to final closure. The SNC corrective action program is used in the event of a loss of FME integrity. If FME integrity is lost through the intrusion or discovery of foreign material, the FME procedure directs the worker to stop work, notify the First Line Supervisor, and develop a recovery plan for the foreign material. If the retrieval of the foreign material is unsuccessful, an evaluation is required to determine further necessary actions. The fleet FME procedure provides controls that minimize the potential for introducing foreign material into systems during maintenance activities, and these controls would be in place if the CSS is opened for maintenance.
Therefore, the FME program provides reasonable assurance that foreign material that could adversely affect the CSS's ability to perform its safety function would not be left in the system as a result of maintenance activities.
Enclosure to NL-24-0088 Basis for Proposed Changes E-4 During maintenance activities on the CSS since the last spray nozzle test, work practices and post work inspections have maintained system cleanliness in accordance with the FME procedure. A review of the maintenance history of the spray nozzles determined that there has been no maintenance performed on the containment spray nozzles or headers since 2012.
3.2 Conclusions NUREG-1366 (Reference 3) found that cases of spray nozzle obstruction in pressurized water reactor containment spray systems were related to construction activities. Previously performed surveillance tests at FNP found that the spray nozzles were unobstructed. Therefore, the proposed change, along with existing programs, processes, and procedures at FNP will ensure the containment spray nozzles remain unobstructed, and that appropriate tests will be performed should activities or conditions occur which could potentially cause spray nozzle obstruction. The design of the containment spray system, its maintenance and testing history, FME program controls, and the proposed change to adopt an event-based testing approach specified in TS SR 3.6.6.8 for verifying no nozzle blockage provides reasonable assurance that the containment spray system nozzles will remain unobstructed.
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met.
10 CFR 50 Appendix A, GDC 38, 39, 40, 41, 42 and 43 GDC 38, Containment Heat Removal, states, in part, that a system to remove heat from the reactor containment shall be provided and that the system safety function shall be to reduce rapidly the containment pressure and temperature following any LOCA and maintain them at acceptably low levels.
GDC 39, Inspection of Containment Heat Removal System, states, in part, that the containment heat removal system shall be designed to permit appropriate periodic inspection of important components, such as the sumps, spray nozzles, and piping to assure the integrity and capability of the system.
GDC 40, Testing of Containment Heat Removal System, states, in part, that the containment heat removal system shall be designed to permit appropriate periodic pressure and functional testing to assure (1) the structural and leaktight integrity of its components, (2) the operability and performance of the active components of the system, and (3) the operability of the system as a whole, and under conditions as close to the design as practical the performance of the full operational sequence that brings the system into operation.
GDC 41, Containment Atmosphere Cleanup, states, in part, that systems to control fission products which may be released into the reactor containment shall be provided as necessary to reduce the concentration and quality of fission products released to the environment following postulated accidents.
Enclosure to NL-24-0088 Basis for Proposed Changes E-5 GDC 42, Inspection of Containment Atmosphere Cleanup Systems, states, in part, that the containment atmosphere cleanup systems shall be designed to permit appropriate periodic inspection of important components, such as filter frames, ducts, and piping to assure the integrity and capability of the systems.
GDC 43, Testing of Containment Atmosphere Cleanup Systems, states, in part, that the containment atmosphere cleanup systems shall be designed to permit appropriate periodic pressure and functional testing to assure (1) the structural and leaktight integrity of its components, (2) the operability and performance of the active components of the systems such as fans, filters, dampers, pumps, and valves and (3) the operability of the systems as a whole and, under conditions as close to design as practical, the performance of the full operational sequence that brings the systems into operation.
The proposed change has no effect on the design of the containment heat removal system. The applicable GDC do not specify the frequency or method of inspection. The changes proposed in this request will continue to meet the above regulatory requirements.
10 CFR 50.36 The NRC's regulatory requirements related to the content of the TS are set forth in 10 CFR 50.36, "Technical specifications." Per 10 CFR 50.36(c)(3), surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.
The regulatory requirements in 10 CFR 50.36 are not specific regarding surveillance requirements other than to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. The proposed change is consistent with the requirements of 10 CFR 50.36(c)(3).
4.2 Precedent The following stations requested a change from a time-based surveillance to an event-based surveillance for the containment spray system nozzles. These stations also relocated their surveillance methods to the TS Bases. FNP TS Bases already contain a discussion of the surveillance methods for this test. Therefore, this portion of the precedents does not apply to this request.
x V. C. Summer LAR (Reference 6) and NRC approval (Reference 7) x Shearon Harris LAR (Reference 8) and NRC approval (Reference 9) 4.3 No Significant Hazards Consideration Analysis Southern Nuclear Operating Company (SNC) requests a license amendment to the Joseph M.
Farley Nuclear Plant (FNP) Units 1 and 2 Renewed Facility Operating Licenses NPF-2 and NPF-8 respectively. The proposed amendment revises the Surveillance Frequency for containment spray nozzle testing specified by Surveillance Requirement (SR) 3.6.6.8.
Specifically, the proposed change would replace the current testing frequency, as specified by
Enclosure to NL-24-0088 Basis for Proposed Changes E-6 the Surveillance Frequency Control Program, with an event-based frequency to verify the spray nozzles are unobstructed following activities that could cause nozzle blockage.
SNC has evaluated if a significant hazards consideration is involved with the proposed amendment(s) 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 modifies the frequency for performance of a surveillance test which does not impact any failure modes that could lead to an accident. The proposed frequency change does not affect the ability of the spray nozzles or spray system to perform their accident mitigation function as assumed and therefore there is no effect on the consequence of any accident. Verification of no blockage continues to be required, but now verification will be performed following activities that could result in nozzle blockage.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The containment spray system is not being physically modified and there is no impact on the capability of the system to perform accident mitigation functions. No system setpoints are being modified and no changes are being made to the method in which borated water is delivered to the spray nozzles. The testing requirements imposed by this proposed change to check for nozzle blockage following activities that could cause nozzle blockage do not introduce new failure modes for the system.
The proposed amendment does not introduce accident initiators or malfunctions that would cause a new or different kind of accident.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No The proposed amendment does not change or introduce any new setpoints at which mitigating functions are initiated. No changes to the design parameters of the spray systems are being proposed. There are no changes in system operation being proposed by this change that would impact an established safety margin. The proposed change modifies the frequency for verification of nozzle operability in such
Enclosure to NL-24-0088 Basis for Proposed Changes E-7 a way that continued high confidence exists that the spray system will continue to function as designed.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, SNC concludes that the proposed change presents no 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.
4.4 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
5.0 ENVIRONMENTAL CONSIDERATION
A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.
Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
6.0 REFERENCES
- 1. Letter from NRC to SNC, Issuance of Amendment No. 113 to Facility Operating License No. NPF-2 and Amendment No. 104 to Facility Operating License No. NPF-8 Regarding Line Item Improvements to Reduce Surveillance Requirements in Accordance With Generic Lettrer 93-05, dated March 20, 1995 (ADAMS Accession No. ML013120599)
- 2. Letter from NRC to SNC, Issuance of Amendments Regarding Relocation of Specific Surveillance Frequency Requirements, dated July 18, 2011 (ADAMS Accession No. ML11167A226)
- 3. NUREG-1366, Improvements to Technical Specifications Surveillance Requirements, dated December 1992
- 4. LER 2007-01-000, Palo Verde Nuclear Generating Station Unit 3, Condition Prohibited by Technical Specification Resulting from Containment Spray Nozzle Blockage, dated April 7, 2008
Enclosure to NL-24-0088 Basis for Proposed Changes E-8
- 5. LER 2010-002-001, Palo Verde Nuclear Generating Station Unit 3, Condition Prohibited by Technical Specification Resulting from Containment Spray Nozzle Blockage, dated June 27, 2012
- 6. Letter from Dominion Energy South Carolina (Virgil C. Summer Nuclear Station) to the Nuclear Regulatory Commission, License Amendment request - Technical Specifications Nozzle Blockage Testing Requirement Change for Reactor Building Spray System, dated April 22, 2022 (ADAMS Accession No. ML22115A104)
- 7. Letter from NRC to Dominion Energy South Carolina, Issuance of Amendment No. 224 to Change Nozzle Blockage Testing Requirement for Reactor Building Spray System, dated February 21, 2023 (ADAMS Accession No. ML23012A015)
- 8. Letter from Shearon Harris Nuclear Power Plant to the Nuclear Regulatory Commission, License Amendment Request Regarding Change to Containment Spray Nozzle Test Frequency, dated March 24, 2021 (ADAMS Accession No. ML21083A317)
- 9. Letter from NRC to Shearon Harris Nuclear Power Plant, Issuance of Amendment No.
190 Regarding Revision to Containment Spray Nozzle Test Frequency, dated February 10, 2022 (ADAMS Accession No. ML21351A472)
Joseph M. Farley Nuclear Plant - Units 1 & 2 Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency Proposed Technical Specification Changes (Marked-Up Pages)
Containment Spray and Cooling Systems 3.6.6 Farley Units 1 and 2 3.6.6-4 Amendment No. 225 XXX(Unit 1)
Amendment No. 222 XXX(Unit 2)
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.2 Operate each required containment cooling train fan unit for 15 minutes.
In accordance with the Surveillance Frequency Control Program SR 3.6.6.3 Verify each containment cooling train cooling water flow rate is 1600 gpm.
In accordance with the Surveillance Frequency Control Program SR 3.6.6.4 Verify each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head.
In accordance with the INSERVICE TESTING PROGRAM SR 3.6.6.5 Verify each automatic containment spray valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.
In accordance with the Surveillance Frequency Control Program SR 3.6.6.6 Verify each containment spray pump starts automatically on an actual or simulated actuation signal.
In accordance with the Surveillance Frequency Control Program SR 3.6.6.7 Verify each containment cooling train starts automatically on an actual or simulated actuation signal.
In accordance with the Surveillance Frequency Control Program SR 3.6.6.8 Verify each spray nozzle is unobstructed.
In accordance with the Surveillance Frequency Control ProgramFollowing activities that could result in nozzle blockage.
SR 3.6.6.9 Verify containment spray locations susceptible to gas accumulation are sufficiently filled with water.
In accordance with the Surveillance Frequency Control Program
Joseph M. Farley Nuclear Plant - Units 1 & 2 Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency Revised Technical Specification Pages
Containment Spray and Cooling Systems 3.6.6 Farley Units 1 and 2 3.6.6-4 Amendment No. (Unit 1)
Amendment No. (Unit 2)
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.2 Operate each required containment cooling train fan unit for 15 minutes.
In accordance with the Surveillance Frequency Control Program SR 3.6.6.3 Verify each containment cooling train cooling water flow rate is 1600 gpm.
In accordance with the Surveillance Frequency Control Program SR 3.6.6.4 Verify each containment spray pump's developed head at the flow test point is greater than or equal to the required developed head.
In accordance with the INSERVICE TESTING PROGRAM SR 3.6.6.5 Verify each automatic containment spray valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.
In accordance with the Surveillance Frequency Control Program SR 3.6.6.6 Verify each containment spray pump starts automatically on an actual or simulated actuation signal.
In accordance with the Surveillance Frequency Control Program SR 3.6.6.7 Verify each containment cooling train starts automatically on an actual or simulated actuation signal.
In accordance with the Surveillance Frequency Control Program SR 3.6.6.8 Verify each spray nozzle is unobstructed.
Following activities that could result in nozzle blockage SR 3.6.6.9 Verify containment spray locations susceptible to gas accumulation are sufficiently filled with water.
In accordance with the Surveillance Frequency Control Program
Joseph M. Farley Nuclear Plant - Units 1 & 2 Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency Proposed Technical Specification Bases Pages (Marked-up) - For Information Only
Containment Spray and Cooling Systems B 3.6.6 (continued)
Farley Units 1 and 2 B 3.6.6-13 Revision 96XXX BASES SURVEILLANCE SR 3.6.6.8 (continued)
REQUIREMENTS containment during an accident is not degraded. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.Activities that could cause nozzle blockage include inadvertent fluid flow through the nozzles, a loss of FME control within the system boundary or a major configuration change. An evaluation will determine if performance of this SR is required.
SR 3.6.6.9 Containment Spray System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the containment spray trains and may also prevent water hammer and pump cavitation.
Selection of Containment Spray System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas our could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.
The Containment Spray System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the Containment Spray System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.
Containment Spray System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same
Containment Spray and Cooling Systems B 3.6.6 Farley Units 1 and 2 B 3.6.6-14 Revision 96XXX BASES SURVEILLANCE SR 3.6.6.9 (continued)
REQUIREMENTS system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation.
REFERENCES
- 3. FSAR, Section 6.2.
- 4. FSAR, Section 7.3.
- 5. FSAR, Section 15.
- 6. ASME Code for Operation and Maintenance of Nuclear Power Plants.
- 7. WCAP-16294-NP-A, Rev. 1, Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs, June 2010.
Joseph M. Farley Nuclear Plant, Units 1 and 2 - Issuance of Amendment Nos. 225 and 222 Regarding Implementation of NEI 06-09, Risk-Informed Technical Specifications Initiative 4B, Risk-Managed Technical Specifications (RMTS) Guidelines, Revision 0-A (EPID L-2018-LLA-0210), dated August 23, 2019 (ADAMS Accession No. ML19175A243).