NL-24-0341, Response to Request for Additional Information Related to the Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency
| ML24254A432 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 09/10/2024 |
| From: | Coleman J Southern Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| NL-24-0341 | |
| Download: ML24254A432 (1) | |
Text
Regulatory Affairs 3535 Colonnade Parkway Birmingham, AL 35243 205 992 5000 September 10, 2024 Docket Nos.: 50-348 NL-24-0341 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 Response to Request for Additional Information Related to the Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency Ladies and Gentlemen:
By letter dated April 5, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24096B775), Southern Nuclear Operating Company (SNC) submitted a license amendment request (LAR) for the Joseph M. Farley Nuclear Plant (FNP) Units 1 and 2. The LAR proposes to revise 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.
By email dated August 14, 2024 (ADAMS Accession No. ML24227A051), the U.S.
Nuclear Regulatory Commission (NRC) notified SNC that additional information is needed for the staff to perform their review.
The enclosure with this letter provides marked-up TS Bases pages that clarify the performance of the surveillance following activities that could result in nozzle blockage as stated in the proposed SR 3.6.6.8 Frequency, per the NRC Request for Additional Information (RAI). The enclosed pages replace the TS Bases pages provided with the LAR.
The conclusions of the No Significant Hazards Consideration and Environmental Consideration contained in the original application have been reviewed and are unaffected by this response.
In accordance with 10 CFR 50.91, a copy of this application, including attachments, is being provided to the designated Alabama Official.
U. S. Nuclear Regulatory Commission NL-24-0341 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 10th day of September 2024.
Respectfully submitted, Jamie M. Coleman Director, Regulatory Affairs Southern Nuclear Operating Company JMC/was/cgb
Enclosure:
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 Response to Request for Additional Information Related to the Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency Enclosure 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 based on the specific situation will determine the appropriate method for performing the surveillance.
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).