ML120730610

Issuance of Amendment Regarding Water Storage Tank

ML120730610
Person / Time
Site:	Farley
Issue date:	03/24/2012
From:	Martin R Plant Licensing Branch II
To:	Ajluni M Southern Nuclear Operating Co
Martin R DORL/LPL2-1 415-1493
References
TAC ME8005, TAC ME8006
Download: ML120730610 (25)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 24, 2012 Mr. M. J. Ajluni Nuclear Licensing Director Southern Nuclear Operating Company, Inc.

P. O. Box 1295 Bin - 038 Birmingham, AL 35201-1295

SUBJECT:

JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2, ISSUANCE OF AMENDMENTS REGARDING REFUELING WATER STORAGE TANK (TAC NOS. ME8005 AND ME8006)

Dear Mr. Ajluni:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 188 to Renewed Facility Operating License No. NPF-2 and Amendment No. 183 to Renewed Facility Operating License No. NPF-8 for the Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2, respectively, in response to your letter dated February 28, 2012, as amended by letters dated March 2 and March 9, 2012. This amendment revised the FNP Technical Specification (TS) 3.5.4, "Refueling Water Storage Tank," to permit the use of a seismically qualified boundary valve under administrative controls for limited periods of time.

A copy of the related Safety Evaluation is enclosed. Notice of Issuance will be included in the Commission's Biweekly Federal Register notice.

Sincerely,

!~

Robert E. Martin, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364

Enclosures:

1. Amendment No. 188 to NPF-2

2. Amendment No. 183 to NPF-8

3. Safety Evaluation cc wfencls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

ALABAMA POWER COMPANY DOCKET NO. 50-348 JOSEPH M. FARLEY NUCLEAR PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 188 Renewed License No. NPF-2

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Southern Nuclear Operating Company, Inc.

(Southern Nuclear). dated February 28,2012, as supplemented on March 2 and March 9, 2012. compliJs with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (0 that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

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2. Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment; and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-2 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 188, are hereby incorporated in the license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications.

3. This amendment is effective as of its date of issuance and shall be implemented within 30 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Nancy L. Salgado, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. NPF-2 and the Technical Specifications Date of Issuance: March 24, 2012

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

ALABAMA POWER COMPANY DOCKET NO. 50-364 JOSEPH M. FARLEY NUCLEAR PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 183 Renewed License No. NPF-8

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Southern Nuclear Operating Company, Inc.

(Southern Nuclear), dated February 28,2012, as supplemented on March 2 and March 9, 2012, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

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2. Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment; and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-8 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 183, are hereby incorporated in the license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications.

3. This amendment is effective as of its date of issuance and shall be implemented within 30 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Nancy L. Salgado, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. NPF-8 and the Technical Specifications Date of Issuance: March 24, 2012

ATTACHMENT TO LICENSE AMENDMENT NO. 188 RENEWED FACILITY OPERATING LICENSE NO. NPF-2 DOCKET NO. 50-348 AND LICENSE AMENDMENT NO. 183 RENEWED FACILITY OPERATING LICENSE NO. NPF-8 DOCKET NO. 50-364 Replace the following pages of the License and Appendix "A" Technical Specifications with the enclosed pages as indicated. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages License License License No. NPF-2, page 4 License No. NPF-2, page 4 License No. NPF-8, page 3 License No. NPF-8, page 3 TS TS 3.5.4-1 3.5.4.-1

-4 (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 188, are hereby incorporated in the renewed license.

Southern Nuclear shall operate the facility in accordance with the Technical Specifications.

(3) Additional Conditions The matters specified in the following conditions shall be completed to the satisfaction of the Commission within the stated time periods following the issuance of the renewed license or within the operational restrictions indicated. The removal of these conditions shall be made by an amendment to the renewed license supported by a favorable evaluation by the Commission.

a. Southern Nuclear shall not operate the reactor in Operational Modes 1 and 2 with less than three reactor coolant pumps in operation.

b. Deleted per Amendment 13

c. Deleted per Amendment 2

d. Deleted per Amendment 2

e. Deleted per Amendment 152 Deleted per Amendment 2

f. Deleted per Amendment 158

g. Southern Nuclear shall maintain a secondary water chemistry monitoring program to inhibit steam generator tube degradation.

This program shall include:

1) Identification of a sampling schedule for the critical parameters and control points for these parameters;

2) Identification of the procedures used to quantify parameters that are critical to control points;

3) Identification of process sampling points;

4) A procedure for the recording and management of data; Farley - Unit 1 Renewed License No. NPF-2 Amendment No. 188

- 3 (2) Alabama Power Company, pursuant to Section 103 of the Act and 10 CFR Part 50, "Licensing of Production and Utilization Facilities," to possess but not operate the facility at the designated location in Houston County, Alabama in accordance with the procedures and limitations set forth in this renewed license.

(3) Southern Nuclear, pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (4) Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5) Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (6) Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level Southern Nuclear is authorized to operate the facility at reactor core power levels not in excess of 2775 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 183, are hereby incorporated in the renewed license.

Southern Nuclear shall operate the facility in accordance with the Technical Specifications.

Farley - Unit 2 Renewed License No. NPF-8 Amendment No. 183

RWST 3.5.4 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.4 Refueling Water Storage Tank (RWST)

LCO 3.5.4 The RWST shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS

---

NOTES-------------**------------------------------------------------

1. RWST piping may be unisolated from non-safety related piping for ~ 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> under administrative controls to perform SR 3.5.4.3.'"

2. RWST piping may be unisolated from non-safety related piping for s 30 days per fuel cycle under administrative controls for filtration or Silica removal.'"

CONDITION REQUIRED ACTION COMPLETION TIME A. RWST boron A.1 Restore RWST to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> concentration not within OPERABLE status.

limits.

RWST borated water temperature not within limits.

B. RWST inoperable for B.1 Restore RWST to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> reasons other than OPERABLE status.

Condition A.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND I C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />

"'These Notes can only be applied during the next two fuel Cycles for each Unit.

These Notes cannot be used after Refueling Outages 1R26 (Spring 2015) and 2R24 (Spring 2016).

Farley Units 1 and 2 3.5.4*1 Amendment NO.188(Unit 1)

Amendment NO.183 (Unit 2)

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 188 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-2 AND AMENDMENT NO. 183 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-8 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND UNIT 2 DOCKET NOS. 50-348 AND 50-364

1.0 INTRODUCTION

By letter dated February 28,2012 as amended by letters dated March 2 and March 9, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession Nos.

ML12059A327, ML12065A026, and ML12072A234, respectively), Southern Nuclear Operating Company (SNC, the licensee) proposed changes to Technical Specification (TS) 3.5.4, Refueling Water Storage Tank [RWST]," for Units 1and 2 of the Joseph M. Farley Nuclear Plant (FNP). The proposed changes revise the TS to permit the use of a seismically qualified boundary valve under administrative controls for limited periods of time.

The RWST ensures that an adequate supply of borated water is available to cool and depressurize the containment in the event of a Design Basis Accident (DBA), to cool and cover the core in the event of a Loss Of Coolant Accident, to maintain the reactor subcritical following a DBA, and to ensure adequate level in the containment sump to support ECCS and Containment Spray System pump operation in the recirculation mode. To be considered OPERABLE, the RWST must meet the water volume, boron concentration, and temperature limits established in the TS surveillance requirements (SRs). SR 3.5.4.3 requires sampling the RWST contents every seven days to verify boron concentration is within limits.

The licensee describes the need for this amendment as follows:

Historically, until February 15, 2012, FNP was periodically using the Spent Fuel Pool (SFP) Purification Loop to filter the Refueling Water Storage Tank (RWST) water while in plant conditions and modes for which the RWST was required to be operable. This alignment was utilized for RWST water mixing prior to weekly surveillance sampling of the boron concentration as required by TS surveillance requirements (SR) 3.5.4.3 and typically for removal of silica from the RWST water prior to refueling outages. It was known that this system alignment could render the RWST inoperable during a seismic event since the SFP Purification Loop consisted of non-seismically qualified piping. To maintain operability, procedure changes were made to direct manual operator action to isolate the RWST from the SFP Purification Loop in the event of a Reactor Trip or at the direction of the Shift Supervisor. After

- 2 reviewing Information Notice (IN) 2012-01, "Seismic Considerations-Principally Issues Involving Tanks," Southern Nuclear Operating Company (SNC) concluded that manual actions should not be credited for this purpose without prior NRC approval and subsequently discontinued this practice. However, the original FNP design of the RWST system affords no other way to re-circulate the RWST through seismically qualified piping without making an Engineering Safety Features (ESF) train inoperable to meet TS sampling requirements ....

A non-seismically qualified safety-related reverse osmosis system, identified as the Boric Acid Recovery System (BARS), is used to remove silica from the RWST water.

Removal of silica is necessary to maintain Reactor Coolant System (RCS) chemistry within fuel requirements and to improve water clarity during refueling to prevent delays in fuel movement and facilitates safe handling of fuel. At FNP, the most practical method of ensuring RWST inventory is maintained, should a seismic event occur while removing silica "from the RWST water is to credit operator action for manually isolating the BARS piping from the RWST piping. Because the RWST water will also be required to be re-circulated through the SFP Purification Loop every seven days to perform required surveillance sampling of its boron concentration, the proposed change will also credit similar operator action during this system alignment as well.

Thus, the licensee describes two operational modes wherein it is desirable to circulate water from the RWST to support plant operations; one to allow mixing of the water within the RWST to support continuing to meet a TS surveillance requirement for the RWST and another operational mode to support reduction of silica content in the water so as to support refueling operations. Each of these two modes would involve opening a seismically qualified boundary valve downstream of the RWST to allow circulation of water through the SFP purification loop and the BARS. The piping and components of these two systems have no accident mitigation purposes and accordingly, are not designed to safety related requirements. The licensee recognizes, as noted above and in more detail in its application, that aligning the RWST with the two systems discussed above by opening the RWST boundary valve number ZV010, renders the RWST to be inoperable in a technical sense, since the non-seismically designed SFP Purification Loop and BARS piping would be assumed to fail if subjected to a seismic event. The licensee proposes to respond to this circumstance by taking the following described action:

To accommodate this recirculation of the RWST water while the RWST is required to be operable, this License Amendment Request (LAR) proposes to allow the crediting of operator action to close a seismically qualified manual ASME code boundary valve connected to the subject RWST piping should a reactor trip occur or the Shift Supervisor directs the valve to be closed, thereby isolating the RWST from non-seismically qualified piping and maintaining its seismic qualification and operability. [and] This closure of the subject boundary valve can be taken in sufficient time to ensure that the TS required volume of water is maintained in the RWST and the injection of sufficient coolant can be performed following a Reactor trip or at the direction of the Shift Supervisor.

- 3 The licensee proposes to limit the amount of time of the plant operating in this configuration by proposing modifications to the TS that will limit the time for mixing of the RWST inventory so as to meet SR 3.5.4.3 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and to specify a limit of 30 days total duration per fuel cycle for operation of the systems to allow RWST water filtration and silica removal. The licensee stated that these changes to the TS will be effective for the next two fuel cycles, after which time the licensee states that "physical modifications [would] be made to the subject systems eliminating the need for manual operator action." Specifically, the changes to TS 3.5.4 are as follows:

RWST piping may be unisolated from non-safety related piping for s 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> under administrative controls to perform SR 3.5.4.3*

RWST piping may be unisolated from non-safety related piping for s 30 days per fuel cycle under administrative controls for filtration or silica removal.*

• These Notes can only be applied during the next two fuel Cycles for each Unit. These Notes cannot be used after Refueling Outages 1R26 (Spring 2015) and 2R24 (Spring 2016).

The supplements dated March 2 and March 9, 2012, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staffs original proposed no significant hazards consideration determination as published in the Federal Register on March 9, 2012 (77 FR 14441).

2.0 REACTOR SYSTEMS ASPECTS 2.1 Regulatory Evaluation - Reactor Systems Information Notice (IN) 2012-01, "Seismic Considerations - Principally Issues Involving Tanks" states, "This IN provides examples and references to events in which licensees failed to recognize various seismic considerations and system alignment issues that could impact safety.

The NRC staff has identified recent concerns about SLC test tanks that were not seismically qualified when they contained water. This operating experience may apply to other tanks found on site at nuclear plants. The NRC identified other examples in which licensees failed to recognize that aligning nonseismic piping to the RWST would require TS LCO action statement entry, system modifications, or license amendments."

Applicable General Design Criteria (GOC)

GOC 2 requires that structures, systems and components important to safety be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without the loss of the capability to perform their safety functions.

GOC 35 Emergency Core Cooling requires that a system to provide abundant emergency core cooling shall be provided. The safety function shall be to transfer heat from the reactor core following any loss of reactor coolant at a rate such that (1) fuel and clad damage that could interfere with continued effective core cooling is prevented and (2) clad metal-water reaction is limited to negligible amounts.

-4 Suitable redundancy in components and features, and suitable interconnections, leak detection, isolation, and containment capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure.

2.2 Technical Evaluation - Reactor Systems 1 During plant operation in Modes 1 through 4, the RWST is required to be operable to maintain a borated water supply for accident mitigation purposes. The RWST is aligned to the suction of the residual heat removal pumps and the containment spray pumps during normal operation in Modes 1 through 4. The suction of the charging pumps is automatically aligned to the RWST on a safety injection signal. During refueling operation in Modes 5 and 6, the RWST is required to be operable as a borated water supply should the boric acid storage system not be operable. The contents of the RWST are also used to flood the refueling cavity during refueling operation. The water in the RWST is borated to a concentration sufficient to ensure shutdown margin is maintained when the reactor is at cold shutdown conditions should RWST water be added to the reactor.

The SFP Purification Loop is a subsystem of the spent fuel pool cooling system that is connected to portions of the RWST piping. The SFP Purification Loop piping is non-safety grade and not seismically qualified. During an evaluation of a seismic event, the failure of the non-seismic SFP Purification Loop piping must be considered. Such a failure could potentially result in a loss of RWST inventory should the ASME Code boundary valve between the RWST and the SFP Purification Loop be open with the SFP Purification Loop aligned to the RWST.

The licensee's FSAR states "The Spent Fuel Pool Cooling and Purification System (SFPCPS) is designed to remove the decay heat generated by stored fuel assemblies from the spent fuel pool water. This cooling is accomplished by taking high temperature water from the pool, pumping it through a heat exchanger, and returning the cooled water to the pool. A secondary function of the SFPCPS is to clarify and purify the spent fuel pool, transfer canal, and refueling water. A portion of the hot water discharged by the pump can be diverted through a water cleanup system and returned to the pool. The purification function of the SFPCPS does not meet Seismic Category 1 requirements."

The primary function of the SFP Purification Loop is to maintain the optical clarity of the spent fuel pool water avoiding delays and providing for safer handling of the fuel. This system is also used to purify the refueling water in the refueling canal and RWST. Prior to refueling outages, the SFP Purification Loop is also used to re-circulate the RWST water to ensure a representative sample for the required boron concentration surveillance.

The surveillance testing of the RWST boron concentration requires sampling of the tank contents every seven days. The licensee mixes the RWST for approximately one hour to receive accurate sample results. The alignment for recirculation requires unisolating the RWST piping from the SFP Purification Loop which is non-safety related and not seismically qualified. In order to 1 Much of the text in this section is a synopsis of information in the licensee's submittals. This section emphasizes the information that is most relevant to the staffs consideration and includes the staffs findings on issues.

-5 perform the alignment, the licensee has credited operator action to close the RWST piping's seismically qualified manual code boundary valve in the event of a seismic event.

The non-seismically qualified skid-mounted Boric Acid Recovery System (BARS) is used to reduce RWST silica concentration levels during power operation in modes that the RWST is required to be operable. Circulation of the RWST contents through the SFP Purification Loop is required when placing BARS in services. The licensee expects to use the BARS system for 30 days or less during each unit's cycle.

An alternative to using the SFP Purification Loop to circulate the RWST water to take the weekly TS SR required sample is to use the Containment Spray (CS) or Residual Heat Removal (RHR) systems. When using these systems the licensee would align them in such a way that could cause the systems to be inoperable while they circulate the RWST water. This action would require the licensee to voluntarily enter into a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Required Action Statement. While this is an option, the staff concludes that when comparing this method to the controlled use of the SFP purification loop, as proposed by the licensee, it is not the preferred method.

The FNP RWST silica concentrations have been increasing due to silica migration from the spent fuel pool to the reactor cavity during refueling outage fuel transfer operations. Increasing silica levels in the RWST mix with reactor coolant each refueling outage in the reactor cavity, increasing the silica concentrations in the reactor coolant system (RCS). The RCS silica concentration limit is less than or equal to 1 ppm based on Westinghouse fuel warranty limits.

The RCS silica concentration can be removed in several ways. The RWST water can be diluted to lower the concentration of silica. This method creates liquid radioactive waste that must be processed. Silica can be removed from the spent fuel pool water as well. The licensee stated that industry experience shows that removing silica from the SFP leads to further deterioration of the Boroflex material in the storage racks in the SFP. The BARS system can also be placed in service with the SFP Purification Loop aligned to the RWST in order to filter the silica. The staff concludes that when these considerations are compared, using the BARS is the preferable method of reducing silica concentration in the RCS water.

The licensee proposes to add notes to TS 3.5.4 to allow the SFP Purification Loop to be aligned to the RWST to perform recirculation of the RWST for weekly SR required sampling as well as alignment to the BARS system for silica removal. The notes would allow this alignment under administrative controls. These administrative controls include stroking the manually operated boundary valve open and closed prior to circulating the RWST water through the SFP Purification System, establishing a designated operator to control the valve, and establishing a preplanned communication method between the operator and the Shift supervisor. The notes would only be allowed to be applied until refueling outages 1R26 and 2R24.

Stroking the manually operated boundary valve Q1 (2)G31 V01 0 open and closed prior to performing circulation through the loop allows the operators to observe that the valve closes as well as observe any RWST drop in level after the valve has been closed to ensure that no leakage is occurring and the valve has closed.

The operator designated to perform the manual action on the boundary valve will be a part of the normal shift compliment. Procedure does not allow this operator to be part of the fire brigade.

The operator will also be required to stay within the seismically qualified Auxiliary Building. The

- 6 designated operator will be a licensed operator or a fully qualified system operator. The control room operator is required to participate in a brief with the designated operator. The control room operator will be responsible for contacting the designated operator and direction performance of the action and the method of communication will be addressed during the required brief. The operator actions required by the designated operator in the Auxiliary Building are to secure the Refueling Water Purification (RWP) pump by a handswitch, and manually close the Refueling water Purification pump suction from the RWST Isolation valve Q1(2)G31V010. The handswitch and the valve are located in the same room. The designated operator is briefed to be readily available and able to secure the RWP pump and close Q1(2)G31V010 within 10 minutes. The operators are required to carry flashlights and are generally directed to stay in operator work stations on the 100 foot or 121 foot elevation. The pump and valve are on the 130 foot elevation.

The Unit 1 Q1G31V010 valve and the Unit 2 Q2G31V010 valve constitute the boundary between the seismic category 1 piping to the RWST and the downstream attached non-safety-related piping. The valves are N-Stamped for class 2 piping and seismically qualified. Unit 1 Q1 G31V01 0 is located in the vertical piping run. Two seismic supports are provided for, since there is a tee one foot downstream of the valve. There is one support on each leg of the tee.

Anchor SS-3640 on the vertical run is 18 inches from the end of the valve. Seismic Support SS-3641 is located 25 inches from the tee connection to provide anchorage support on the pipe.

Unit 2 Q2G31V010 has a Seismic Support SS-14989 located three inches downstream of the seismic valve. The staff concludes that there is reasonable assurance boundary valves Q1G31V010 and Q2G31V010 would remain operable if a seismic event were to occur.

The licensee stated that during a seismic event, should the SFP Purification Loop be severed it would take approximately 35 minutes for the RWST to drain out of the 2 inch pipe and down to its minimum TS required level. The administrative controls require the valve be closed within 10 minutes of the initiating event. This provides 25 minutes of margin between when the valve is administratively required to be closed and when the TS minimum level of the RWST would be reached. The licensee provided scenarios in which they evaluated the time it would take the operator to reach the valve and operate the handswitch and valve. The licensee found that when they stationed the designated operator in the furthest credible point from the valve in the seismically qualified Auxiliary Building the average time to complete the isolation of the RWST from the SFP Purification Loop was approximately 4 minutes. The licensee also developed a scenario in which the designated operator goes to the valve in the wrong unit. They found that in three validation cases the operators were able to promptly investigate why the valve was already closed and the RWST was still draining. They found that the operators were still able to isolate the correct unit within the 10 minute procedural requirement. The staff has found that the licensee has provided reasonable assurance that the RWST will be isolated from the SFP Purification Loop within the procedurally required 10 minutes. Further, there would be another 25 minutes from the procedural limit until the TS limit is reached for minimum RWST water level.

The staff concludes that there is reasonable assurance that the isolation valves will remain intact during a seismic event that the designated operator will be able to perform his required functions within the procedurally required 10 minute completion time. Further the staff has found that there is reasonable assurance that the RWST water level will remain above the TS minimum level in the event of a seismic event.

-7 2.3 Conclusions - Reactor Systems The staff has reviewed the proposed TS changes to TS 3.5.4 regarding allowing non-seismically qualified piping of the SFP purification system to be connected to the RWST seismic piping by manual operation of a RWST seismically qualified boundary valve under administrative controls for limited time periods. The limited time periods are up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for performance of SR 3.5.4.3 and 30 days per fuel cycle per unit for filtration and to remove silica from the RWST water. The changes are to be applied only for the next two cycles for each unit. They cannot be used after Refueling Outages 1R26 (Spring 2015) and 2R24 (Spring 2016). The staff has concluded that there is reasonable assurance that the isolation valves will remain intact during a seismic event that the designated operator will be able to perform the required functions within the procedurally required 10 minute completion time. Further the staff has found that there is reasonable assurance that the RWST will remain above the TS minimum required level in the event of a seismic event. Therefore, the NRC staff has concluded that the proposed TS change is acceptable.

3.0 HUMAN PERFORMANCE ASPECTS 3.1 Regulatory Evaluation - Human Performance The regulatory requirements and guidance considered in the human performance aspects of the staff's review of the LAR are as follows:

1. Appendix A to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, "General Design Criteria (GDC)," Criterion 19--ControJ room. "A control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents ... Equipment at appropriate locations outside the control room shall be provided (1) with a design capability for prompt hot shutdown of the reactor, including necessary instrumentation and controls to maintain the unit in a safe condition during hot shutdown, and (2) with a potential capability for subsequent cold shutdown of the reactor through the use of suitable procedures."

2. 10 CFR 50.120, "Training and qualification of nuclear power plant personnel"

3. NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition." Chapter 13 addresses "Conduct of Operation."

Specific sub-chapters considered in this review were Chapters 13.2.1. "Reactor Operator Requalification Program; Reactor Operator Training", and 13.5.2.1 "Operating and J

Emergency Operating Procedures." Chapter 18, provides review guidance for "Human Factors Engineering."

4. NUREG-1764, "Guidance for the Review of Changes to Human Actions;"

5. GL 82-33, "Supplement 1 to NUREG-0737 - Requirements for Emergency Response Capability";

6. NUREG-0700. "Human-System Interface Design Review Guidelines" Revision 2;

-8

7. NUREG-0711, "Human Factors Engineering Program Review Model," Revision 2;

8. IN 97-78, "Crediting Operator Actions in Place of Automatic Actions and Modifications of Operator Actions, Including Response Times."

3.2 TECHNICAL EVALUATION

3.2.1 Description of Operator Action(s) and Assessed Safety Significance The proposed TS change would revise 3.5.4, "Refueling Water Storage Tank" such that the non-seismically qualified piping of the Spent Fuel Pool (SFP) purification system may be connected to the RWST's seismic piping by manual operation of a RWST seismically qualified boundary valve under administrative controls for limited periods of time. This action is conditional on assignment of a qualified crew member to be available to isolate the RWST in a timely manner, so that it retains its safety function of being a source of reactor coolant during transients and accidents. This is proposed as an interim action until a design solution makes the action unnecessary.

In accordance with the generic risk categories established in Appendix A to NUREG-1764, this task sequence is considered "risk-important" due to the fact that its failure would jeopardize the ECCS injection and recirculation phases of a LOCA. Because of its risk importance, the NRC staff performed a "Level One" review, i.e., the most stringent of the graded reviews possible under the guidance of NUREG-1764.

Note: This NRC staff assessment of risk is only for the purpose of scoping the staff's review and may conflict with the licensee's assessment of risk importance or that of other branches, and should not be considered as an accurate assessment of risk when compared to other methods, especially, those using plant-specific data and NRC-accepted methods of Probabilistic Risk Analysis and Human Reliability Analysis (PRNHRA).

3.2.2 Operating Experience Review Farley operating experience was used to develop the operating strategy as well as reasonable durations for weekly testing and pre-outage RWST purification. A review of relevant Licensee Event Reports for the last twenty-five years was done by the staff to confirm that the proposed manual actions have an operating history of successful implementation. No negative trends were identified. Based on the above, the staff finds SNC's application of operating experience acceptable.

3.2.3 Functional Requirements Analysis and Function Allocation Because the proposed, interim operator action is not a new action, a functional requirements analysis and function allocation were not necessary. Prior experience had shown that operators, when assigned this task, had sufficient time and resources available to perform it reliably.

However, for the long term the licensee has decided to resolve the issue in the long-term by re-design, e.g., automation, or seismic upgrading, or both. The staff finds the SNC approach acceptable based on their demonstration of adequate margin to proposed time constraints, their characterization of the action as a time-critical action, and their intent to monitor the feasibility and reliability of the action until redesign is completed, i.e., Refueling Outages 1R26 (Spring 2015)

-9 and 2R24 (Spring 2016).

3.2.4 Task Analysis Because this interim operator action is not a new action, the only aspect requiring reanalysis was the establishment of time constraints for the action sequence. The licensee established the design value of 35 minutes and an operational value of ten minutes for the time to close the valve that isolates the RWST from the non-seismic Spent Fuel Pool Purification System and the Boric Acid Recovery System (BARS). The design and operational values for the timing of the action sequence were validated (see Human Factors Verification and Validation, below). The walkthrough testing demonstrated adequate margin to the design time limit. The staff finds the SNC update to the task timing acceptable based on their validation of adequate margin to proposed time constraints.

3.2.5 Staffing Staffing and qualification are not affected by the proposed LAR. No new or additional crew members are required, nor are there any new or additional qualifications required to perform the action sequence within the time constraints established.

3.2.6 Probabilistic Risk and Human Reliability Analyses Probabilistic Risk Analysis and Human Reliability Analysis are outside the scope of review for the Health Physics and Human Performance Branch (IHPB) and, therefore, are not reviewed in this safety evaluation (SE).

3.2.7 Human-System Interface Design Human-System Interface (HSI) design, including the design of the Safety Parameter Display System (SPDS) will not be affected by the proposed LAR.

3.2.8 Procedure Design No changes are required to the Emergency Operating Procedures (EOPs). Because the proposed interim action is not a new action, the existing procedure covering the action (Procedure FNP-1/2-S0P-54.0 Appendix 8/7 or FNP-1/2-S0P-54.4 Appendix 5/4) does not require any changes. The staff finds the existing procedure acceptable based the validation and verification of the procedure to confirm its effectiveness.

3.2.9 Training Program and Simulator Design The Farley simulator is not capable of modeling the proposed task sequences and will not, therefore, be used in training. A training needs analysis was completed. Based on the fact that the proposed action has a long history of successful implementation, and is supported by written procedures, the licensee concluded that additional training is not necessary. Based on the above, the staff finds that the training already provided is acceptable.

- 10 3.2.10 Human Factors Verification and Validation Time testing of the proposed action was performed to demonstrate sufficient margin to the licensee-established design values. The results of this study indicate that operators are able to isolate RWST flow to the non-seismic systems. The licensee found that the operator action is achievable within the operational goal of 10 minutes as directed by procedure, providing substantial margin to the 35 minute design value available. Even when a wrong-unit error was simulated, the error was recovered and the action completed in less than ten minutes. Based on the results of these walkthrough demonstrations, the staff finds that the actions are feasible and can be reliably performed by Farley operators within the very conservative operational time established (ten minutes).

3.2.11 Human Performance Monitoring Strategy The procedures and actions proposed by this LAR will be included in licensee's configuration control program. This will ensure that subsequent changes to the plant, procedures, or programs will not invalidate the credited action times. Based on the administrative protection against inadvertent change and the licensee's plan to obviate the manual action in the longer term, the staff finds the SNC long-term monitoring strategy acceptable.

3.2.12 Conclusion - Human Performance Aspects Based on the statements provided by SNC, i.e., that time-testing results demonstrate significant margin to design, that appropriate administrative controls will be applied to procedures and training, and that both Units have substantial in-house operating experience, the staff concludes that the proposed LAR is acceptable from the human performance point of view.

4.0 TECHNICAL SPECIFICATION ASPECTS 4.1 Regulatory Evaluation - Technical Specifications The Commission's regulatory requirements related to the content of TS are set forth in 10 CFR 50.36. This regulation requires that the TS include items in five specific categories.

These categories include (1) safety limits, limiting safety system settings and limiting control settings, (2) LCOs, (3) SRs, (4) design features, and 5) administrative controls.

Additionally, 10 CFR 50.36(d)(3) defines SRs as 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 staff reviewed the proposed changes for compliance with 10 CFR 50.36. In general, licensees must fully describe and justify the desired technical specification changes. The staff then makes a determination as to whether the proposed changes maintain adequate safety.

Changes that result in relaxation (less restrictive condition) of current TS requirements require detailed justification.

Licensees may revise the technical specifications provided that plant-specific review supports a finding of continued adequate safety because: (1) the change is editorial, administrative or

- 11 provides clarification (i.e., no requirements are materially altered), (2) the change is more restrictive than the licensee's current requirement, or (3) the change is less restrictive than the licensee's current requirement, but nonetheless still affords adequate assurance of safety when judged against current regulatory standards. The detailed application of this general framework, and additional specialized guidance, are discussed in Section 4.2 in the context of specific proposed changes.

The staff evaluated the TS changes contained in the licensee's amendment request by comparing them to the Requirements of 10 CFR 50.36.

4.2 Technical Evaluation - Technical Specifications The current FNP RWST TS require the RWST to be operable in MODES 1 through 4. Aligning the RWST with the SFP Purification System could render the RWST inoperable during a seismic event since the SFP Purification Loop consisted of non-seismically qualified piping. The licensee stated that its preferred methods for performing the boron concentration verification of SR 3.5.4.3, as well as reducing silica in the RWST prior to a refueling outage involve aligning the RWST with the SFP Purification System. When the RWST is inoperable for reasons other than water temperature or boron concentration being out of limits, current RWST TS Condition B requires the RWST to be restored to operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of being made inoperable. If the RWST is not restored to operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, the licensee is required to bring the plant to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

The licensee proposed adding two notes to TS 3.5.4, as well as a footnote describing how long the notes would be applicable. The notes and footnote would read:

1) RWST piping may be unisolated from non-safety related piping for::;; 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> under administrative controls to perform SR 3.5.4.3.*

2) RWST piping may be unisolated from non-safety related piping for::;; 30 days per fuel cycle under administrative controls for filtration or silica removal. "*

• These Notes can only be applied during the next two fuel Cycles for each Unit.

These Notes cannot be used after Refueling Outages 1 R26 (Spring 2015) and 2R24 (Spring 2016).

The staff reviewed the proposed changes and determined that the changes are less restrictive than the licensee's current requirements. The licensee provided justification for the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> allowance in Note 1 and the 30 day allowance in Note 2. The licensee stated that the alternative to performing SR 3.5.4.2 by aligning the RWST to the SFP Purification System would require rendering the Containment Spray system inoperable for approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> every seven days.

The licensee also stated that the 30 day allowance in Note 2 is appropriate based on the time required to reduce silica content in the RWST prior to refueling outages. The licensee provided RWST silica reduction time data from the past six Unit 1 outages and the past five Unit 2 outages.

The staff reviewed the licensee's justification for the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> allowance in Note 1 and determined that unisolating RWST piping under administrative control is acceptable, as discussed in section 3.2.12. The staff reviewed the silica cleanup data and concluded that a 30 day allowance is necessary for RWST silica cleanup, since recent operations have taken as long as 27 days. The staff concluded that both notes are acceptable. The staff determined that the footnote restricting

- 12 the applicability of the notes to the next two fuel cycles is acceptable, given the complexity of developing a permanent solution to allow RWST sampling and silica reduction using seismically qualified systems.

The licensee submitted proposed TS Bases pages that describe the notes, footnote, and some of the details of the administrative controls necessary to unisolate RWST piping. While the staff does not approve TS Bases pages, the staff did review the pages. The staff determined the TS Bases language is consistent with the licensee's justification for the proposed change.

4.3 Conclusions - Technical Specifications The staff determined that the proposed changes meet the regulatory requirements of 10 CFR 50.36. The staff determined the proposed change is less restrictive than the licensee's current requirements, but nonetheless still affords adequate assurance of safety when judged against current regulatory standards. The staff determined that all proposed changes are acceptable.

5.0 EXIGENT AND CHANGED CIRCUMSTANCES A Notice of Consideration of Issuance of Amendment, Proposed No Significant Hazards Consideration and Opportunity for Hearing was published in the Federal Register on March 9, 2012. In accordance with the provisions of 10 CFR 50.91 (a)(6), comments were requested within 14 days from the date of publication and hearing requests within 60 days from the date of publication. However, that notice provided that the Commission could issue the subject amendment prior to the expiration of the 14-day comment period if circumstances changed so that prompt action was required by the Commission.

By letter dated February 28, 2012, the licensee has provided a basis with respect to the change in circumstances related to the amendment request. The licensee stated that until February 15, 2012, it was periodically using the spent fuel pool (SFP) purification loop to filter the RWST water while in plant conditions and modes for which the RWST was required to be operable. The licensee utilized manual actions to maintain the operability of the RWST during that time. The licensee stated that after reviewing Information Notice 2012-01, "Seismic Considerations Principally Issues Involving Tanks," dated January 26,2012, it concluded on February 15, 2012, that manual actions should not be credited for this purpose without prior NRC approval and subsequently discontinued that practice. However, the licensee has a continuing need to circulate water through the RWST for the purpose of meeting the surveillance requirements of TS 3.5.4 and refueling water filtration prior to refueling outages. The licensee states that it plans a refueling outage beginning on April 1, 2012, and submitted the request for an exigent change to the TSs before that time.

With the issuance of the Federal Register Notice on March 9,2012, the 14-day period for noticing exigent amendment would expire prior to the licensee's scheduled entry into its refueling outage.

The NRC staff concludes that the licensee could not have foreseen the changed circumstances for operation of RWST related activities that derived from issuance of the NRC Information Notice discussed above and that the licensee acted promptly in preparing its LAR within two weeks upon determining on February 15, 2012, that the preferred RWST operations required prior NRC approval. The NRC staff has evaluated the changes in circumstances related to the amendment

- 13 request and has determined that a valid need exists for issuance of the TSs under consideration to allow upon expiration of the 14-day comment period.

6.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION

DETERMINATION The regulations at 10 CFR 50.92 state that the Commission may make a final determination that a license amendment involves no significant hazards considerations, if operation of the facility, in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of any accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.

These amendments have been evaluated against the standards in 10 CFR 50.92. They do not involve a significant hazards consideration because:

(1) The proposed change does not involve a significant increase in the probability or consequences of any accident previously evaluated. The use of the [Boric Acid Recovery System] BARS system and the SFP Purification Loop to re-circulate the RWST does not involve any changes or create any new interfaces with the reactor coolant system or main steam system piping. Therefore, the connection of the SFP Purification Loop to the RWST and use of the BARS system would not affect the probability of these accidents occurring.

Neither the SFP Purification Loop nor the BARS system are credited for safe shutdown of the plant or accident mitigation. A combination of design and administrative controls ensure that both the SFP Purification Loop and BARS systems maintain RWST boron concentration and water volume requirements whenever the contents of the RWST are processed through these systems. RWST volume margin will be verified to be adequate to compensate for postulated BARS system line losses and process losses which may occur through the BARS system reject waste stream. The BARS system is designed to maintain a high boron recovery rate. Potential boron dilution during use of the BARS system is prevented through verifying RWST boron margin prior to BARS system operation and monitoring the BARS system boron recovery rate by grab samples taken from the system inlet and outlet points approximately one hour after placing it in service and at least every 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> thereafter. Following each operation of the BARS system, RWST sampling will be performed to verify the RWST boron concentration, and boron additions will be made to the RWST, accordingly.

Since the RWST will continue to perform its safety function and meet all surveillance requirements, overall system performance is not affected, assumptions previously made in evaluating the consequences of the accident are not altered, and the consequences of the accident are not increased.

(2) The amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated. Contingent upon manual operator action as described above, a SFP Purification Loop line break will not result in a loss of the RWST safety function. Similarly, an active or passive failure in the BARS system will not result in loss of the RWST safety function. Adequate RWST volume and boron margin will be verified prior to BARS system operation. The BARS system boron

- 14 recovery rate will be monitored by grab samples taken of the system inlet and outlet one hour after placing the system in service and at least every 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> thereafter. In addition, the [Documentation of Engineering Judgment] DOEJ evaluation supports that the operator action can be taken within sufficient time to isolate the BARS system from the RWST during postulated accidents.

Calculations were reviewed for potential internal flooding from this nonseismic pipe break, and it was concluded that the break would have no affect on safe shutdown equipment in the affected areas.

(3) The amendment does not involve a significant reduction in a margin of safety. Neither the SFP Purification Loop nor the BARS systems are credited for safe shutdown of the plant or accident mitigation. Adequate RWST volume and boron margin will be verified prior to BARS system operation and timely operator action can be taken to isolate the BARS system from the RWST. The BARS system waste stream losses will also be monitored throughout BARS system operation.

The potential boron dilution of the RWST inventory during tank processing through the SFP Purification Loop is minimized by administratively maintaining closed all manual boundary valves within the SFP Purification Loop while the SFP Purification Loop is connected to the RWST. The BARS system is designed to maintain a high boron recovery rate, which will be verified through testing prior to initial start up of the system. Potential boron dilution during every operation of the BARS system is prevented through verification of the RWST boron margin prior to BARS system operation, calculating the expected rate of dilution, and monitoring the BARS system boron recovery rate by grab samples taken from the system inlet and outlet at least every 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. Following operation of the BARS system, RWST sampling will be performed to verify the RWST boron concentration, and boron additions to the RWST will be made accordingly. These measures will ensure the TS minimum RWST boron concentration is available to mitigate the short-term consequences of a small break LOCA, large break LOCA, or MSLB accident.

Accordingly, the Commission has determined that this amendment involves no significant hazards considerations.

7.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Alabama State official was notified of the proposed issuance of the amendment. The State official had no comments.

8.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (77 FR 14441). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR

- 15 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

9.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (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 amendments will not be inimical to the common defense and security or to the health and safety of the public.

10.0 REFERENCES

1. Southern Nuclear Operating Company, Inc., Joseph M. Farley Nuclear Plant, Units 1 and 2, License Amendment Request "Refueling Water Storage Tank," February 28,2012 (ADAMS Accession No. ML12059A327).

2. Southern Nuclear Operating Company, Inc., Joseph M. Farley Nuclear Plant, Units 1 and 2, response to request for additional information, March 2, 2012 (ADAMS Accession No. ML12065A026).

3. Southern Nuclear Operating Company, Inc., Joseph M. Farley Nuclear Plant, Units 1 and 2, response to request for additional information, March 9, 2012 (ADAMS Accession No. ML12072A234).

4. NRC Information Notice 2012-01: Seismic Considerations - Principally Issues Involving Tanks, January 26, 2012 (ADAMS Accession No. ML11292A175)

Principal Contributors: J. Miller M. Hamm G. Lapinsky Date oJ issuance: March 24,2012

March 24, 2012 Mr. M. J. Ajluni Nuclear licensing Director Southern Nuclear Operating Company, Inc.

P. O. Box 1295 Bin - 038 Birmingham, AL 35201-1295

SUBJECT:

JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2, ISSUANCE OF AMENDMENTS REGARDING REFUELING WATER STORAGE TANK (TAC NOS. ME8005 AND ME8006)

Dear Mr. Ajluni:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 188 to Renewed Facility Operating License No. NPF-2 and Amendment No. 183 to Renewed Facility Operating License No. NPF-8 for the Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2, respectively, in response to your letter dated February 28, 2012, as amended by letters dated March 2 and March 9,2012. This amendment revised the FNP Technical Specification (TS) 3.5.4, "Refueling Water Storage Tank,>> to permit the use of a seismically qualified boundary valve under administrative controls for limited periods of time.

A copy of the related Safety Evaluation is enclosed. Notice of Issuance will be included in the Commission's Biweekly Federal Register notice.

Sincerely, IRA!

Robert E. Martin, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364

Enclosures:

1. Amendment No. 188 to NPF-2

2. Amendment No. 183 to NPF-8

3. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

Public JMitter, NRR RidsNrrDorllp2-1 RidsOgcRp lp12-1 RfF MSinglelary, NRR RidsNrrDssStsb RidsRgn2MailCenter MHamm, NRR RidsAcrs AcnwMailCTR RidsNrrLASFigueroa Glapinsky, NRR RidsNrroOrlDpr RidsNrrPMFarley ADAMS Accession No, Ml120730610

• b memo dated OFFtCE NRRIlPl2*1/PM DSS/STSB/BC DSS/SRXB/BC DRAlAHPB/BC NAME RMartin AUlses UShoo DATE 03115/12 03/08/12

• 03/09/12

• OFFICE DSS/AADB/BC NRRflPl2*1/PM NAME TTate RMartin DATE 03115/12 03/24/12