ML16256A135

License Amendment Request to Revise Facility Operating License Condition 2.C.(23) Required Completion Date

ML16256A135
Person / Time
Site:	Farley
Issue date:	09/08/2016
From:	Wheat J Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-16-0889
Download: ML16256A135 (12)

Text

Justin T. Wheat Southern Nuclear Nuclear Licensing Manager Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242

& Southern Nuclear Tel 205.992.5998 Fax 205.992.7601 September 8, 2016 Docket Nos.: 50-364 NL-16-0889 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant - Unit 2 License Amendment Request to Revise Facility Operating License Condition 2.C.(23) Required Completion Date Ladies and Gentlemen:

In accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) proposes to amend Renewed Facility Operating License (FOL) No. NPF-8 for Joseph M. Farley Nuclear Plant (FNP) Unit 2. This amendment corrects an understandable and unintentional mistake in the Unit 2 FOL.

Specifically, FNP Unit 2 Renewed FOL condition 2.C.(23) says in the second paragraph, The Southern Nuclear Updated Final Safety Analysis Report supplement, submitted pursuant to 10 CFR 54.21 (d), describes certain future activities to be completed prior to the period of extended operation. Southern Nuclear shall complete these activities no later than June 25, 2017, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection." However, June 25, 2017 is the date when Unit 1 future activities to be completed prior to the period of extended operation must be completed. The corresponding date for Unit 2 is March 31, 2021, which is the date that should be shown in the license condition. to this letter provides the proposed FOL License Condition change, the basis for the proposed change, and Significant Hazards Considerations. SNC has evaluated the proposed FOL change and has determined that it does not involve a significant hazards consideration as defined in 10 CFR 50.92. to this letter provides the marked up revision to the FOL License Condition. to this letter provides the clean-typed revision to the FOL License Condition.

SNC requests approval of the proposed license amendment by December 31, 2016. The proposed changes would be implemented within 90 days of issuance of the amendment.

U.S. Nuclear Regulatory Commission NL-16-0889 Page 2 This letter contains no NRC commitments. If you have any questions, please contact John Giddens at 205.992.7924.

Mr. Justin T. VVheat states he is the Nuclear Licensing Manager for Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.

I , .. ':. t ,*

Respectfully submitted,

,J \' 1 My commission expires: /O -J' - 2o/7 JlW/JMC/lac

Enclosures:

1. Basis for Proposed Change

2. Marked-Up License Condition Change Plan

3. Clean-Typed License Condition Change Plan*

cc: . Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Ms. C. A. Gayheart, Vice President- Farley.

Mr. M. D. Meier, Vice President - Regulatory Affairs Mr. D. R. Madison, Vice President- Fleet Operations Mr. B. J. Adams, Vice President - Engineering Ms. B. L. Taylor, Regulatory Affairs Manager- Farley RTYPE: CFA04.054 U. S. Nuclear Regulatory Commission Ms. C. Haney, Regional Administrator Mr. S. A Williams, NRR Project Manager - Farley Mr. P. K. Niebaum, Senior Resident Inspector - Farley

. Alabama Department of Public Health David Walter, Director, Alabama Office of Radiation Control

Joseph M. Farley Nuclear Plant - Unit 2 License Amendment Request to Revise Facility Operating License Condition 2.C.(23) Required Completion Date Enclosure 1 Basis for Proposed Change to NL-16-0889 Basis for Proposed Change Table of Contents 1.0 Summary Description 2.0 Detailed Description 3.0 Technical Evaluation 4.0 Regulatory Evaluation 4.1 No Significant Hazards Consideration Determination 4.2 Applicable Regulatory Requirements/Criteria 4.3 Conclusions 5.0 Environmental Consideration E1-1

Enclosure 1 to NL-16-0889 Basis for Proposed Change 1.0 Summary Description The proposed amendment corrects an understandable and unintentional mistake in the Facility Operating Licenses (FOL), NPF-8, for Joseph M. Farley Nuclear Plant (FNP) Unit 2.

2.0 Detailed Description This proposed License Amendment Request (LAR) corrects an understandable and unintentional mistake discovered in License Condition 2.C.(23). Specifically, the license condition states, "The Southern Nuclear Updated Final Safety Analysis Report supplement, submitted pursuant to 10 CFR 54.21 (d), describes certain future activities to be completed prior to the period of extended operation. Southern Nuclear shall complete these activities no later than June 25, 2017, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection." However, June 25, 2017 is the date the Unit 1 future activities must be completed. For Unit 2, the correct date for this license condition is March 31, 2021, not June 25, 2017.

This LAR proposes to change the FNP FOL, License Condition 2.C.(23), to correct the date by which the future activities described in the Updated Final Safety Analysis Report supplement must be completed from June 25, 2017 to March 31, 2021.

3.0 Technical Analysis The proposed amendment contains no technical changes; all proposed changes are administrative. These changes are consistent with the intent of what the Nuclear Regulatory Commission (NRC) has already approved..

Proposed Change:

Replace the date June 25, 2017 in License Condition 2.C.(23) with the date March 31, 2021, so that sentence reads:

Southern Nuclear shall complete these activities no later than March 31. 2021, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRG inspection.

Basis for Change:

This is an understandable and unintentional mistake. The following points provide a basis for that assertion.

The portion of the license condition in question that needs to be corrected states, "The Southern Nuclear Updated Final Safety Analysis Report supplement, submitted pursuant to 10 CFR 54.21 (d), describes certain future activities to be completed prior to the period of extended operation. Southern Nuclear shall complete these activities no later than June 25, 2017, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection." ,

Note that the date June 25, 2017 is the date that the previous FNP Unit 1 license, before license renewal, would have expired and the last day before the FNP Unit 1 Period of E1-2 to NL-16-0889 Basis for Proposed Change Extended Operation (PEO) begins. The comparable license condition in the FNP Unit 1 FOL is identical, including the date. Finally, note that the license condition states, " ... describes certain future activities to be completed prior to the period of extended operation. Southern Nuclear shall complete these activities no later than June 25, 2017, and ... "

For FNP Unit 1, this statement is consistent with the requirement that the activities must be completed prior to the period of extended operation because June 25, 2017 is the last day before the period of extended operation begins. However, for Unit 2, this June 25, 2017 is not consistent with the requirement because it still states the activities must be completed prior to the period of extended operation, but the last day before the period of extended operation is March 31, 2021, not June 25, 2017.

Risk Impact Discussion:

No formal risk evaluation was performed as no actual change to the plant is being made.

Defense-in-Depth/Safety Margin Discussion:

No Defense-in-Depth/Safety Margin evaluation was performed as no actual change to the plant is being made.

4.0 Regulatory Safety Analysis 4.1 Significant Hazards Consideration Southern Nuclear Operating Company (SNC) is requesting an amendment to the Joseph M. Farley N!Jclear Plant (FNP) Unit 2 Facility Operating License (FOL), License Condition 2.C.(23), to correct the date by which the future activities described in the Updated Final Safety Analysis Report supplement must be completed. The FOL was originally issued with this date, June 25, 2017, being the same date as in the similar license condition in the Unit 1 FOL, instead of the using the appropriate Unit 2 date, which is March 31, 2021.

A written evaluation of the significant hazards consideration of a proposed license amendment is required by 10 CFR 50.92. According to 10 CFR 50.92, a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

• Involve a significant increase in the probability or consequences of an accident previously evaluated; or

• Create the possibility of a new or different kind of accident from any accident previously evaluated; or

• Involve a significant reduction in a margin of safety.

As required by 10 CFR 50.91 (a), the SNC analysis of the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is presented below:

1: Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No E1-3 to NL-16-0889 Basis for Proposed Change The proposed amendment contains no technical changes; all proposed changes are administrative. These changes are consistent with the intent of what has already been approved by the Nuclear Regulatory Commission (NRC). There are no accidents affected by this change, and therefore no 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 proposed amendment contains no technical changes; all proposed changes are administrative. These changes are consistent with the intent of what has already been approved by the Nuclear Regulatory Commission (NRC). There are no accidents affected by this change, and therefore no 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 ame.ndment contains no technical changes; all proposed changes are administrative. These changes are consistent with the intent of what has already been approved by the Nuclear Regulatory Commission (NRC). There are no accidents affected by this change, and therefore no reduction in a margin

.of safety.

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 Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. SNC has evaluated the proposed amendment and determined that it involves no significant hazards consideration.

4.2 Applicable Regulatory Requirements/Criteria The proposed amendment contains no technical changes; all proposed changes are administrative. Therefore, there are no applicable regulatory requirements for these proposed changes.

• 4.3 Conclusions 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 Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common

• defense and security or to the health and safety of the public.

E1-4 to NL-16-0889 Basis for Proposed Change 5.0 Environmental Considerations SNC has evaluated the proposed amendment and determined that the amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or 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.

• E1-5

Joseph M. Farley Nuclear Plant - Unit 2 License Amendment Request to Revise Facility Operating License Condition 2.C.(23) Required Completion Date Enclosure 2 Marked-Up License Condition Change Page

(23) Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50 .71(e)(4) following issuance of this renewed license.

Until that update is complete , Southern Nuclear may make changes to the programs and activities described in the supplement without prior Commission approval , provided that Southern Nuclear evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements of that section.

The Southern Nuclear Updated Final Safety Analysis Report supplement, submitted pursuant to 10 CFR 54 .21 (d) , describes certain future activities to be completed prior to the period of extended operation . Southern Nuclear shall complete these activities no later than June 25 , 201 ?March 31. 2021 ,

and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection .

(24) Reactor Vessel Material Surveillance Capsules All capsules in the reactor vessel that are removed and tested must meet the test procedures and reporting requirements of American Society for Testing and Materials (ASTM) E 185-82 to the extent practicable for the configuration of the specimens in the capsule. Any changes to the capsule withdrawal schedule , including spare capsules , must be approved by the NRC prior to implementation. All capsules placed in storage must be maintained for future insertion .

D. Southern Nuclear shall fully implement and mainta in in effect all provisions of the Commission-approved physical security, training and qualification , and safeguards contingency plans includ ing amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73 .55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p) . The plan , which contain Safeguards Information protected under 10 CFR 73 .21 , is entitled : "Southern Nuclear Operating Company Security Plan ,

Training and Qualification Plan , and Safeguards Contingency Plan ," and was submitted on May 15, 2006 .

Southern Nuclear shall fully implement and maintain in effect all provisions of the Commission-approved cyber security (CSP) , includ ing changes made pursuant to the authority of 10 CFR 50 .90 and 10 CFR 50 .54(p) . The Southern Nuclear CSP was approved by License Amendment No. 181 , as supplemented by a change approved by License Amendment No. 195.

E. Deleted per Amendment 144 F. Alabama Power Company shall meet the following antitrust conditions:

(1) Alabama Power Company shall recognize and accord to Alabama Electric Cooperative (AEC) the status of a competing electric utility in central and southern Alabama .

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

Joseph M. Farley Nuclear Plant - Unit 2 License Amendment Request to Revise Facility Operating License Condition 2.C.(23) Required Completion Date Enclosure 3 Clean-Typed License Condition Change Page

(23) Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71 (e)(4) following issuance of this renewed license.

Until that update is complete, Southern Nuclear may make changes to the programs and activities described in the supplement without prior Commission approval, provided that Southern Nuclear evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements of that section.

The Southern Nuclear Updated Final Safety Analysis Report supplement, submitted pursuant to 10 CFR 54.21 (d}, d~scribes certain future activities to be completed prior to the period of extended. operation. Southern Nuclear shall complete these activities no later than March 31, 2021, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

(24) Reactor Vessel Material Surveillance Capsules All capsules in the reactor vessel that are removed and tested must meet the test procedures and reporting requirements of American Society for Testing and Materials (ASTM) E 185-82 to the extent practicable for the configuration of the specimens in the capsule. Any changes to the capsule withdrawal schedule, including spare capsules, must be approved by the NRC prior to implementation. All capsules placed in storage must be maintained for future insertion.

• D. Southern Nuclear shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plan, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Southern Nuclear Operating Company Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan," and was submitted on May 15, 2006.

• Southern Nuclear shall fully implement and maintain in effect all provisions of the Commission-approved cyber security (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Southern Nuclear CSP was approved by License Amendment No. 181, as supplemented by a change approved by License Amendment No. 195.

E. Deleted per Amendment 144 F. Alabama Power Company shall meet the following antitrust conditions:

(1) Alabama Power Company shall recognize and accord to Alabama Electric Cooperative (AEC) the status of a competing electric utility in central and southern Alabama.

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