ML040610023

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& 02/05/2004 Summary of Telephone Conferences Between the U.S. Regulatory Commission and Southern Nuclear Operating Company Concerning Draft Requests for Additional Information on Farley Nuclear Plant, Units 1 and 2 TAC MC0774 & MC0775
ML040610023
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 02/25/2004
From: Tilda Liu
NRC/NRR/DRIP/RLEP
To: Stinson L
Southern Nuclear Operating Co
Liu T, NRR/DRIP/RLEP, 415-1315
References
TAC MC0774, TAC MC0775
Download: ML040610023 (16)


Text

February 25, 2004 LICENSEE: Southern Nuclear Operating Company FACILITY: Joseph M. Farley Nuclear Plant, Units 1 and 2

SUBJECT:

SUMMARY

OF TELEPHONE CONFERENCES ON JANUARY 28 AND FEBRUARY 5, 2004, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND THE SOUTHERN NUCLEAR OPERATING COMPANY CONCERNING DRAFT REQUESTS FOR ADDITIONAL INFORMATION ON JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. MC0774 AND MC0775)

The U.S. Nuclear Regulatory Commission staff and representatives of Southern Nuclear Operating Company (SNC or the applicant) held telephone conferences on January 28 and February 5, 2004, to discuss the draft requests for additional information (D-RAIs) concerning the Joseph M. Farley Nuclear Plant (FNP) license renewal application.

The conference calls were useful in clarifying the intent of the staffs questions. On the basis of the discussion, the applicant was able to better understand the staff's questions. No staff decisions were made during the telephone conferences. In some cases, the applicant agreed to provide information for clarification. provides a list of the telephone conference participants. Enclosure 2 contains a listing of the D-RAIs discussed with the applicant, including a brief description on the status of the items. The applicant has had an opportunity to review and comment on this summary.

/RA/

Tilda Y. Liu, Project Manager License Renewal Section A License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos: 50-348 and 50-364

Enclosures:

As stated cc w/enclosures: See next page

February 25, 2004 LICENSEE: Southern Nuclear Operating Company FACILITY: Joseph M. Farley Nuclear Plant, Units 1 and 2

SUBJECT:

SUMMARY

OF TELEPHONE CONFERENCES ON JANUARY 28 AND FEBRUARY 5, 2004, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND THE SOUTHERN NUCLEAR OPERATING COMPANY CONCERNING DRAFT REQUESTS FOR ADDITIONAL INFORMATION ON JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. MC0774 AND MC0775)

The U.S. Nuclear Regulatory Commission staff and representatives of Southern Nuclear Operating Company (SNC or the applicant) held telephone conferences on January 28 and February 5, 2004, to discuss the draft requests for additional information (D-RAIs) concerning the Joseph M. Farley Nuclear Plant (FNP) license renewal application.

The conference calls were useful in clarifying the intent of the staffs questions. On the basis of the discussion, the applicant was able to better understand the staff's questions. No staff decisions were made during the telephone conferences. In some cases, the applicant agreed to provide information for clarification. provides a list of the telephone conference participants. Enclosure 2 contains a listing of the D-RAIs discussed with the applicant, including a brief description on the status of the items. The applicant has had an opportunity to review and comment on this summary.

/RA/

Tilda Y. Liu, Project Manager License Renewal Section A License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos: 50-348 and 50-364

Enclosures:

As stated cc w/enclosures: See next page DISTRIBUTION:

Accession No: ML040610023 See next page Document Name:C:\ORPCheckout\FileNET\ML040610023.wpd OFFICE PM:RLEP LA:RLEP SC:RLEP NAME TLiu YEdmonds SLee DATE 2/18/04 2/18/04 2/25/04 OFFICIAL RECORD COPY

DISTRIBUTION: Date: February 25, 2004 Accession No: ML040610023 HARD COPY RLEP RF T. Liu (PM)

K. Martin D. Jeng H. Ashar G. Galletti T. Ford E-MAIL:

PUBLIC J. Craig D. Matthews F. Gillespie C. Grimes RidsNrrDe E. Imbro G. Bagchi K. Manoly W. Bateman J. Calvo R. Jenkins P. Shemanski J. Fair S. Black B. Boger D. Thatcher R. Pettis G. Galletti C. Li J. Moore R. Weisman M. Mayfield A. Murphy S. Smith (srs3)

S. Duraiswamy Y. L. (Renee) Li RLEP Staff C. Julian (R-II)

C. Patterson (R-II)

R. Fanner (R-II)

S. Peters D. Cummings/M. Lemoncelli (OGC)

OPA B. Jain L. Whitney

LIST OF PARTICIPANTS FOR TELEPHONE CONFERENCES ON DRAFT REQUESTS FOR ADDITIONAL INFORMATION January 28, 2004 Participants Affiliation Tilda Liu NRC David Jeng NRC Richard Morante BNL Charles Hofmayer BNL Jan Fridrichsen SNC Mike Macfarlane SNC Chuck Pierce SNC Danny Stephens SNC Partha Ghosal SNC Mark Crisler SNC February 5, 2004 (1st Call)

Participants Affiliation Tilda Liu NRC Greg Galletti NRC Y. (Renee) Li NRC Chang Li NRC Jan E. Fridrichsen SNC Mike Macfarlane SNC Bill Evans SNC Chuck Pierce SNC February 5, 2004 (2nd Call)

Participants Affiliation Tilda Liu NRC Tanya Ford NRC Kamishan Martin NRC Jan E. Fridrichsen SNC Mike Macfarlane SNC Danny Stephens SNC Bill Evans SNC Chuck Pierce SNC Willie Jennings SNC Enclosure 1

REVIEW OF LICENSE RENEWAL APPLICATION (LRA) FOR FARLEY UNITS 1 AND 2 DRAFT REQUESTS FOR ADDITIONAL INFORMATION (D-RAIs)

January 28, 2004 Section 2.4: Scoping and Screening Results: Containments, Structures, and Component Supports D-RAI 2.4-1 LRA Table 2.2-1h identifies structures that are not in scope of license renewal. It is not obvious to the staff that all of the listed structures serve no intended function. The applicant is requested to provide its technical basis for this determination for the following structures: circulating water structures and cooling towers; containment equipment hatch access enclosure; river water intake structure; meteorological & microwave structures and equipment; and yard drainage system. Also verify that seismic II/I considerations are not applicable to any of the structures not in the scope of license renewal (e.g., containment equipment hatch access enclosure).

In addition, while the staff acknowledges that the tendon access gallery does not serve an intended function in the strictest interpretation of the License Renewal Rule, there is significant industry operating experience related to flooding and corrosive environments in the tendon access gallery that have contributed to degradation of the tendon anchorage components and surrounding concrete. Management of the condition of the tendon access gallery is a preventive step to minimize aging effects for the prestressing system. The applicant is requested to submit its plant-specific operating/aging experience related to (1) flooding and corrosive environments in the tendon access gallery, and (2) degradation of the prestressing system components (both steel and concrete) in the tendon access gallery, and based on the FNP specific tendon gallery operating/aging experience, discuss FNPs basis for not including the tendon gallery structure within the AMR scope pursuant to 10 CFR 54.4(a)(2).

Response: The applicant indicated that the question is clear. This D-RAI will be sent as a RAI.

D-RAI 2.4-2 Based on its review of LRA Sections 2.1, 2.2, 2.3, 2.4, and 2.5, the staff identified a number of cross-references between the mechanical and structural scoping and screening, that require clarification and/or additional information:

(1) In LRA Section 2.4.2.7, the plant vent stacks are identified as yard structures. However, in the first paragraph, it is stated The plant vent stacks are evaluated as part of the Auxiliary and Radwaste Ventilation System in Section 2.3.3.10. In LRA Section 2.4.2.7, under the heading Plant Vent Stack, it states The vent stack is a Seismic Category I structure that is not required for safe shutdown. and The vent stack is a non safety-related structure but its function is to maintain its structural integrity during a design basis event such that it does not impact other SR structures or components. It appears that the plant vent stacks are in the LR scope for seismic II/I considerations. LRA Table 2.3.3.10 does not list the plant vent stacks as a Component Type. Please clarify which section of LRA Chapter 2 includes the plant vent stacks (and their foundations) in its scope, and also identify where the AMR for the plant vent stacks (and their foundations) is explicitly listed in LRA Chapter 3.5 tables.

Enclosure 2

(2) LRA Table 2.3.1.3 identifies Pressurizer-Support Lugs and Pressurizer-Support Skirt and Flange, with a Structural Support intended function. These component types appear to be the ASME Class 1 component support for the pressurizer. However, LRA Section 2.4.1.4 Containment Internal Structures states RCS supports are addressed in Section 2.4.3, Component Supports. LRA Section 2.4.3.1 Supports for ASME and Non-ASME Piping and Components describes the supports for the reactor vessel, steam generator, reactor coolant pumps, and pressurizer.

In order to clarify the treatment of pressurizer supports in the LRA:

a. verify that the ASME Class 1 component supports for the reactor vessel, steam generators, reactor coolant pumps, and pressurizer are included in the Structures scope, under Component Supports. In LRA Table 2.4.3, only RPV Supports are explicitly identified.
b. explain the Pressurizer-Support Lugs and Pressurizer-Support Skirt and Flange entries in LRA Table 2.3.1.3.

Response: The applicant indicated that the question is clear. The staff informed the applicant that part (1) of this D-RAI will be sent as a RAI, and part (2) of the D-RAI will be combined with other D-RAIs that are of CLARIFYING and/or CONFIRMATORY in nature, and sent under an umbrella RAI.

D-RAI 2.4-3 Please clarify the complete scope of load handling systems in the Farley LR scope. LRA Section 2.3.3.4 Overhead Heavy and Refueling Load Handling System appears to be limited to the major heavy lift and refueling-related systems. Are there any other load handling systems that serve an intended function (e.g., seismic II/I), and are included in the LR scope?

If so, please provide a description of the other load handling systems in the LR scope; define their intended functions; identify whether they are in the Mechanical Systems scope or Structures scope; and specify where the AMR is located in the LRA.

Response: The applicant indicated that the question is clear. This D-RAI will be sent as a RAI.

D-RAI 2.4-4 In LRA Section 2.4.2.6 Steel Tank Structures (Foundations and Retaining Walls), it states:

The Emergency Diesel Generator Fuel Oil Storage Tanks are 40,000 gallon, Seismic Category I underground tanks. The tanks are supported by poured concrete and buried for protection.

LRA Table 2.4.2.6 does not specifically identify a component type to cover a buried concrete foundation. The staff requests the applicant to confirm that the subject buried concrete foundation is in the scope of license renewal, and to identify the component type in LRA Table 2.4.2.6 that includes this foundation.

Response: The applicant indicated that the question is clear. The staff informed the applicant that this D-RAI will be combined with other D-RAIs that are of CLARIFYING and/or CONFIRMATORY in nature, and will be sent under an umbrella RAI.

D-RAI 2.4-5 To completely clarify the scope of the ultimate heat sink structures, provide the following additional information:

(1) Describe the River Water system that transports water from the river water intake structure to the storage pond and explain why the structures in this system are not within the scope of license renewal. Also, can there be a reverse flow of water that can reduce the water level in the storage pond, and consequently jeopardize the intended function of the ultimate heat sink?

If applicable, what structures would prevent such an occurrence and are they included in the LR scope?

(2) In LRA Section 2.4.2.5, the discussion of the Storage Pond Spillway Structure does not include a description of the Spillway Intake and Discharge Canals. These canals are described in FSAR Section 2.4.8.2. Further information on these canals (channels) is provided in FSAR Section 2.4.14.2, which states:

The spillway channel shall be inspected after each operation of sufficient magnitude to have a potential for erosion. A discharge of 80 ft3/s corresponding to a pool at elevation 187.0 has been selected as the minimum flow for which inspection shall be required. At this discharge the flow in the grassed discharge channel would have an average velocity of about 1.3 ft. per second with a flow depth of 1.3 ft. The pond level will be monitored in the control room. Whenever the operator observes or inspection of the chart indicates that the pool level is greater than or equal to elevation 187.0, the channels and structure shall be inspected at the end of the discharge period, as required by the Technical Requirements Manual. Eroded areas that affect or can affect the channel bank slopes or that are more than 4 ft. deep should be promptly repaired. Because of the expected infrequent use of the spillway, the channels and structure shall also be inspected biennially, as required by the Technical Requirements Manual.

In light of the above information, clarify whether the Spillway Intake and Discharge Canals are within the scope of license renewal. If not, explain why not.

Response: The applicant indicated that the question is clear. This D-RAI will be sent as a RAI.

D-RAI 2.4-6 LRA Section 2.4.2.1 states that the Auxiliary Building is a reinforced concrete slab, bearing directly on the Lisbon foundation. However, FSAR Section 3.8.4.1A indicates that portions of the foundation consist of a reinforced concrete slab placed over 9 ft. 5 in. of concrete fill, which in turn bears on the Lisbon formation. FSAR Section 3.8.4.1A further indicates that another portion of the foundation consists of a reinforced concrete slab placed over 30 ft. of compacted fill, which in turn rests on a reinforced concrete mat bearing directly on the Lisbon formation. In addition, FSAR Section 3.8.5.1B indicates that the eastern section of the Auxiliary Building is supported on spread footings which bear on the Lisbon formation, and also states that loads are transmitted through cast-in place reinforced concrete columns. The applicant is requested to clarify whether all the concrete structural elements of the Auxiliary Building foundation (as described in the FSAR) are within the scope of license renewal. If not, provide the technical basis for their exclusion.

Response: The applicant indicated that the question is clear. The staff informed the applicant that this D-RAI will be combined with other D-RAIs that are of CLARIFYING and/or CONFIRMATORY in nature, and sent under an umbrella RAI.

REVIEW OF LICENSE RENEWAL APPLICATION (LRA) FOR FARLEY UNITS 1 AND 2 APPLICANTS RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION (RAI)

February 5, 2004 (1ST Call)

The NRC staff and representatives of SNC held a telephone conference on February 5, 2004, to discuss the applicants responses to RAI 2.1-1, and RAI 2.1-2, dated January 9, 2004. On the basis of the discussions, the applicant plans to revise some of its responses. A summary of the questions discussed and the applicants proposed actions are presented below.

RAI 2.1-1 10 CFR 54.4(a)(2), Scoping Criteria for Non-safety Related Systems, Structures, or Components (SSCs)

Orthogonal Restraint The applicant stated in its RAI response that its non-safety related (NSR) piping attached to the safety related (SR) piping is in scope up to and including the third orthogonal restraint. During the discussion, the applicant confirmed that this evaluation scope is consistent with the seismic analysis and current licensing basis (CLB) pertaining to FNP, Units 1 and 2. The staff determined that no further information is required for the particular RAI response.

20 ft. Radius The staff asked what analysis that FNP, Units 1 and 2, has in order to support the criteria that, for all low energy systems with the potential for interaction (e.g., in proximity to a SR SSC),

spraying will not disperse greater than a distance of 20 ft. In addition, the staff asked that for those low energy systems evaluated at FNP, Units 1 and 2, whether the valid threat systems determined only to be at atmospheric pressure and/or temperature. The applicant indicated that it will need to conduct a review on this issue prior to responding to the staffs questions.

This issue will be discussed again during a future conference call or a meeting.

Electrical Target The staff asked that, for SR mechanical components in low energy locations, whether the mechanical and structural components were qualified to withstand the environmental effects postulated for low energy crack or leakage as part to the CLB. The staff stated that, if these mechanical and structural components were not qualified for the postulated environment as required by the CLB, then exclusions based on the premise of short-term exposure to wetting of these components does not appear to be reasonable. The staff indicated that these components should be brought into scope, and an appropriate AMP be applied to these SCs.

The applicant indicated that it will need to conduct a review on this issue prior to responding to the staff s questions. This issue will be discussed again during a future conference call or a meeting.

RAI 2.1-2 Quality Assurance Program Attributes in Appendix A, Updated Final Safety Analysis Report (UFSAR) Supplement, and Appendix B, Aging Management Activities The staff requested the applicant to clarify that the UFSAR update regarding the FNP Operations Quality Assurance Program is applicable to non-safety SSCs in addition to safety related SSCs. The applicant plans to revise its response by including this clarification.

REVIEW OF LICENSE RENEWAL APPLICATION (LRA) FOR FARLEY UNITS 1 AND 2 DRAFT REQUESTS FOR ADDITIONAL INFORMATION (D-RAIs)

February 5, 2004 (2nd Call)

Section 2.3.1: Reactor Vessel, Internals, and Reactor Coolant System 2.3.1.1 Reactor Vessel D-RAI 2.3.1.1-1 Please provide justifications for the exclusions or submit an AMR for each of the stated component:

a. Verify whether the component group "Head Vent Penetration" listed in LRA Table 2.3.1.1 includes head vent piping, which serves as a pressure boundary. In accordance with 10 CFR 54.4(a), the piping should be within the scope of license renewal.
b. Verify whether the component group "Leakage Monitoring Tube Assembly" listed in LRA Table 2.3.1.1 includes O-Ring leak monitor tubes, which serves as a pressure boundary. In accordance with 10 CFR 54.4(a), O-Ring leak monitor tubes should be within the scope of license renewal.

Response: The staff informed the applicant and the applicant agreed that this D-RAI will be combined with other D-RAIs that are of CLARIFYING and/or CONFIRMATORY in nature, and will be sent under one umbrella RAI. The applicant indicated that the question is clear.

D-RAI 2.3.1.1-2 Instrumentation tubes and safe ends were not identified in the LRA (Table 2.3.1.1) as within the scope of license renewal. The subject components perform a pressure boundary function, and therefore, should be within scope. The staff requests the applicant to confirm that there are no instrumentation tubes and safe ends at Farley. However, if instrumentation tubes and safe ends do exist, then the applicant should identify them within scope, and submit an AMR for them.

Response: The staff informed the applicant and the applicant agreed that this D-RAI will be combined with other D-RAIs that are of CLARIFYING and/or CONFIRMATORY in nature, and will be sent under one umbrella RAI. The applicant indicated that the question is clear.

D-RAI 2.3.1.1-3 Borated water leakage through the pressure boundary in PWRs, and resulting borated water induced wastage of carbon steel is a potential aging degradation for the components. Reactor vessel head lifting lugs are considered to be such components requiring aging management.

However, if the components are currently covered under Boric Acid Wastage Surveillance Program, then it may not require additional aging management. It appears that the subject components were not discussed in the LRA (Table 2.3.1.1); and therefore, the staff requests the applicant to verify whether the components are within the surveillance program; and if not, to provide an explanation for the exclusion.

Response: The applicant indicated that the question is clear. This question will be sent as a RAI.

2.3.1.2 Reactor Vessel Internals D-RAI 2.3.1.2-1 Please verify whether the component group "Neutron Panels" listed in LRA Table 2.3.1.2 includes a thermal shield, whose intended function is to provide shielding for the safety-related SSCs, such as the reactor vessel and the internals, from gammas and neutrons. A thermal shield may be relied upon to minimize irradiation induced embrittlement of the vessel and/or the internals. If the component exists at Farley, clarify whether a thermal shield is included with "Neutron Panels" or justify its exclusion from aging management; otherwise, submit an AMR for the subject component.

Response: The applicant indicated that the question is clear. This question will be sent as a RAI.

D-RAI 2.3.1.2-2 Please clarify whether the following list of bolts are included in LRA Table 2.3.1.1 as part of the component group, "Baffle Bolts".

a. Lower and Upper Support Column Bolts
b. Baffle/Former Bolts
c. Barrel/Former Bolts
d. Guide Tube Bolts
e. Clevis Insert Bolts The above list usually provides structural support of the reactor core as well as flow distribution of reactor coolant to the reactor core. The above items meet the criteria identified in 10 CFR 54.4(a), and therefore, should be within the scope of license renewal. If the above items are not included in component group "Baffle Bolts" and exist at Farley, please provide justification for the exclusion or submit an AMR for the stated components.

Response: The staff informed the applicant and the applicant agreed that this D-RAI will be combined with other D-RAIs that are of CLARIFYING and/or CONFIRMATORY in nature, and will be sent under one umbrella RAI. The applicant indicated that the question is clear.

D-RAI 2.3.1.2-3 Diffuser plates were not identified in the LRA (Table 2.3.1.2) as within the scope of license renewal. The above component provides flow distribution of reactor coolant to the reactor core and meets the criteria identified in 10 CFR 54.4(a). Therefore, diffuser plates should be within the scope of license renewal. Please provide justification for the exclusion or submit an AMR for the stated component.

Response: The staff informed the applicant and the applicant agreed that this D-RAI will be combined with other D-RAIs that are of CLARIFYING and/or CONFIRMATORY in nature, and will be sent under one umbrella RAI. The applicant indicated that the question is clear.

2.3.1.3 Reactor Coolant System and Connected Lines D-RAI 2.3.1.3-1 Please verify whether the component groups "Piping, Class 1 (Reactor Coolant Loop)," "Piping, Class 1 (Piping Components < NPS 4)," and "Piping, Class 1 (Piping Components

listed in LRA Table 2.3.1.3 also include fittings, which serve as a pressure boundary. In accordance with 10 CFR 54.4(a), the fittings should be within the scope of license renewal.

Please provide justification for the exclusion or submit an AMR for the stated components.

Response: The applicant indicated that the question is clear. This question will be sent as a RAI.

D-RAI 2.3.1.3-2 The following components were not identified in the LRA (Table 2.3.1.3) as within the scope of license renewal:

a. Primary loop elbows
b. Reactor coolant pump lugs These components provide pressure boundaries and meet the criteria identified in 10 CFR 54.4(a). Therefore, these components should be within the scope of license renewal.

Please provide justification for the exclusion or submit an AMR for each of the stated components.

Response: The staff informed the applicant and the applicant agreed that this D-RAI will be combined with other D-RAIs that are of CLARIFYING and/or CONFIRMATORY in nature, and will be sent under one umbrella RAI. The applicant indicated that the question is clear.

D-RAI 2.3.1.3-3 Pursuant to 10 CFR 50, Appendix R, Section III O, the reactor coolant pump (RCP) lube oil collection subsystem is designed to collect oil from the RCPs and drain it to a collection tank to prevent a fire in the Containment Building during normal plant operations. The staff believes that the subsystem and the tank should be within scope requiring aging management.

However, it appears that the subject components were not identified in the LRA (Table 2.3.1.3);

and therefore, the staff requests the applicant to provide an explanation for the exclusion or submit an AMR for the stated component.

Response: The applicant indicated that the requested information is located in the LRA. The information is located in the text section of Section 2.3.3.19 of the LRA. Therefore, this question is WITHDRAWN and will not be sent as a formal RAI.

D-RAI 2.3.1.3-4 Thermal barrier heat exchanger tubing was not identified in the LRA (Table 2.3.1.3) as within the scope of license renewal. The above component provides a pressure boundary, heat transfer ability, and meets the criteria identified in 10 CFR 54.4(a). Therefore, the component should be within the scope of license renewal. Please provide justification for the exclusion or submit an AMR for the stated component.

Response: The applicant indicated that the requested information is located in the LRA. The information is located in Table 2.3.1.3, "RCP Thermal Barrier Assembly, in the LRA. Therefore, this question is WITHDRAWN and will not be sent as a formal RAI.

2.3.1.4 Steam Generator D-RAI 2.3.1.4-1 Please provide justification for the exclusion or submit an AMR for the following stated components:

a. Verify whether the component group "Primary Inlet and Outlet Nozzle Safe Ends" listed in LRA Table 2.3.1.4 includes primary inlet and outlet nozzles, which serve as a pressure boundary. In accordance with 10 CFR 54.4(a), the following component groups should be within the scope of license renewal.
b. Verify whether the component group "Secondary Side Shell Penetrations" listed in LRA Table 2.3.1.4 includes blowdown piping nozzles, which serve as a pressure boundary. In accordance with 10 CFR 54.4(a), the blowdown piping nozzles should be within the scope of license renewal.
c. Verify whether the component group "Secondary Side Manways, Handholes, Inspection Ports, Covers" listed in LRA Table 2.3.1.4 includes secondary closures, which serve as a pressure boundary. In accordance with 10 CFR 54.4(a), the secondary closures should be within the scope of license renewal.

Response: The applicant indicated that the requested information is located in the LRA. The information in (a) of the D-RAI is located in Table 2.3.1.1, "Channel Head and Integral Primary Nozzles, in the LRA. The information in (b) of the D-RAI is located in Table 2.3.1.4, "Secondary Shell Penetrations, in the LRA. The information in (c) of the D-RAI is located in Table 2.3.1.4, "Secondary Side Manways, Handholes, Inspection Ports, Covers, in the LRA.

Therefore, this question is WITHDRAWN and will not be sent as a formal RAI.

D-RAI 2.3.1.4-2 The following components were not identified in the LRA (Table 2.3.1.4) as within the scope of license renewal:

a. Steam outlet nozzle
b. Primary channel head They provide pressure boundary functions and meet the criteria identified in 10 CFR 54.4(a).

Therefore, these components should be within the scope of license renewal. Please provide justification for the exclusion or submit an AMR for each of the stated component.

Response: The applicant indicated that the requested information is located in the LRA. The information for (a) of the D-RAI is located in Table 2.3.1.4, "Upper Head with Integral Steam Nozzle, in the LRA. The information for (b) of the D-RAI is located in Table 2.3.1.4, "Channel Head and Integral Primary Nozzles, in the LRA. Therefore, this question is WITHDRAWN and will not be sent as a formal RAI.

D-RAI 2.3.1.4-3 The following components were not identified in the LRA (Table 2.3.1.4) as within the scope of license renewal:

a. Internal shroud
b. Lattice grid tube supports
c. U-Bend restraints
d. Support pad
e. Seismic lugs The above components provide structural support functions and meet the criteria identified in 10 CFR 54.4(a). Therefore, these component should be within the scope of license renewal.

Please provide justification for the exclusion or submit an AMR for each of the stated component.

Response: The staff informed the applicant and the applicant agreed that this D-RAI will be combined with other D-RAIs that are of CLARIFYING and/or CONFIRMATORY in nature, and will be sent under one umbrella RAI. The applicant indicated that the question is clear.

D-RAI 2.3.1.4-4 Primary manway bolts were not identified in the LRA (Table 2.3.1.4) as within the scope of license renewal. The above components provide mechanical closure integrity and meets the criteria identified in 10 CFR 54.4(a). Therefore, the component should be within the scope of license renewal. Please provide justification for the exclusion or submit an AMR for the stated component.

Response: The applicant indicated that the requested information is located in the LRA. The information is located in Table 2.3.1.4, "Closure Bolting (Primary), in the LRA. Therefore, this question is WITHDRAWN and will not be sent as a formal RAI.

D-RAI 2.3.1.4-5 Steam generator (SG) tube plugs were not identified in the LRA (Table 2.3.1.4) as within the scope of license renewal. The subject components perform a pressure boundary function, and therefore, should be within scope. The staff requests the applicant to confirm that there are no SG tube plugs inside the SGs at FNP, Units 1 and 2. If there are tube plugs inside the SGs, then the applicant should identify them within scope, and submit an AMR for them.

Response: The staff informed the applicant and the applicant agreed that this D-RAI will be combined with other D-RAIs that are of CLARIFYING and/or CONFIRMATORY in nature, and will be sent under one umbrella RAI. The applicant indicated that the question is clear.

2.3.2 Engineered Safety Features 2.3.2.3 Emergency Core Cooling System (ECCS)

D-RAI 2.3.2.3-1 Screen assemblies and vortex suppressors are normally used in the containment sump which provides water for the ECCS recirculation phase, and one of the intended functions is to protect the ECCS pumps from debris and cavitation due to harmful vortex following a LOCA. The subject components were not identified as within scope in Table 2.3.2.3 of the LRA, which listed component groups for the ECCS that require an AMR. Explain why screen assemblies and vortex suppressors are not in scope or submit an AMR for the stated components.

Response: The applicant indicated that the requested information is located in the LRA. The information is located in Tables 2.3.2.1, "Vortex Breakers and 2.4.1, "Sump Trash Rack, in the LRA. Therefore, this question is WITHDRAWN and will not be sent as a formal RAI.

2.3.3 Auxiliary Systems 2.3.3.8 Chemical and Volume Control System (CVCS)

D-RAI 2.3.3.8-1 The following components were not identified in the LRA (Table 2.3.3.8) as within the scope of license renewal.

a. CVCS condenser
b. CVCS cooler
c. Flow element
d. Pulsation damper
e. Pump casing The above components provide pressure boundary functions and meet the criteria identified in 10 CFR 54.4(a). Therefore, these components should be within the scope of license renewal.

Please provide justification for the exclusion or submit an AMR for each of the stated component.

Response: The applicant indicated that, for parts (a), (b), and (d) of this D-RAI, the requested information is not applicable to FNP, Units 1 and 2; and for part (e), the requested information is located in the LRA. The information for part (e) of this D-RAI is located in Tables 2.3.3.8, "Boric Acid Transfer Pump Casings and 2.3.2.3, "High Head & RHR Pump Casings, in the LRA.

Therefore, the aforementioned parts to this question are WITHDRAWN and will not be sent under a formal RAI. Part (c) of this D-RAI will be combined with other D-RAIs that are of CLARIFYING and/or CONFIRMATORY in nature, and will be sent under one umbrella RAI.

The applicant indicated that the question is clear.

Joseph M. Farley Nuclear Plant cc:

Mr. Don E. Grissette Mr. William D. Oldfield General Manager - Plant Farley SAER Supervisor Southern Nuclear Operating Company Southern Nuclear Operating Company Post Office Box 470 Post Office Box 470 Ashford, AL 36312 Ashford, AL 36312 Mr. B. D. McKinney Mr. Charles R. Pierce Licensing Manager Manager - License Renewal Southern Nuclear Operating Company Southern Nuclear Operating Company 40 Inverness Center Parkway 40 Inverness Center Parkway Post Office Box 1295 Post Office Box 1295 Birmingham, AL 35201-1295 Birmingham, AL 35201 Mr. Stanford M. Blanton, esq. Mr. Fred Emerson Balch and Bingham Law Firm Nuclear Energy Institute Post Office Box 306 1776 I Street, NW, Suite 400 1710 Sixth Avenue North Washington, DC 20006-3708 Birmingham, AL 35201 Resident Inspector Mr. J. B. Beasley, Jr. U.S. Nuclear Regulatory Commission Executive Vice President 7388 N. State Highway 95 Southern Nuclear Operating Company Columbia, AL 36319 40 Inverness Center Parkway Post Office Box 1295 Mr. L. M. Stinson, Jr.

Birmingham, AL 35201 Vice President - Farley Project Southern Nuclear Operating Company Dr. D. E. Williamson 40 Inverness Center Parkway State Health Officer Post Office Box 1295 Alabama Department of Public Health Birmingham, AL 35201 The RSA Tower 201 Monroe Street, Suite 1500 Montgomery, AL 36130-1701 Chairman Houston County Commission Post Office Box 6406 Dothan, AL 36302