ML22308A059

Issuance of Amendments Regarding Revision to Technical Specifications to Relocate Augmented Piping Inspection Program Details to a Licensee-Controlled Document

ML22308A059
Person / Time
Site:	Farley
Issue date:	11/08/2022
From:	John Lamb Plant Licensing Branch II
To:	Gayheart C Southern Nuclear Operating Co
Devlin-Gill, Stephanie
References
EPID L-2021-LLA-0235
Download: ML22308A059 (18)

Text

November 8, 2022 Ms. Cheryl A. Gayheart Regulatory Affairs Director Southern Nuclear Operating Co., Inc.

3535 Colonnade Parkway Birmingham, AL 35243

SUBJECT:

JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS REGARDING REVISION TO TECHNICAL SPECIFICATIONS TO RELOCATE AUGMENTED PIPING INSPECTION PROGRAM DETAILS TO A LICENSEE-CONTROLLED DOCUMENT (EPID L-2021-LLA-0235)

Dear Ms. Gayheart:

The U. S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 244 to Renewed Facility Operating License No. NPF-2 and Amendment No. 241 to Renewed Facility Operating License No. NPF-8 for the Joseph M. Farley Nuclear Plant (Farley), Units 1 and 2, respectively. The amendments consist of changes to the License and Technical Specifications (TSs) in response to your application dated December 22, 2021, as supplemented by letter dated May 10, 2022.

The amendments would revise the Farley, Units 1 and 2, TS by relocating augmented piping inspection detailed information from TS 5.5.16, Main Steamline Inspection Program, to the Farley, Units 1 and 2, Updated Final Safety Analysis Report (UFSAR). A program description will remain in TS 5.5.16.

The Amendment No. 216 to Renewed Facility Operating License NPF-68 and Amendment No. 199 to Renewed Facility Operating License NPF-81 for the Vogtle Electric Generating Plant, Units 1 and 2, were issued under Agencywide Documents and Access Management System Accession No. ML22286A074.

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

C.

If you have questions, you can contact me at 301-415-3100 or John.Lamb@nrc.gov.

Sincerely,

/RA/

John G. Lamb, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364

Enclosures:

1. Amendment No. 244 to NPF-2

2. Amendment No. 241 to NPF-8

3. Safety Evaluation for Farley cc: Listserv

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. 244 Renewed License No. NPF-2

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

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

(Southern Nuclear), dated December 22, 2021, as supplemented by a letter dated May 10, 2022, 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 license 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.

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 The Technical Specifications contained in Appendix A, as revised through Amendment No. 244, are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 90 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: November 8, 2022 Michael T.

Markley Digitally signed by Michael T. Markley Date: 2022.11.08 13:37:49 -05'00'

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. 241 Renewed License No. NPF-8

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

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

(Southern Nuclear), dated December 22, 2021, as supplemented by a letter dated May 10, 2022, 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 license 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.

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 The Technical Specifications contained in Appendix A, as revised through Amendment No. 241, are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 90 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: November 8, 2022 Michael T.

Markley Digitally signed by Michael T. Markley Date: 2022.11.08 13:38:44 -05'00'

ATTACHMENT JOSEPH M. FARLEY NUCLEAR PLANT, UNIT 1 TO LICENSE AMENDMENT NO. 244 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-2 DOCKET NO. 50-348 TO LICENSE AMENDMENT NO. 241 JOSEPH M. FARLEY NUCLEAR PLANT, UNIT 2 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-8 DOCKET NO. 50-364 Replace the following pages of the License and Appendix A Technical Specifications (TSs) with the enclosed pages. The revised pages are identified by amendment number and contain vertical 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 TSs TSs 5.5-13 5.5-13

Farley - Unit 1 Renewed License No. NPF-2 Amendment No. 244 (2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 244, 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;

5)

Procedures defining corrective actions for off control point chemistry conditions; and

Farley - Unit 2 Renewed License No. NPF-8 Amendment No. 241 (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 byproducts, 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 Commissions 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 incorporate 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. 241, are hereby incorporated in the renewed license.

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

(3)

Delete per Amendment 144 (4)

Delete Per Amendment 149 (5)

Delete per Amend 144

Programs and Manuals 5.5 Farley Units 1 and 2 5.5-13 Amendment No. 244 (Unit 1)

Amendment No. 241 (Unit 2) 5.5 Programs and Manuals 5.5.15 Safety Function Determination Program (SFDP) (continued)

b.

Provisions for ensuring the plant is maintained in a safe condition if a loss of function condition exists;

c.

Provisions to ensure that an inoperable supported system's Completion Time is not inappropriately extended as a result of multiple support system inoperabilities; and

d.

Other appropriate limitations and remedial or compensatory actions.

A loss of safety function exists when, assuming no concurrent single failure, no concurrent loss of offsite power or no concurrent loss of onsite diesel generator(s), a safety function assumed in the accident analysis cannot be performed. For the purpose of this program, a loss of safety function may exist when a support system is inoperable, and:

a.

A required system redundant to the system(s) supported by the inoperable support system is also inoperable; or

b.

A required system redundant to the system(s) in turn supported by the inoperable supported system is also inoperable; or

c.

A required system redundant to the support system(s) for the supported systems (a) and (b) above is also inoperable.

The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by inoperability of a single Technical Specification support system, the appropriate Conditions and Required Actions to enter are those of the support system.

5.5.16 Main Steamline Inspection Program In accordance with the augmented inservice inspection program for high energy lines outside of containment, examinations of welds in the main steam lines of each unit shall be performed to provide assurance of the continued integrity of the piping systems over their service lifetime. These requirements apply to welds in piping systems or portions of systems located outside of containment where protection from the consequences of postulated ruptures is not provided by a system of pipe whip restraints, jet impingement barriers, protective enclosures and/or other measures designed specifically to cope with such ruptures.

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 AMENDMENT NO. 244 TO RENEWED FACILITY OPERATING LICENSE NPF-2 AMENDMENT NO. 241 TO RENEWED FACILITY OPERATING LICENSE NPF-8 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

DOCKET NOS. 50-348, AND 50-364

1.0 INTRODUCTION

By letter dated December 22, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21356B484), Southern Nuclear Operating Company (SNC, the licensee) submitted a license amendment request (LAR) to the U.S. Nuclear Regulatory Commission (NRC or the Commission), which requested changes to the Technical Specifications (TSs) for the Joseph M. Farley Nuclear Plant (Farley), Units 1 and 2. The LAR proposed to relocate augmented piping inspection details from TS 5.5.16, Main Steamline Inspection Program, (also referred to herein as the augmented inspection program) to the Farley Updated Final Safety Analysis Report (UFSAR) (ML20125A201). A program description will remain in TS 5.5.16. The UFSAR will be updated in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.71(e).

The supplement dated May 10, 2022 (ML22131A331), provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published the Federal Register on February 22, 2022 (87 FR 9652).

2.0 REGULATORY EVALUATION

2.1 Description of Change The licensee proposed removing the existing detailed description of the Main Steamline Inspection Program from Farley TS Section 5.5.16 and relocating it into the UFSAR. SNC also proposes to replace the description in TS Section 5.5.16 with a general program description.

The current TS 5.5.16, Main Steamline Inspection Program, provides details of the licensees augmented inservice inspection (ISI) program for high energy lines outside of containment, including which welds are examined and the extent they are to be examined each inservice inspection cycle. The TS further states that the areas subject examination are those defined in accordance with examination category C-G for Class 2 piping welds in Table IWC-2520. These

augmented inspection requirements are applied to welds in piping located outside of containment where protection from the consequences of postulated ruptures is not provided (e.g.by pipe whip restraints, jet impingement barriers, etc.). The purpose of these augmented inservice inspections is to ensure the continued integrity of the piping systems over their service life. The requirements for the augmented inspection program are contained in Appendix 3K of the Farley UFSAR. The Farley UFSAR also discusses the scope of high energy fluid systems subject to the augmented inspection program in Appendix 3K, Part II, Section D.

The licensee evaluated the requirements in 10 CFR 50.36(c) and determined that the regulations do not require augmented piping inspection detailed information to be included in the TS and can be relocated into a licensee-controlled program document.

Section 5.5.16 of the Farley TS currently states:

The three main steamlines from the rigid anchor points of the containment penetrations downstream to and including the main steam header shall be inspected. The extent of the inservice examinations completed during each inspection interval (IWA 2400, ASME Code, 1974 Edition,Section XI) shall provide 100 percent volumetric examination of circumferential and longitudinal pipe welds to the extent practical. The areas subject to examination are those defined in accordance with examination category C-G for Class 2 piping welds in Table IWC-2520.

The licensee proposes to relocate this to Section 3K, Part II, Item D of the UFSAR and replace it with a general description, as follows:

In accordance with the augmented inservice inspection program for high energy lines outside of containment, examinations of welds in the main steam lines of each unit shall be performed to provide assurance of the continued integrity of the piping systems over their service lifetime. These requirements apply to welds in piping systems or portions of systems located outside of containment where protection from the consequences of postulated ruptures is not provided by a system of pipe whip restraints, jet impingement barriers, protective enclosures and/or other measures designed specifically to cope with such ruptures. This augmented inservice inspection is consistent with Section 3K of the UFSAR.

The licensee (SNC) stated that any of the relocated information that is already contained in the UFSAR may be edited for clarity. The licensee also stated that the UFSAR will be updated in accordance with 10 CFR 50.71(e).

2.2 Regulatory Requirements and Guidance The Commissions regulatory requirements related to the content of the TSs are set forth in 10 CFR 50.36, Technical specifications. This regulation requires that the TSs include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs);

(3) Surveillance Requirements (SRs); (4) design features; and (5) administrative controls.

The regulation 10 CFR 50.36(c)(3) states that surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

The NRC staffs guidance for the review of TSs is in Chapter 16.0, Technical Specifications, of NUREG 0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light Water Reactor] Edition (SRP), March 2010 (ML100351425).

The NRC staff has prepared Standard Technical Specifications (STSs) for each of the light-water reactor (LWR) nuclear designs. The NRC staffs review includes consideration of whether the proposed changes are consistent with the applicable STSs (i.e., the current STS), as modified by NRC-approved Technical Specification Task Force (TSTF) travelers. The guidance states that comparing the change to previous STS can help clarify the TS intent, but conformance with the STS in NUREG-1431 is insufficient alone to support NRC approval. The current STSs that are applicable to the facilities are:

NUREG-1431, Standard Technical Specifications, Westinghouse Plants, Volume 1, Specifications, and Volume 2, Bases, Revision 5.0, dated September 2021 (ML21259A155 and ML21259A159, respectively).

The regulation 10 CFR 50.55a(g)(6)(ii) states that, The Commission may require the licensee to follow an augmented inservice inspection program for systems and components for which the Commission deems that added assurance of structural reliability is necessary.

The regulation 10 CFR 50, Appendix A, Criterion 4Environmental and dynamic effects design bases. states Structures, systems, and components [SSCs] important to safety shall be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents. These structures, systems, and components shall be appropriately protected against dynamic effects, including the effects of missiles, pipe whipping, and discharging fluids, that may result from equipment failures and from events and conditions outside the nuclear power unit. However, dynamic effects associated with postulated pipe ruptures in nuclear power units may be excluded from the design basis when analyses reviewed and approved by the Commission demonstrate that the probability of fluid system piping rupture is extremely low under conditions consistent with the design basis for the piping.

The FSAR is required to be maintained and updated in accordance with 10 CFR 50.71(e). The Farley UFSAR is a licensee-controlled document. Any changes to the UFSAR are subject to the regulations in 10 CFR 50.59. The regulation 10 CFR 50.59 is the process that identifies when a license amendment is required prior to implementing changes to the facility or procedures described in the UFSAR or tests and experiments not described in the UFSAR.

The NRC staff used Branch Technical Position (BTP) MEB 3-1, Postulated Rupture Locations in Fluid System Piping Inside and Outside Containment of Standard Review Plan (SRP)

Section 3.6.2, Determination of Rupture Locations and Dynamic Effects Associated with the Postulated Rupture of Piping, November 1975 included in NUREG-75/087, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, (ML042080427).

3.0 TECHNICAL EVALUATION

3.1 Evaluation of Farley Augmented ISI Requirements GDC 4 allows the exclusion of certain pipe ruptures when the probability of fluid system piping rupture is extremely low. BTP MEB 3-1 outlined the requirements for pipe break exclusion. The requirements include meeting ASME Section III, NE-1120 and the additional requirements including augmented inservice inspection (ISI) of 100 percent volumetric examination of circumferential and longitudinal pipe welds in those portions of piping (i.e., the no break region) during each inspection interval is required and is conducted in accordance with ASME Code,Section XI. SNC requested in this proposed LAR to relocate the augmented inspection program from TS to FSAR. BTP MEB 3-1 of SRP 3.6.2 provides guidelines acceptable to meet the GDC 4 requirements to ensure that SSCs important to safety be designed to against the effects of postulated pipe ruptures. For high energy piping within the containment penetration area, breaks need not be postulated in those portions of piping that meet the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME BPV Code)Section III, Subarticle NE-1120 and the additional requirements outlined in BTP MEB 3-1 of SRP Section 3.6.2. Augmented inservice inspection of 100 percent volumetric examination of circumferential and longitudinal pipe welds in those portions of piping (i.e., the no break region) during each inspection interval is required and is conducted in accordance with ASME Code,Section XI.

SNCs design provisions and the augmented inspection requirements for the no break region are contained in the current UFSARs for Farley, Units 1 and 2. The current TS 5.5.16 for Farley provides details of an augmented ISI program for the no break region. These design provisions and the augmented inspection requirements were addressed during licensing of Farley as described below.

For Farley, Units 1 and 2, breaks are not postulated for main steam piping outside containment up to and including the main steam isolation valves. The basis for this position is discussed in the current Farley, Units 1 and 2, UFSAR Appendix 3K, PART II, Postulated Break and Leakage Locations in the Main Steam Line, and the UFSAR Appendix 3K, Part II, Section D, Augmented Inservice Inspection. In addition, the current Farley, Units 1 and 2, TS 5.5.16 provides details of an augmented ISI program for high energy lines outside of containment.

These augmented inspection requirements apply to welds in piping systems or portions of piping systems located outside of containment where pipe breaks are not postulated (i.e., the break exclusion region). These augmented inservice inspections of 100 percent volumetric examination of the welds for the piping system that breaks are not postulated provide assurance of the continued integrity of the piping systems over their service life and is conformed to BTP MEB 3-1 of SRP 3.6.2.

In its letter dated December 22, 2021, SNC proposed to revise the Farley, Units 1 and 2, TSs by relocating augmented piping inspection detailed information from TS 5.5.16 to the Farley, Units 1 and 2, UFSAR Appendix 3K, Part II, Section D. A program description will remain in TS 5.5.16 for Farley. TS 5.5.16 will refer to the appropriate UFSAR section. The information proposed for relocation from the TS to the plants UFSAR is the detailed descriptions of the augmented inspection requirements. SNC stated that the specific augmented ISI program details of current TS 5.5.16 will be included in Farleys UFSAR as a concise description of the augmented inspection program. In its letter dated May 10, 2022, the licensee provided the proposed update associated with the above-mentioned LAR to reflect changes in the proposed TS to point to

Section 3K of the UFSAR for Farley, Units 1 and 2. SNC also provided the proposed UFSAR update for Farley, Units 1 and 2.

The proposed Farley, Units 1 and 2, UFSAR Appendix 3K, Part II, Section D.2 states that the three main steamlines from the rigid anchor points of the containment penetrations downstream to and including the main steam header, shall be inspected. It also states that the extent of the inservice examinations completed during each inspection interval (IWA 2400, ASME Code, 1974 Edition,Section XI) shall provide 100 percent volumetric examination of circumferential and longitudinal pipe welds to the extent practical. It further states that the areas subject to examination are those defined in accordance with examination category C-G for Class 2 piping welds in Table IWC-2520.

Based on its review of SNCs proposed UFSAR updates as described above, the NRC staff finds that the specific augmented inspection program details of current TS 5.5.16 will be included in the proposed UFSAR update for Farley conforms to BTP MEB 3-1 of SRP 3.6.2 and will continue to provide assurance of the continued integrity of the piping systems as required by the current TSs. In accordance with 10 CFR 50.71(e), the UFSAR for Farley, Units 1 and 2, shall be updated.

Based on the review of the information provided by SNC in its letter dated December 22, 2021, and supplemented by letter dated May 10, 2022, the NRC staff finds that the licensees proposed changes are acceptable, because (1) a program description will remain in TS 5.5.16 for Farley, (2) the specific augmented inspection program details of current TS 5.5.16 will be included in the proposed UFSAR update for Farley, (3) the augmented ISI program will continue to be performed per the proposed TS 5.5.16 and the proposed UFSAR update, and (5) the UFSAR for Farley will be updated in accordance with 10 CFR 50.71(e).

3.2 Evaluation of Proposed Change The NRC staff evaluated the licensees proposal to relocate the specific details related to the Augmented Inservice Inspections from the Farley TSs to the Farley UFSAR and replace it in the TSs with a general program description against the regulatory requirements cited above.

The NRC staff determined the licensees proposal to be acceptable based on the following evaluation.

In its submittal dated December 22, 2021, the licensee stated:

The proposed changes are requested to relocate detail from the TS to the plants UFSARs and to provide a consistent program description for this augmented inspection program. The TS details proposed for relocation from the TS are descriptions of inspections to be performed on plant equipment. These details are design basis information and are more appropriately contained in the respective plants UFSARs. Therefore, SNC requests relocation of these TS details to the respective plants UFSARs as described below.

Regarding the current TS 5.5.16 augmented inspection requirements, the NRC staff considered whether these requirements are required to be in the TSs by the requirements of 10 CFR 50.36. The NRC staff determined that the augmented inspection requirements currently included in Farley TS Section 5.5.16 do not meet any of the criteria in 10 CFR 50.36 that would require them to be included in the Farley TSs. Specifically, the NRC staff found that:

1) Farleys augmented inspections are inspections or examinations to ensure the continued integrity of the piping systems over their service life. These inspections do not provide any limits on important process variables or settings for automatic protective devices.

Therefore, they do not constitute safety limits or limiting safety system settings required to be included in TSs;

2) Farleys augmented inspections do not define the lowest functional capability or performance levels of equipment required for safe operation of the facility, so they do not constitute LCOs required to be included in TSs;

3) Surveillance Requirements (SRs) are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. Although not explicitly stated in 10 CFR 50.36, SRs relate specifically to TS SSCs (i.e., those that have LCOs). Licensees typically conduct numerous inspections and tests on various plant systems that are not TS SRs because they do not relate to ensuring facility operation will be within safety limits or that LCOs will be met. Accordingly, since Farleys augmented inspection program has no LCO associated with it and is not needed to assure that facility operation will be within safety limits. The augmented inspection program does not meet the criterion for a TS SR.

4) Farleys augmented ISI program is a piping examination program. Therefore, it does not constitute a design feature that if altered or modified, would have a significant effect on safety.

5) Farleys augmented ISI program does not constitute an administrative controls program as defined in 10 CFR 50.36(c)(4) because it does not relate to organization and management, procedures, recordkeeping, review, and audit, or reporting necessary to assure operation of the facility in a safe manner. However, the program will still be maintained in the Administrative Controls section of the Farley TS. The licensee is only requesting to relocate the details of the program to the UFSAR.

As noted above, 10 CFR 50.55a(g)(6)(ii) states that, The Commission may require the licensee to follow an augmented inservice inspection program for systems and components for which the Commission deems that added assurance of structural reliability is necessary.

SNCs application states that, The augmented inspections are performed in addition to required ASME Code Section XI inspections or examinations and will continue to be performed as required by the UFSARs for each plant. and that the plant systems and components to which the augmented inspections apply will not be operated in a different manner. The proposed relocation of the augmented inspection details does not involve a physical change to the plant or a change to the manner in which the plant is operated or controlled. In addition, SNC proposed to add a new general description of the augmented ISI program to the Farley TSs in the Administrative Controls Section 5.5.16. Based on this, the NRC staff concludes that the licensees proposed relocation of the inspection details does not change the licensees obligation to continue to conduct the augmented inspections and examinations of the program as described in the UFSAR and required by TS 5.5.16. Since there is no physical change to the plant, the NRC staff concludes there is no effect on the licensees compliance with Criterion 4 of 10 CFR 50, Appendix A.

The NRC staff compared the licensees proposed changes to the current STS and found them to be consistent with the format and content of the STS. In addition, since the Augmented ISI Program will continue to be performed in accordance with TS 5.5.16 and UFSAR Section 6.6.8, ensuring that the program will continue to provide assurance of the continued integrity of the piping systems, the NRC staff finds the proposed relocation of the detailed program information to the UFSAR to be acceptable. Furthermore, the requirements to conduct

the augmented inspections provided by TS 5.5.16 could not be eliminated without NRC approval. Based on the above, the NRC staff concludes that the licensee would continue to meet 10 CFR 50.36 with approval of the proposed changes to relocate the augmented piping inspection program detailed information to the licensee-controlled UFSAR.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Georgia State and Alabama State officials were notified on August 30, 2022, of the proposed issuance of the amendments. The State of Georgia official had no comments on August 30, 2022. The State of Alabama official had no comments on August 30, 2022.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. 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 on February 22, 2022 (87 FR 9652), and there has been no public comment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 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) there is reasonable assurance that 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.

Principal Contributors: Renee Li, NRR/DEX/EMIB Rob Elliott, NRR/DSS/STSB Date: November 8, 2022

ML22308A059 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DEX/EMIB/BC NRR/DSS/STSB/BC NAME JLamb KGoldstein SBailey VCusumano DATE 10/12/2022 10/14/2022 10/18/2022 10/12/2022 OFFICE OGC - NLO NRR/DORL/LPL2-1/BC NRR/DORL/LPL2-1/PM NAME LShrum MMarkley JLamb DATE 10/18/2022 11/8/2022 11/8/2022