ML24344A084
| ML24344A084 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/05/2024 |
| From: | Turner Z Plant Licensing Branch II |
| To: | Sparkman W Southern Nuclear Operating Co |
| Turner, Zachary | |
| References | |
| EPID L-2024-LLA-0091 | |
| Download: ML24344A084 (1) | |
Text
From:
Zach Turner To:
Sparkman, Wesley A.
Cc:
Joyce, Ryan M.; John Lamb; Michael Markley; Vijay K Goel; Nadim Khan; Khadijah West; Shivani Mehta (She/Her); Wendell Morton
Subject:
For Your Action - RAIs - Farley Units 1 and 2 - TSTF-500 LAR - EPID L-2024-LLA-0091 Date:
Thursday, December 5, 2024 3:05:00 PM Attachments:
RAI-Farley TSTF-500.pdf
- Wes,
By letter dated June 28, 2024 (ADAMS Documents and Access Management System (ADAMS)
Accession No. ML24180A204), Southern Nuclear Operating Company (SNC, the licensee) submitted a license amendment request (LAR) for Joseph M. Farley Nuclear Plant (Farley), Units 1 and 2. The proposed LAR would revise the Technical Specifications (TS) to adopt Technical Specifications Task Force (TSTF) Traveler TSTF-500, Revision 2, "DC Electrical Rewrite - Update To TSTF-360 (ADAMS Accession No. ML111751792)."
To complete its review of the application, the U.S. Nuclear Regulatory Commission (NRC) staff requests additional information (RAI) as discussed in the attachment to this email. On November 21, 2024, the NRC staff provided SNC the draft RAI questions to ensure that they are understandable, the regulatory basis is clear, to ensure there is no proprietary information, and to determine if the information was docketed previously. A clarifying call was held on December 5, 2024.
This request is now released formally with a 46-day calendar response period from the date of this email (due January 20, 2024). If you have any questions, you may contact me at 301-415-2258.
Very Respectfully, Zach Turner, Project Manager Nuclear Regulatory Commission Division of Operating Reactor Licensing NRR/DORL/LPL2-1 (301) 415-2258 Office: OWFN-07C12 Mail Stop: O-08 B01A
1 REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FARLEY - ADOPTION OF TSTF-500 REV 2 DC ELECTRICAL REWRITE SOUTHERN NUCLEAR OPERATING COMPANY FARLEY, UNITS 1, 2 DOCKET NO. 05000348, 05000364 ISSUE DATE: 12/05/2024
Background
By letter dated June 28, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24180A204), Southern Nuclear Operating Company (SNC) (the licensee) submitted a license amendment request (LAR) for the Joseph M. Farley Nuclear Plant (FNP), Units 1 and Unit 2. The LAR would revise the Technical Specifications (TS) to adopt Technical Specifications Task Force (TSTF) Traveler TSTF-500, Revision 2, "DC Electrical Rewrite - Update To TSTF-360 (ADAMS Accession No. ML111751792)."
Specifically, the licensee proposed changes to the TS requirements related to direct current (DC) electrical systems in TS limiting condition for operation (LCO) 3.8.4, DC Sources -
Operating, LCO 3.8.5, DC Sources - Shutdown, and LCO 3.8.6, Battery Cell Parameters.
Additionally, the licensee proposed to add a new Battery Monitoring and Maintenance Program to TS Section 5.5, Programs and Manuals. TS changes include the relocation of several Surveillance Requirements (SRs) to the new licensee-controlled, Battery Monitoring and Maintenance Program.
The NRC staff has determined that additional information is needed to complete its review.
Regulatory Basis:
Title 10 of the Code of Federal Regulations, Part 50 (10 CFR 50), Section 36, Technical Specifications, requires, in part, that the operating license of a nuclear production facility include TS. Pursuant to 10 CFR 50.36(c), TS are required to include items in the following five categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) LCOs; (3) SRs; (4) design features; and (5) administrative controls. The LAR relates to changes in the LCOs, SRs, and administrative controls.
Question 1 EEEB RAI-1 In the LAR enclosure, the licensee proposes relocating the requirements of TS Table 3.8.6-1, Battery Cell Parameters Requirements, to a new licensee-controlled program in TS 5.5.21, Battery Monitoring and Maintenance Program, added under the TS Section 5.5, Programs and Manuals.
TSTF-500, Section 4.5.1 states, in part, that TS Table 3.8.6-1 specifies the battery cell parameters requirements, including electrolyte level, float voltage, and specific gravity. The Category A and B values of TS Table 3.8.6-1 represent appropriate monitoring levels and appropriate preventive maintenance levels for long-term battery quality and extended battery life. This provides adequate assurance that the battery parameter values will continue to be controlled, and actions will be implemented if the battery parameter values are not met.
In its submittal, SNC's proposed TS 5.5.21 would include provisions to take actions to restore battery cells if float voltage is <2.13 V as compared to <2.08 V considered in the exiting TS
2 Table 3.8.6-1 under Category A or Category B values. Please justify the basis for increasing the minimum float cell voltage from 2.08 V to 2.13 V.
Also, provide justifications for any differences between the existing limits for the average electrolyte temperature, battery connection resistance, battery terminal voltage and specific gravity as considered in the TS Table 3.8.6-1 and the limits which will be controlled in accordance with the proposed new TS 5.5.21, Battery Monitoring and Maintenance Program.
Question 2 EEEB RAI-2 The proposed TS 3.8.6, Condition A, would require SNC to restore affected cell voltage 2.07 V if one Auxiliary Building battery or one required Service Water Intake Structure (SWIS) battery with one or more battery cells float voltage is <2.07 V.
Please provide the basis of minimum cell float voltage of 2.07 V value.
Question 3 EEEB RAI-3 On Page E-10 of its submittal, SNC states, in part, that:
Placing the auxiliary building swing charger or SWIS standby charger in service that fully meets the SR acceptance criteria becomes the required charger and; thus, the one removed from service is no longer a required charger and no longer governed by the TS Surveillance (in accordance with the provisions of SR 3.0.1). Alternatively, with the proposed addition of TS 3.8.4 Actions A and D, proposed SR 3.8.4.2 can be performed with spare or redundant charger(s) while they are in compliance with Action A or D.
Please clarify whether the existing SR 3.8.4.6 (proposed renumbered as SR 3.8.4.2) on battery chargers also applies to spare chargers and specify at which frequency.
Question 4 EEEB RAI-4 TSTF-500, Section 4.7.2, Commitments, specifies the following regulatory commitments:
- 1. The [2] amp float current value is an indication that the battery is [95] percent charged. The licensee must provide a regulatory commitment to maintain a [5] percent design margin for the batteries.
- 2. The licensee-controlled program, required and described in TS Section 5.5, "Programs and Manuals," and titled the "Battery Monitoring and Maintenance Program," will require verification of the selection of the pilot cell or cells when performing SR 3.8.6.5.
In its submittal, SNC states that, This letter contains no regulatory commitments. The SNC submittal also states that, SNC is not proposing any variations or deviations from the TS changes described in the TSTF-500, Revision 2, or the applicable parts of the NRC staffs model SE referenced in the Federal Register on September 1, 2011 (76 FR 54510) as supplemented on November 8, 2011 (76 FR 69296).
In Attachment 2 of the LAR, the licensee stated that the FNP FSAR will be changed or verified to describes how a 5 percent design margin for the batteries corresponds to a 2 amp float current value indicating that the battery is 95 percent charged. Additionally, in the Enclosure of
3 the LAR, the licensee states that the plant procedures will be updated to require verification of the selection of the pilot cell or cells when performing proposed SR 3.8.6.5.
Please explain the deviation regarding regulatory commitments and describe whether the two regulatory criteria listed in TSTSF-500, Section 4.7.2 by making conforming changes in the FSAR, as specified in the LAR Attachment 2 and updating the plant procedures when performing proposed SR 3.8.6.5, as described in TSTF-500, Section 4.7.2.
Question 5 STSB RAI-1 In Section 2.1.3 of its submittal regarding proposed changes to TS 3.8.4, SNC states, in part, that:
The [Completion Time (CT)] for Required Actions A.1 and D.1 are proposed with the option to calculate a [Risk-Informed Completion Time (RICT)] by including OR In accordance with the Risk Informed Completion Time Program, consistent with current licensing basis provided in existing Required Actions A.1 and B.1 CTs. The guidance from TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b (Ref. 4) allows for application of a RICT provided a modeled system and its components could be used in calculating a RICT.
The proposed changes adding new Farley TS 3.8.4.A.1 and D.1 are both similar to standard TS 3.8.4.A.1. However, in TSTF-500 and in TSTF-505, Revision 2, there is no option to add, OR in accordance with the Risk Informed Completion Time Program, to standard TS 3.8.4.A.1.
Proposed new TS 3.8.4 Required Actions A.1 and D.1 state, Restore battery terminal voltage to greater than or equal to the minimum established float voltage. Section 2.3, "Scope," of TSTF-505, Revision 2, lists the exclusion criteria which state, in part, 18. [] the traveler will only modify Required Actions that specify that a system be restored to OPERABLE status, that require an instrument channel to be placed in trip, or that require isolating an inoperable isolation valve.
Although the Required Actions use the term restore, the proposed new TS 3.8.4 A.1 and D.1 are not actions that would restore the system to operable status as required by limiting condition for operation 3.8.4 (e.g., restoring the inoperable required battery charger on one Auxiliary Building DC electrical power subsystem would meet the limiting condition for operation). Please justify these variations from TSTF-500 and TSTF-505, Revision 2, to add risk informed completion times, or revise the proposed changes.
OFFIC E
NRR/DORL/LPL2
-1/PM NRR/DORL/LPL2
-1/BC NRR/DEX/EEEB/B C
NRR/DSS/STSB/B C
NAME ZTurner MMarkley WMorton SMehta DATE 11/21/2024 11/21/2024 11/20/2024 11/20/2024