Text

Proposed Tech Specs Based on NUREG-1431
	ML20100G037
Person / Time
Site:	Vogtle
Issue date:	02/19/1996
From:	; GEORGIA POWER CO.
To:	;
Shared Package
ML20100G035	List: ML20100G033; ML20100G037;
References
	RTR-NUREG-1431 NUDOCS 9602220321
	Download: ML20100G037 (46)
	v • d • e

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Although the FSAR already contains most of the design information desc ove, the licensee committed by letter dated (Jan , 995],to confirm that ils are appropriately refle e FSAR, the TRM, i

the improved TS Bases or e will b ed in the next required

., update of these documents. The has also committed to maintain an auditable record of, an mplementation e for, the procedure changes associated wit evelopment of the improved TS. ensee will also mainta ocumentation of these changes in accordance wit rd j _

ion requirements in the OA plan and the_TRM.

The staff has concluded that appropriate controls have been identified

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for all of the current specifications, information, and requirements that are being moved to licensee-controlled documents. Until incorporated in the FSAR and procedures, changes to these provisions will be controlled in accordance with the applicable current procedures that control these documents. The NRC will audit the relocated provisions following implementation to ensure that an appropriate level of control has been achieved. The staff has conclud,ed that, in accordance with the Final Policy Statement, sufficient regulatory controls exist under the regulations, particularly in 10 CFR 50.59. Accordingly, these specifications, information, and requirements, as described in detail in this safety evaluation, n.ay be removed from the CTS'and placed in the FSAR or other

licensee-controlled documents as specified herein.

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Vogtle Units I and 2 Improved STS Conversion l l

9602220321 960219

PDR ADOCK 05000424 P PDR

5.S.12, EFplosive. Ges and Sforagc Tan K Radimhyify Mc>M Q Use and.A plication

The requirements of CTS 3/4.11.2.5 and 3/4.3.3. 10 are being $. J t_ dphtet;[

W/M an administrative controls program, improved TS . .;, T. ;... .., ::h:t ,

L The use L :;.c ; it;'d: C::t:L:.::t,' O,.i w.. :;;;d: t: CT C.7.'.:. l of the system name in this program specification does et r qui a a definition. Thus, the existing requirements for the gaseous wastre 4

- processing system are not reduced by omitting this definition. See Section 5 of this safety evaluation for additional discussion of l improved TS i (6) The definitions MEMBER OF THE PUBLIC and UNRESTRICTED AREA are contained in 10 CFR 20.1003. Thus, including them in the CTS is redundant. i Therefore, these definitions can be omitted from the improved TS, consistent with the STS.

! (7) The requirements contained in the definition 0FFSITE DOSE CALCULATION MANUAL (ODCM) has been placed in improved TS 5.5.1, "Offsite Dose Calculation Manual (ODCM)," in conforman'ce with the STS. Therefore, it

is not necessary to include ODCM as a defined term in the improved TS.

, (8) Existing definitions PURGE - PURGING, VENTILATION EXHAUST TREATMENT SYSTEM, VENTING, and SOURCE CHECK have been deleted in conformance with l the STS because they are not used as defined terms in the CTS.

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(9) Existing definition PROCESS CONTROLS PROGRAM (PCP)has been removed from the CTS along with the associated administrative controls program specified in CTS 6.12, " PROCESS CONTROLS PROGRAM (PCP)," to conform with the STS. These requirements have been placed in the FSAR. See Section III.5.2 of this safety evaluation for additional discussion of this i change.

4 (10) Existing definition REPORTABLE EVENT has been deleted because it is redundant to the detailed definition of a reportable event in 10 CFR !

50.72 and 50.73. This change will have no effect on current reporting

practices at VEGP and does not reduce any reporting requirements.

i (11) Existing definition SITE BOUNDARY is not needed in the improved TS because it has been replaced with an equivalent description in improved TS 4.1.1, " Site and Exclusion Area Boundaries (EAB)," in conformance i with the STS.

Although removal of these terms from the list of definitions is considered less-restrictive, the relaxations of existing specifications containing these terms is brought about by changes to the CTS discussed elsewhere in this Vogtle Units 1 and 2 Improved STS Conversion j I

l rDRAfi Use and Application j i

safety evaluation. Therefore, omission of these definitions from the improved l TS does not, by itself, reduce existing restrictions on plant operation; therefore, these changes are acceptable.

, 1.3 More Restrictive Requirements

- The licensee, in electing to implement STS Section 1.1 definitions, proposed '

the following more restrictive condition.

(1) The existing definition of SDM has been made more restrictive by adding the requirement to change the fuel and n.oderator temperatures to the hot zero power temperatures when the unit is in MODE 1 or 2. This ensures

. that the power defect due to shutting down the reactor from MODE 1 or 2 is accounted for in the SDM.

This added requirement is consistent with current practice at VEGP, conforms to the STS, and is acceptable.

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1.4 Sigr}ificant Differences from the STS In electing to adopt the STS, the licensee proposed e number of definitions that do not conform to the corresponding STS definit %ns. These definitions are CHANNEL CALIBRATION, CHANNEL OPERATIONAL TEST, TRIP ACTUATING DEVICE OPERATIONAL TEST, and the PTLR. These differences are the following:

i (1) The licensee proposed to omit from the CHANNEL CALIBRATION definition the language in the STS definition regarding the method of calibrating temperature sensing elements (resistance temperature detectors (RTDr,) and thennocouples) because it is not part of the CTS definition.

The existing definition of CHANNEL CALIBRATION does require calibration of the sensors, but does not specify the technique for

calibrating RTDs or thermocouples. Whether the RTDs or thermocouples are calibrated using cross calibration techniques (as specified in the

) STS definition) or bath inanersion 3rd b tk h .=;is considered by the licensee to be irrelevant to the definition. The licensee considers both techniques equally valid, .and thus concludes it is sufficient for the purpose of the definition to simply require that they be calibrated.

This difference is based on maintainig the flexibility of the 4 existing definition and the licensee's decision not to backfit the STS language in question. Because the proposed definition is consistent with the current requirement, this difference is acceptable.

(2) The licensee proposed to omit the STS requirement to include the display in the definitions of the following types of instrumentation

Vogtle Units 1 and 2 Improved STS Conversion

O Administrative Changes LCOs, ACTI i to be OPERABLE in MODES 1 and 2 as specified in improved TS LCO 3.1.4,

" Rod Group Alignment Limits," (and also in corresponding CTS LCO 3.1.3.1) this action requirement is deleted. This does not change existing requirements because the definition of MODE 3, 4, and 5 requires the reactor to be c 1% shutdown (k, ,,, 0.99). These administrative changes do not reduce existing requirements.

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(5) In the event that the requirements CTS 3/4.1.3.1, ACTION b (one inoperable, but trippable, rod) were not met within the r,pecified Completion Times, CTS LCO 3.0.3 would require placing the plant in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This requirement is retained as ACTION C of improved TS 3.1.4 to conform to the presentation in the STS.

(6) CTS 4.1.3.2, to verify that individual rod positions are within the alignment limit, has been retained as improved TS SR 3.1.4.1, with descriptive procedural information relocated to the Bases (as noted in Table 1), and with wording changes to conform to the presentation of corresponding STS SR 3.1.5.1.

3.1.5 Shutdown Bank Insertion Limits (7) Improved TS LCO 3.1.5, " Shutdown Bank Insertion Limits," applies to l shutdown banks, not to individual shutdown rods, as does corresponding l

CTS 3.1.3.5, " Shutdown Rod Insertion Limits." Instead, individual rods (both in shutdown banks and in control banks) are addressed by improved :

TS LCO 3.1.4, " Rod Group Alignment Limits." This presentation change is consistent with corresponding STS LCO 3.1.5, " Rod Group Alignment i' Limits," and STS LCO 3.1.6, " Shutdown Bank Insertion Limits."

Similarly, CTS 3.1.3.6, " Control Rod Insertion Limits," which already applies to control banks, not individual rods, is entitled i " Control Bank Insertion Limits" in corresponding improved TS LCO 3.1.6, l also consistent with the STS presentation. j, y 7 (8) The ACTION of CTS 3/4.1.3.5 contains an except ion to taking the actions I

( required. This exception is when performing t ie 92-day Frequency rod freedom-of-movement-verification test, CTS 4.1.0.2, corresponding to improved TS SR 3.1.4.2. Because this exception permits operation with the LCO not met, it is equivalent to saying the LCO does not apply.

Therefore, this exception is presented as a Note in the Applicability of improved TS 3.1.5, consistent with corresponding STS 3.1.6.

A similar change has been made to the ACTION and Applicability of CTS 3/4.1.3.6, " Control Rod Insertion Limits,' in corresponding improved TS 3.1.6, " Control Bank Insertion Limits."

(9) Required Actions have been added to the ACTIONS of CTS 3/4.1.3.5 and CTS i 3/4.1.3.6 to verify that the SDM is within limit or to initiate boration Vogtle Units 1 and 2 Improved STS Conversion i

I

L i Administrative Changes DRAFT LCOs, ACTIONS, and SRs administrative change in presentation of the current requirement, and is [

acceptable.

4 3.1.3.2 Power Distribution Limits Current power distribution limit specifications that are being retained in the

_ improved TS have been administrative 1y reformatted and reorganized to conform i

to the presentation of STS Section 3.2, as surmarized in Table 2-2.

Discussions of the administrative changes that are significant follow. l

)

j 3.2.1 Heat Flux Hot Channel Factor (Fe(Z)) j

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(1) CTS 4.2.2.1 specifies an exception to the MODE entry restrictions of CTS 4.0.4 for CTS surveillances for Fq(Z). Because the SR Frequencies of i the F9(Z) surveillances retained in improved TS 3.2.1 specify ,

performance after entry into MODE 1, an exception to corresponding

improved TS SR 3.0.4 would be superfluous. Because the existing :

! allowance is effectively unchanged, omission of this exception is considered an administrative change.

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l. (2) The requirements of CTS 4.2.2.2.f have been retained as improved TS SR j 3.2.1.2 consistent with the STS. The term " penalty" was added to emphasize that the factor specified in the COLR is used to offset '

possible increases in F q(Z) between surveillances. This change l l"

clarifies the intent of the existing requirement and is, therefore, .

4 purely administrative.

! i 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor (F%)

(3) CTS 3/4.2.3, ACTION c, has been retained as Required Action A.3 of

improved TS, in confomance with STS 3.2.2, Required Action A.3. In j addition, a Note has been added to clarify that Required Action A.3 is

only required if THERMAL POWER has to be reduced to less than 50% RTP to

comply with Required Actions A.1.1 or A.I.2.1. Because this Note serves a to clarify the intent of the existing action requirement, the addition j of this" Note is considered an administrative chanaa.

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-- nu Mata differs from the car- gndi. 3 nne in% STS. ^

5,

,7 See Subsection 3. ' d Fu t III or sni. d+y avaluation for

edigsssa4wn o is difference. j l 1

(4) CTS 4.2.3.1 specifies an exception to the MODE entry restrictions of CTS i 4.0.4 for the CTS surveillance for F"m. Because the SR Frequencies of the F"a surveillance, CTS 4.2.3.2, specify performance after entry into MODE 1, an' exception to corresponding improved TS SR 3.0.4 would be superfluous. Because the existing allowance is effectively unchanged, a

Vogtle Units 1 and 2 Improved STS Conversion

,, . . _ _ . . .~ - ._a __

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!' Administrative Changes DRH LCOs, ACTIONS, and SRs The Action Statements currently specified by CTS Table 3.3-1 are given as' ACTIONS (Conditions, Required Actions and Completion Times) in improved TS 3.3.1. The ACTIONS applicable to each RTS instrument F function are specified in improved TS Table 3.3.1-1. j i The general requirements of CTS 4.3.1.1 and 4.3.1.2, to perform

all applicable surveillances, including response time testing (improved i TS SR 3.3.1.15), have been replaced by specific requirements for each j l ..

RTS instrumentation function. All Surveillance Requirements are given !

in the STS format following the LCO and ACTIONS in improved TS 3.3.1. !

i Each Surveillance Frequency is specified as part of the associated Surveillance Requirement. Similarly, each SR Note in CTS Table 4.3-1 is I i stated with the associated SR instead of in a list at the end of the table. The Surveillance Requirements applicable to each RTS instrument l function are specified in improved TS Table 3.3.1-1. In addition, the j word analog, has been deleted from the defined term ANALOG CHANNEL i OPERATIONAL TEST (ACOT). i The TOTAL NUMBER OF CHANNELS column in CTS Table 3.3-1 has been

! revised and renamed the REQUIRED CHANNELS column in improved TS Table l

3.3.1-1.'When one or more required instrument channels, as specified in i this column, are inoperable for a given function, the ACTIONS of improved TS 3.3.1 that would apply would be determineu from the i CONDITIONS column of Table 3.3.1-1.

1 The MINIMUM CHANNELS OPERABLE column of CTS Table 3.3-1 has been eliminated because the ACTIONS for each RTS instrument function are no longer referenced from it. Instead the ACTIONS are referenced from the i new REQUIRED CHANNELS and CONDITIONS columns of improved TS Table 3.3.1-1. -

' Numbered discussions of specific administrative changes that are significant follow. The improved TS instrument function or functions are listed in italics before each discussion or discussions that apply.

i 3.3.1.2.a Power Range Neutron Flux - High l (2) Notes 2 and 4 of CTS Table 4.3-1, modify the daily channel calibration (calorimetric comparison) of the power range neutron flux - high RTS l trip function. This surveillance has been retained as improved TS SR

3.3.1.2 in'which these existing notes have been incorporated,-whdein the i following omissions. W%

The exception to CTS 4.0.4 in existing Note 2 has been omitted j 7.,_;. J because the Frequency of SR 3.3.1.2 is conditional (Note 2 of l

l SR 3.3.1.2). As described in the improved TS Section 1.4, " Frequency," a

] conditional Frequency does not become due until the specified conditions

are met-(i.e., THERMAL POWER 15% RTP).

Existing Note 4, which excludes neutron detectors from channel

! calibration, has been omitt , because SR 3.3.1.2 does not specify a channel calibration but si ly requires a comparison with a calorimetric

); Vogtle Units 1 and 2 Improved STS Conversion

l Administrative Changes LCOs, ACTIONS, and SRs i heat balance. Note 1 of SR 3.3.1.2 requires adjusting indicated power to within 2% of the calorimetric power. i This change is considered administrative because it clarifies the I intent of the existing Notes while retaining the existing Surveillance l Requirement.

3.3.1.2.b Power Range Neutron Flux - Low; 3.3.1.3 Power Range Neutron Flux Rate - High Positive Rate; 3.3.1.6 Overtemperature AT; 3.3.1.7 Overpower AT; Pressurizer Pressure - High; and 3.3.1.B.b 3.3.1.13 Stean Generator Water level - Low Low (3) ACTION E of improved TS 3.3.1 is a new ACTION applicable to RTS instrument functions previously associated with ACTIONS 2 or 6 of CTS Table 3.3-1 and for which the action to be in Mode 3 is appropriate to remove the unit from the MODE of Applicability for the affected

- function. The addition of the requirement to be in Mode 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is in accordance with the STS. This Required Action provides an alternative to CTS 3.0.3 if any of the other REQUIRED ACTIONS for the affected functions can not be completed in the allotted time. Thus, this change is considered administrative.

l 3.3.1.4 Intermediate Range Neutron Flux < '

(4) The MODE 2 Applicability for the intermediate range instr umentation has been adjusted to accommodate the presentation of associat ed ACTION G and ACTION H in improved TS 3.3.1. Specifically, MODE 2 has been divided into al P-6 condition (new Applicability Note c) and a hP-6 condition (new Applicability Note d). This change conforms to the STS which contains separate actions for the intermediate range instrumentation above and below P-6. (Note that ACTION G is a new more restrictive requirement. See Subsection 3.3.3.1 of Part III of this safety evaluation for additional discussion.)

3.3.1.5 Source Range Neutron Flux; and 3.3.8 High Flux at Shutdown Alarn (HFASA))

(5) Improved TS 3.3.1.5 contains a new LCO requiring on% une source range neutron flux channel to be OPERABLE, instead of two, in MODES 3, 4, and 5 provided the RTBs are open (Applicability Note e). Currently, the LCO for corresponding RTS instrument function 6.b of CTS Table 3.3-1, does not explicitly 1, tate the OPERABILITY, action, and surveillance requirements on source range instrumentation with the reactor trip breakers (RTBs) open in MODES 3, 4, and 5. It only specifies requirements with the RTBs closed.

Vogtle Units 1 and 2 Improved STS Conversion

i DRAFTi Administrative Changes LCOs, ACTIONS, and SRs 4

this change groups the SRs to the most appropriate function for OPERABILITY concerns.

The Frequencies of these SRs have also been changed to be in

- accordance with applicable portions of CTS Notes 3 and 6 (clarifying that monthly and quarterly mean 31 EFPD and 92 EFPD respectively for 4 these surveillances). In addition, the new SRs do not require the 4.0.4

_ exception given in CTS Notes 3 and 6, because these SRs are conditional with the Frequency specified with the required power level in the SR y itself.

l Finally, the exclusion for the neutron detectors from the Channel

Calibration given by CTS Note 4 has been adopted as Note 2 of SR

3.3.1.6. This is a >propriate, bec

-eeMbpstede adjus1ed pernHlon %t.dehuse theCAL.I6RATICAl.

a CMMEL neYtron detectors c J All these changes are administrative, are consistent with the STS, and are acceptable.

3.3.1.8.s Pressurizer Pressure - Low; 3.3.1.9 Pressurizer Water Level - High; 3.3.1.10.b Reactor Coolant Flow - Low - Two Loops i 3.3.1.11 Undervoltage RCPs; and 3.3.1.12 Underfrequency RCPs 1

, (7) ACTION M of improved TS 3.3.1 has been developed from ACTION 6 of CTS Table 3.3-1, for RTS instrument functions that have an Applicability of

MODE 1 > P-7 (low power reactor trips block). A separate ACTION for l these functions is appropriate because the, default action (to remove the l

unit outside the Applicability) that must be added to each ACTION to conform to the STS, is the same -- reduce power < P-7 if the inoperable j channel has not been placed in trip within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This presentation j' enhancement of the existing action requirements is considered an

administrative change to conform to the STS.

I j 3.3.1.B.a Pressurizer Pressure - Low l (8) The time constant Note ** of CTS Table 2.2-1 for the pressurizer i pressure-low function has been moved to improved TS Table 3.3.1-1 for this function. In the improved TS all information pertaining to the RTS j instrument functions appear on Table 3.3.1-1. This change is l administrative and consistent with the STS.

3.3.1.17 Reactor Trip Breakers (RTBs) l (9) A clarifying Note (Note k) has been added to the RTB function. Note k l specifies that RTB bypass breakers racked in and closed are included in the instrument function to meet the LC0 requirement for 2 trains. The bypass breakers are counted as one of the required trains and all

! Vogtle Units I and 2 Improved STS Conversion l

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E

=

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i 7k f werop 6*t n '

LCOs, ACTIONS, and SRs Administrative Changes 9%g,g l by this specification, this deletion is an administrative improvement in the presentation of existing requirements. Therefore, removal of these redundant require ments is acceptable.

bne

(26) CTS Table 3.3-3 9 otationb,adeItingthepoweroperationsetpointof 4

the containment area (ventilasion isolation) radiation monitors, has

. - beenrevisedtod{1etethere"erences to.an initial setpoint and the I

first fuel cycle. The setpoit t is s 50 times background level during 1 i power operation. 3Mf*Notejue been placed in corresponding Table l 3.3.6-1 as Note (d) and the setpoint has been placed directly in the )

l Trip Setpoint column. In addition, Note (d) states that the setpoint

applies during MODES 1, 2, 3, and 4, and not just during power operation )

, as currently required. ;

i CTS Table Notation a has been retained as improved TS Table 3.3.6- '

i 1, Note (c), and states that the s 15 mr/hr setpoint applies during i CORE ALTERATIONS and movement of irradiated fuel assemblies within .

! containment. These words clarify the intent of the existing requirement :

l of "during refueling operations."

The revision to both of these Notes is considered an administrative clarification of the current requirements. It is, l ,

therefore, acceptable.

l l (27) CTS Table 3.3-3 Notation c references CTS 6.7.4.f.7 for the setpoint of I l the gaseous, particulate, and iodine monitors. Corresponding improved !

l TS 5.5.4.h and 5.5.4.1 replace CTS 6.7.4.f.7. This Note has been retained as Note (b) of improved TS Table 3.3.6-1 and has been revised i to reference the new specification. This is purely an administrative j change. ;

3.3.7 Control Roon Energency Filtration System (CREFS) Actuation i Instrumentation

! (28) CTS 3/4.3.2.10, ESFSAS Instrument Function 10, "CREFS," has been

! reformatted to conform to the presentation of STS 3.3.7, as indicated in j Table 2-3. The new Required Channels column in improved TS Table 3.3.7-1 replaces the Minimum Channels OPERABLE column of corresponding CTS Table 4

3.3-2 for the CREFS actuation function. It has been is revised to match the fomat and presentation of the STS and also for the VEGP design

! (common control room, 4 100% capacity trains, with two air intakes, each l monitored by a redundant set of radiation detectors). Since the CTS contains specific action requirements for up to 4 channels of actuation j logic and 4 channels of radiogas monitors inoperable, a total of 4 of

each of these channels is specified to be OPERABLE in the table. The Note "(2 per unit)" has been added to clarify that the total number is made of 2 redundant sets of channels. Current licensing basis only j requires a total of 1 manual initiation channel operable (each train is Vogtle Units 1 and 2 Improved STS Conversion k

k

_ _ _ _ . _ _ _ _ . _ _ _ = _ _ _ _ _ _ _ _ - - _ - _ _ _ _ _ .

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DRAFL Administrative Changes. LCOs, ACTIONS, and SRs Subsection 3.2.3.6 of Part III of this safety evaluation. In addition, ,

i the new ACTIONS contain two other Notes that clarify existing :

j requirements. Note 2 allows each air lock to be treated independently ,

in the ACTIONS. And Note 3 requires entering the containment specification action requirements if air lock leakage exceeds the overall containment leakage rate limit, L,. Because these Notes are j consistent with existing requirements and plant operating practices,

these changes are purely administrative.

! (4) CTS 4.6.1.1.b has been deleted because it requires verifying compliance ,

! with the requirements of CTS 3/4.6.1.3 for the containment air locks, i which is redundant and unnecessary. In addition, no Frequency for this

' surveillance is specified. This change is purely administrative because the appropriate CTS OPERABILITY requirements, ACTIONS, and Surveillance Requirements for the air locks have been retained in corresponding l

improved TS 3.6.2.

1 l (5) The acceptance criteria for air lock seal leak testing contained in CTS I

4.6.1.3.a 30 seconds(seal leakagepressure at a constant is less than of 37 0.01 L,)when psig has been movedmeasured for at least to improved

! TS 5.5.17, "CLRT Program." This change is purely administrative and conforms to the.STS presentation of these requirements M e Option B of j hs. i;tf.

l 0 Appendix J h=Lenill han been adopted a+ Impined Ts imp %

3.6.3 Containment Isolation Valves (CIVs)

I CTS 4.6.1.1.a and associated Note *, to verify inoperable penetrations :

(6)

are isolated, have been reworded and moved to improved TS 3.6.3. CTS

[ 4.6.1.1.a has become SR 3.6.3.3 for manual valves and blind flanges

outside containment, and Note * (except for the last sentence) has ;

1 become SR 3.6.3.4 for manual valves and blind flanges inside

! containment.

j In addition, the requirement of the last sentence of CTS 4 4.6.1.1.a. to verify penetrations isolated by de-activated automatic valves, has been moved to ACTION A of improved TS 3.6.3 as Required Action A.2. This presentation clarifies and directly connects the verification of de-activated automatic valves to an inoperable isolation i '

valve. By making this verification a Required Action, the potential to miss a required verification, resulting from an inoperable automatic isolation valve that'is not part of the plant procedure for SR 3.6.3.3, has been reduced. This change in presentation of these existing j requirements is purely administrative.

i i (7). The last sentence of Note

to CTS 4.6.1.1.a regarding the blind flange l on the fuel transfer canal, has been retained as Note 2 of improved TS

SR 3.6.3.4, for verifying isolation devices inside containment. This is i

Vogtle Units 1 and 2 Improved STS Conversion i

RWI Administrative Changes LCOs, ACTIONS, and SRs a plant-specific Note that is consistent with the CTS. In addition, editorial changes for clarity and conformance to the STS presentation of Notes have been made. This change is purely administrative because the existing level of restriction has been retained.

(8) The requirements of CTS 3/4.6.1.7 for containment ventilation isolation

- valves have been placed with the requirements of CTS 3/4.6.3 for all other CIVs in improved TS 3.6.3, " Containment Isolation Valves." This change places all containment isolation valves in one specification and is consistent with the STS. This change to conform to the STS presentation of CIV requirements is purely administrative.

(9) Four Notes have been added to the ACTIONS of CTS 3/4.6.3 and CTS 3/4.6.1.7 which have been combined in improved TS 3.6.3, and which apply to all containment isolation valves, including the containment purge and exhaust valves. Note 1 provides an allowance to open containment isolation valves required to be closed (except for the 24" purge valves) under administrative controls. (This relaxation of the current requirements, which contain no provision for unisolating inoperable penetration flow paths under administrative control, is also discussed in Subsection 3.2.3.6 of Part III of this safety evaluation.) Notes 2, 3, and 4 are purely administrative changes because they only clarify the intent of the existing requirements. These clarifications are (a) to treat each penetration flow path separately, (b) to enter the affected system specification made inoperable by isolation of containment per.etration flow paths in accordance with the ACTIONS of Specification 3.6.3, and (c) to enter Specification 3.6.1 if CIV leakage exceeds containment leakage limits.

3.1.3.7 Plant Systems Current plant system specifications that have been retained in the improved TS have been administrative 1y reformatted and reorganized to conform to the presentation of STS Section 3.7, as indicated in Table 2-7. Discussions of the administrative changes that are significant follow. The improved TS plant system specification is given in italics before the discussion or discussions that apply.

3.7.1 Main Steam Safety Valves (MSSVs) r SY00' (1) A note has been added to the ACTIONS of CTS 3/4.7.1 .1, consistent with l

the STS, to clarify that each MSSV is to be treated! Because no technical change is involved, the addition of this Note is purely V administrative.

Vogtle Units 1 and 2 Improved STS Conversion

l'<

'DRAFL

Less Restrictive Requirements LCOs, ACTIONS, and SRs j (3) Removal of Applicability Condition of During Movement of Loads Over

Irradiated Fuel

\

j The requirements of several specifications in the CTS are applicable i during the movement of loads over irradiated fuel. The licensee has proposed to delete such requirements from these specifications. These i current specifications are listed under.the corresponding -

]

y specification (s) in the improved TS.

I 3 mproved TS 3.3.6, Containment Ventilation Isolation Instrumentation:

h.5 2. - i,. ...c.u, ESFAS Instrumentation - Containment Ventilation Isolation; Table 3.3-2, Notation c; and Table 4.3-2, Note #

) 3/4.3.3.1.2, Radiation Monitoring for Plant Operations -

l Containment Ventilation; and Table 3.3-4, Notation a Improved TS 3.3.7, Control Room Emergency Filtration System (CREFS) l Actuation Instrumentation:

j 3/4.3.2.10, ESFAS Instrumentation - CREFS; Table 3.3-2, Notation i a; and Table 4.3-2, Note #

3/4.3.3.1.3, Radiation Monitoring for Plant Operations - Control Room Air Intake; and Table 3.3-4, Notation b l

! 3.7.12, CREFS - Both Units Shutdown:

3/4.7.6, CREFS (Common System) l 3.8.2, AC Sources,- Shutdown:

j

3/4.8.1.2, A.C. Sources - Shutdown; ACTION

.c.-

Background:

At VEGP, an overhead heavy load handling system (OHLHS) is l-defined in Section 9.1.5 of the FSAR as a system which lifts loads i weighing more than the combined weight of a single spent fuel assembly j and its handling tool. Anything weighing less than or equal to this i (2300 pounds) is defined in Section 9.1.4 of the FSAR as a light load

handling system (LLHS). LLHSs were not evaluated as heavy loads. With j respect to movement of loads over irradiated fuel at VEGP, there are two

areas of concern: the fuel handling building and containment. '

! Note that fuel handling accident analysis in FSAR Section 15.7.4 i states that the fuel handling building post accident exhaust system is not required to function in order to maintain the releases from a fuel handling accident below acceptable levels. In addition, no credit is l

taken for filtration by the containment purge exhaust system during the

[ brief period of time (about 10 seconds) before automatic isolation of the containment purge system.

Fuel Handling Building: Within the fuel handling building, there is the spent fuel cask bridge crane, the cask lifting device bridge crane, and l Vogtle Units 1 and 2 Improved STS Conversion i

i

__ i. _

~

y. DRAFL i Less Restrictive Requirements LCOs, ACTIONS, and SRs

Control Room Habitability The preceding discussion addressed the

! potential offsite radiological consequences of dropping a load other j than a fuel assembly onto irradiated fuel. However, the radiological l

impact on the. control room environment following a load drop without actuation of the CREFS system must also be considered. The FSAR does not address this issue. Therefore, in the absence of an analysis of the i

! - potential radiation dose to plant operations staff in the control room, )

4 the licensee offered the following justification. The CREFS is a system that is common to both control rooms consisting of two full capacity i trains from'each unit. Therefore, CREFS is effectively a four train l system. When one or both units are in MODE 1, 2, 3, or 4, or are ,

i conducting CORE ALTERATIONS or moving irradiated fuel, the CTS and the l

improved TS require all four trains to be OPERABLE. Therefore, control .

room habitability is only a concern in the event a load is dropped onto j irradiated fuel when both units are shutdown in MODE 5 or 6 and the i

licensee is niether moving irradiated fuel nor conducting CORE

ALTERATIONS. It is unlikely that these conditions would occur concurrently with all four CREFS trains being inoperable. Assumming :

l that three trains could not operate at all and that the fourth train i

would not start automatically on a control room air intake radiogas i actuation signal, manual initiation of CREFS would still be possible.

i Because of the strict administrative controls already vin place for crane j operation over irradiated fuel at VEGP, the operator will learn of the 4 load drop immediately and would start CREFS within a very short time,

minimizing the potential radiation dose above that which would be l expected were CREFS to automatically start. To minimize the potential )

adverse radiological effect on control room habitability, the licensee l j committed to require by ;hrt ";i.tratin ,,..;;J..m tha CREFS be i capable of manual initiation duri g movement of loads over radiated l p fuel in both the containment and efueli buildings. y' e ]

$At M frohr o i Adminstrative Controls for Load Handling Load handling operations for '

i loads that are or could be handled over or in proximity to irradiated i j fuel are controlled by written procedures. Each procedure addresses: ;

i ~'

l 'The specific equipment required to handle load (e.g., special lifting device, slings, shackles, turnbuckles, clevises,

load cell, etc.).

l_

The requirements for crane operator and riggers qualification.

The requirements for inspection prior to load movement and 4

acceptance criteria for inspection.-

2 The defined safe load path and provisions to provide visual

. reference to the crane operator and/or signal person of the -

l safe load path envelope.

Specific steps and' proper sequence to be followed ,for handling

' load.

L Vogtle Units 1 and 2 Improved STS Conversion i

l;

DRAW ;

1 Less Restrictive Requirements LCOs, ACTIONS, and SRs l 4 1

! 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor (FQ \

! (3) In conformance with STS 3.2.2, ACTION B, the requirement of CTS 3/4.2.3, i ACTION b (second part), to reduce THERMAL POWER to less than 5% RTP >

(MODE 2)'within the next 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months has been retained as improved TS 3.2.2, ACTION B, except that the Completion Time for reaching MODE 2 has been l relaxed to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This increase in Completion Time is reasonable based

on operating experience regarding the time required to reach MODE 2 from full power conditions in an orderly manner and without challenging plant t

j systems. This time provides a sufficient restriction, based on t operating experience and the low likelihood of an event during this period, to avoid an undue risk to public health and safety.

1 In addition, this action requirement now applies to any improved ;

! qj TS3.2.2RequiredActionthatisnot6[metwithintheassociated V Completion Time, not just to correspong Ing Required Action A.2 of

! improved TS 3.2.2. Q.o m

! 3.2.3 AxialFluxOffference(AFD) l (4) VEGP is presently operated using the Relaxed Axial Offset Control (RAOC) J methodology. The existing provision of CTS 4.2.1.1.a.2, to monitor AFD i

once per hour until the AFD monitor alarm is updated after restoration to OPERABLE status, is a holdover from the time when VEGP was operated l

using the Constant Axial Offset Control (CAOC) methodology. As such, CTS 4.2.1.1.a.2 has been relaxed to require the AFD to be monitored at i least once per hour only while the AFD monitor alarm is inoperable, in

improved TS SR 3.2.3.1.

l Similarly, CTS 4.2.1.1.b also applies to use of the CAOC

! methodology. Thus this surveillance has also be deleted.

l (5) ACTION a.2 of CTS 3/4.2.1 requires (a) reducing THERMAL POWER below 50%

RTP and (b) reducing the power range neutron flux high trip setpoints to

! s 55% RTP in the event AFD is outside its specified limits. The second q requirement has been deleted in conformance with the ACTIONS of

corresponding STS 3.2.38. As documented in a letter dated September 5, l 1990, from.J. R. Hinds, Westinghouse Owners Group (WOG), to Jose A.

Calvo, NRC, it was agreed that this action requirement may be deleted.

j Reducing THERMAL POWER below 50% RTP maintains the plant in a benign

! condition since under the RAOC methodology there are no AFD limits below l 50% RTP. In addition, a rapid rise to greater than 50% RTP with AFD l

outside limits does not immediately create an unacceptable situation, j Since the transient analysis setpoint calculations for f(aI)

(input to the overtemperature delta-T (OTDT) trip function) are based on

! the same core power distributions that the fuel designers use for a l reload cycle design, the OTDT trip function should provide an acceptable i level of protection for such an excursion.

Vogtle Units 1 and 2 Improved STS Conversion ,

l l^

1 c

L______ _

. .. .--. -- . . . - -- -. . _= - - _ - - - . - - . _ . - .

DRAFT !

Less Restrictive Requirements LCOs, ACTIONS, and SRs L Reducing the setpoints increases the likelihood of a reactor trip 1

< potentially. challenging safety systems. Because the OTDT trip function

< provides adequate protection in the event _of a power excursion above 50%

RTP when the AFD is outside its limits, reducing the power range neutron

flux high trip setpoints to s 55% RTP is not justified.

! 3.2.4 - Quadrant Power t Ratio (QPTR) i Q fy (6) Intheeventthe$>T xce its limit of 1.02 but remains s 1.09, ACTION a.1 of CTS 4.2.4 requires QPTR to be calculated once per hour until either QPT is restored to within its limit or until THERMAL POWER

is reduced to 0% RTP. This action requirement has been replaced by 4 Required Actio A.2.1 of improved TS 3.2.4, to calculate QPTR (i.e.,

i perform SR 3.2.4.1) once per.12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months until QPTR is restored to within i its limit. The 12-hour interval for calculating QPTR while it is

outside its limit is reasonable when coupled with the requirement of -

j Required Action A.1 to reduce thermal power by 3% for each 1% QPTR exceeds 1.0, because any additional change in QPTR would be slow.

]

In the event the 12-hour verification identifies a change in QPTR ,

warranting an additional power reduction, Required Action A.2.2 allows 2 j hours to reach the new power level, similar to Required Action A.I. 1 These proposed action requirements provide sufficient restriction, based

! on operating experience and the low likelihood of an event during this

period, to avoid an undue risk to public health and safety. The existing requirement te calculate QPTR once per hour is, therefore,

'.! excessive. In addition, it could needlessly divert the attention of the

! control room staff from correcting the QPTR out-of-limit condition.

[

Therefore, this e ange is acceptable.

i iq (7) In the event.the TR exceeds its limit of 1.02 but s 1.09, ACTION a.3 of CTS 3/4.2.4 requires --

[

_. verifying restoration of the QPTR to within its limit within 24

! hours, or

a reducing THERMAL POWER to less than 50% RTP within the next 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and -.

- reducing the power range netron flux - high trip setpoints to i s 55% RTP within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

In addition, ACTION a.4 of CTS 3/4.2.4 requires --

- correcting the cause of the out-of-limit condition prior to increasing THERMAL POWER;

. verifying QPTR is within its limits at least once per hour for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months subsequent to p r Z operation above 50% RTP or until verified acceptable at 95% RTP.

fL5untitfn Vogtle Units 1 and 2 J Improved STS Conversion

.~ - , , - -

L-ORAFT Less Restrictive Requirements LCOs, ACTIONS, and SRs 3

THERMAL P9WER level, in turn, provides additional margin below the fuel

< design linits during conditions in which a radial tilt is indicated.

This additional margin ensures that the fuel design limits are not

. challenged by local power peaking. The conservatism in these design i margins prevides additional assurance that operation at the reduced ,

j power level for the time required to achieve equilibrium plus 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months l will not result in a challenge to the fuel design limits. l Finally, Required Action A.2.1 requires determining QPTR by calculation once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to identify any increase from the initial

value above 1.02 or any increase since the previous determination. This

. time is considered appropriate because the QPTR is not expected to j change rapidly. Should an increase be detected, Required Action A.2.2 i requires reducing power further, proportional to the increase, within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , the same as the Completion Time of Required Action A.I.

\

Required Actions A.4, and A.5 Prior to increasing thermal power above the limit based on the amount that QPTR exceeds 1.0 (specified by the j more limiting of Required Action A.1 and'A.2)--

l

. Required Action A.4 specifies confirming that the safety analysis results remain valid for the duration of operation under the

change in core radial power distribution that resulted in QPTR exceeding its limit.

l

. Once A.4 is completed, Required Action A.5 requires recalibrating l

~

the excore detectors to show zero tilt to enable detection of any i subsequent changes in QPTR.

These two action requirements provid rance of safe operation above the limit of Required Action A.1 or A.2.2 and provide an operational restriction equivalent to that of cts m.2.4 ACTION a.4 (first part). l L/

" {

Required Action A.6 Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after reaching RTP or hin 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after exceeding the limit of Required Action A.1 or A.2.2, whichever occurs first, Required Action A.6 specifies rever g the

peaking factors are within limits. This is necessary following recalibration of the excore detectors to show QPTR equals 1.0. resfjmyg These action requirements are sufficient to ensure that m ~--' s jt .

7 operation above 50% RTP will not pose an undue risk to public health and t safety. Thus, the requirement of CTS 3/4.2.4 ACTION a.4 (second part) to verify QPTR is within its limit once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , subsequent to l operation above 50% RTP, until QPTR is verified acceptable at THERMAL l l POWER 2 95% RTP, is overly restrictive, and may be deleted.

Required Actions A.1 through A.6 will ensure that the unit continues to operate within the envelcpe of the safety analyses in the event QPTR j Vogtle Units 1 and 2 Improved STS Conversion l l

l

Less Restrictive Requirements LCOs, ACTIONS, and SRs (8) The CTS 3.2.4 limit of 1.09 for QPTR has been deleted to conform to the '

I STS. CTS 3/4.2.4, ACTIONS b and c, which are based on QPTR exceeding i

1.09, have also been deleted. ,

i ACTION b applies to QPTR in excess of 1.09 due to misalignment of

a shutdown rod or a control rod. This action requirement is no longer '

necessary to be contained in the QPTR specification because improved TS

.- 3.1.4, " Rod Group Alignment Limits," in. combination with the

. . requirements of improved TS 3.2.4, "QPTR," adequately addresses this condition.

CTS ACTION c, which applies to QPTR in excess of 1.09 due to ,

causes other than the misalignment of either a shutdown rod or a control rod, contains the following requirements, which are similar to those of CTS ACTION b:

f . ACTION c.1 requires calcultting QPTR each hour until either QPTR i s 1.02 or THERMAL POWER is s 50% RTP.

. ACTION c.2 requires reducing THERMAL POWER to s 50% RTP within 2

hours as long as QPTR remains above 1.02, and also reducing the ,

power range neutron flux - high trip setpoint.

5

! . ACTION c.3 requires correcting the cause of the out-of-limit l condition prior to increasing power, plus additional hourly determinations for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or until verified within limit with l THERMAL above 95%

i D In contrast, i roved TS 3 2.4 quired Action A.1 (or A.2.2) would

, I require reduchg THEMAL PC ER to a 3% belom RTP for each 1% (that is 0.01) of QPTR () 1.00 withi n 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Thus QPTR were 1.09, THERMAL i

POWER sust be reduced to (100% - 9/3) or 73% RTP within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

This is less restrictive an the CTS acti requirement. (Note that the CTS and the improved TS power reduction requirements are equivalent I when QPTR reaches approximately(l.00 + 0.50/3) or about 1.17.) The 2-i hour Completion Time to reduce power is considered acceptable because, i in the case of QPTR out of limit for causes other than a misaligned rod, the core tilt will occur gradually over an extended period of time.

Also, in most cases, to achieve the specified power reduction within 2 l hours, the operators would have begin reducing power within a short time

after QPTR exceeds the limit of 1.02 (the QPTR alarm setting). This

power reduction will limnediately act to mitigate the tilt by increasing i

margin to the conservatively-set fuel design limits ensuring that these L limits are not challenged by local peaking. Thus, operation at the reduced power level for the time required to achieve equilibrium i

conditions so that QPTR can be accurately determined will not result in 1

a challenge to the fuel design limits. Therefore, the CTS conservative y actionofreducingpowerto$50%RTPwithin2hoursresultsina Vogtle Units I and 2 Improved STS Conversion a

g .

Less Restrictive Requirements BRAFT LCOs, ACTIONS, and SRs l instrument functions in the CTS previously evaluated in WCAP-10271 and 1 accepted by the NRC. (See discussion (12) above.) Therefore, the

changes in the COT Frequencies justified in WCAP-10271 are applicable to the semi-automatic switchover to containment emergency sump function 1 generated by the RWST level low-low signal coincident with safety injection. This is based on the small increase in signal unavailability )

and a comparison to unavailability changes for other signals

.specifically evaluated in WCAP-10271 and accepted by the NRC.

i 3.3.3 Post Accident Monitoring (PAN) Instrumentat on s(upon impkmenkhon oHAe ckgqir mdiCcabm .

f i (17) The requirene of CTS Table 3.3-8 for condennte storage lev)el ha l

been revised t only require two channels for the OPERABLE tank as opposed to requ ring two channels per tank (implying 2 OPERABLE channels j l of level indicacion are required for the other, potentially inoperable, j j tank). At VEGP( only one condensate storage tank (CST) is required to J i

be OPERABLE at any given time. There .irno need to require two channels of level instrumentation for the tank that is not required to be i

0PERABLE. This is consistent with improved TS 3.7.6, " CST," which only requires one CST to be OPERABLE.

(

(18) CTS 4.3.3.6.2 requires a CHANNEL CALIBRATION of the containment hydrogen concentration monitors at least once per 6 months on a STAGGERED TEST i

1 BASIS (current definition). This surveillance has been revised to be

! consistent with the improved TS CHANNEL CALIBRATION surveillance for the other PAN instrumentation channels, improved TS SR 3.3.3.2. The j improved TS require the CHANNEL CALIBRATION of both containment hydrogen j - concentration monitor channels every 18 months, consistent with the STS, l

and also the CHANNEL CALIBRATION Frequency of RTS and ESFAS

! instrumentation channels. In addition, the hydrogen monitors only

! provide indication of hydrogen concentration in containment. They are

! not required during or immediately after a design basis accident because peak hydrogen concentrations would not be reached until several days after a worst case DBA, as described in the Bases for improved TS 3.6.7,

" Hydrogen Recombiners." Should the monitors fail, manual sampling would j be still available to monitor hydrogen concentration. Therefore, the 18-month CHANNEL CALIBRATION Frequency is acceptable.

l

\

j 3.3.4 RemoteShutdownSysten(RSS)

(Ig) ACTION a of CTS 3/4.3.3.5.1 requires restoring the OPERABILITY of an inoperable remote shutdown monitoring channel in 7 days. This action requirement has been replaced by ACTION A of improved TS 3.3.4. ACTION l A requires restoring the OPERABILITY an inoperable function, not just a

, , j

'1 channel, and allows 30 days to do so The 7-day Completion Time for individual channels no longer applie . The 30 day Completion Time is I Of Vogtle Units 1 and 2 Improved STS Conversion !

I

r 4

DRAFT, ;

}; Less Restrictive Requirements LCOs, ACTIONS, and SRs i appropriate based on industry operating' experience and the low probability of an event that would require the evacuation of the control room. Therefore, this change in the RSS action requirements, which conforms to the STS, is acceptable.

! (20) The requirement of CTS 3.3.3.5.2, to be capable of using the remote ,

.- shutdown panels to control the residual heat (RHR) removal system for removing decay heat, has been deleted, consistent with the STS. The RHR i system is not placed into service until MODE 4, which is outside the 4 3

Applicability of the RSS specification. Only the auxiliary feedwater l i

j (AFW) system and at least one steam generator are required for achieving

MODE 3 from outside the control room. Thus, control of RHR system ,

i i components from the RSS panels is not necessary. Therefore, the '

requirement for this capability to be OPERABLE may be deleted.

j l

T/ pen imp j rapeorW/m of hhe dery sorh6WedfiM, (21) The r fred channels of condensate stvrage tank (CST) level I 2, instrums ion in CTS Table 3.3-7 for the RSS has been revised from two l

j. Y channels to o channel per tank for the'0PERABLE tank in improved TS i

- Table 3.3.4-1. Improved TS 3.7.6 only requires one CST to be OPERABLE, i I

so only the channel for that tank needs to be OPERABLE.

$ 3.3.S 4.16 kV ESF Bus loss of Power (LOP) Instrumentation (22) The time allcwed to bypass a loss of power (LOP) channel has been increased from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , as given in ACTION 29a of CTS Table 3.3-2, to 4 i hours in ACTION A of improved TS 3.3.5, consistent with the STS and all other similar bypass time limits used in tiie TS. The additional 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months allows a more reasonable time to perform surveillances. The affected instrument function consists of 4 channels configured in a 2/4 logic.

l The allowance to bypass an inoperable channel allows another channel to t- be tested in the trip condition. The resulting instrument function logic,1-out-of-2, still retains the capability to withstand a single

failure.

l; The proposed increase in the time allowed for testing in bypass is based on a comparison with other instrumentation that has been specifically analyzed for the risk significance of allowing a channel j to be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for testing. Examples of RTS l

instrument functions where 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months are currently allowed for testing in bypass are:

Power Range instrumentation - 2/4 logic i Overtemperature delta T - 2/4 logic

Overpower delta T - 2/4 logic i Pressurizer Pressure - High - 2/4 logic

- Pressurizer Pressure - Low - 2/4 logic

! Steam Generator Water Level - Low - 2/4 logic

! Vogtle Units 1 and 2 Improved STS Conversion F

L L__._______-__-_-__-__- - . . , . - - . - - - -,.-e, - , - - -

DRAFT Less Restrictive Requirements LCOs, ACTIONS, and SRs fi j failure of Train B (single failure) and delay of filtration of the J. control room air (supply and recirculation) until the lag train (Train

A) is fully functioning. Therefore, starting either Train A or B in the

event of inoperable CREFS actuation instrumentation will be consistent j with the accident analyses. The proposed change will provide additional

! flexibility in that it will allow the train with shortest run time on 4 -

the filters to be used. Therefore, deletion of this Note is acceptable.

This same Note occurs in CTS 3/4.7.6, CREFS, and has been. deleted i from corresponding improved TS 5.7.10 for the same reasons just j l described.

1 k 3.3.8 High Flux at Shutdown Alarn

. (31) CTS RTS instrumentation function 6.b, " Source Range Neutron Flux

Shutdown," references ACTION 5 of CTS Table 3.3-1. ACTION 5 contains ,

j the requirement that valves 1208-U4-175,1208-U4-176,1208-U4-177, and l

1208-U4-183 be closed and secured in position: h.... . th "i ' ' i

I. a 3 --- . mm u___ _m m., > -c

" whenever less than the !

i required source range instrumentation is operable. Corresponding STS

! 3.3.9, " Boron Dilution Protection System," which is supported by this

' instrument function, only specifies that any valve used to isolate unborated water sources be closed and secured in position, but does not j specify which valves must be used for isolation. It is implicit that

! the applicable valves are specified in plant procedures. Thus, the

! licensee has proposed to adopt the STS requirement for isolating unborated water sources in corresponding im, proved TS 3.3.8, "High Flux

at Shutdown Alarm (HFASA)," which is applicable in MODES 3, 4, and 5.

j Specification 3.3.8, Required Action B.2, will require verifying that i the unborated water source is isolated within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months in the event an

! HFASA instrument channel is inoperable for 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or upon both

channels becoming inoperable. This is a less restrictive requirement

because the TS will no longer be specific as to which valves must be i used to isolate unborated water sources. However, the change is acceptable because plant procedures will require that at least one valve

' in each flow path from the reactor makeup water storage tank (RMWST)

(the RmfST is the unborated water source at VEGP) to the suction of each

! charging pump be closed and secured in position. Administrative l controls will ensure that these valves are maintained closed when

required. The fact that the TS will continue to require that the isolation valves be secured in position will ensure that the valves are I not inadvertently opened.

1 The existing VEGP TS requirements are overly restrictive because (a) other valves besides the four specified in the CTS can be used to

! effectively isolate the RMWST, and (b) the four valves specified provide

double isolation of each flow path. This double isolation coupled with the requirement that each valve be secured in position would effectively i

! Vogtle Units 1 and 2 - 103 - Improved STS Conversion

,, -- - . - . - s -, - . . . , - . - , , , . - ~ ~_

]

ORAFT

] Less Restrictive Requirements LCOs, ACTIONS, and SRs d

i required by improved TS 5.6.6. CTS 3.4.9.1 has been retained as l improved TS LCO 3.4.3 which requires maintaining the RCS P/T values j within the limits specified in the PTLR instaed of these CTS Figures.

1 CTS 3/4.4.9.1 addresses P/T limits associated with parameters that i may change with reactor vessel fluence, requiring processing of changes to the TS to update these limits for each reactor vessel fluency period.

It.is essential to safety that the unit be operated within the bounds of

> . the RCS P/T limits, and that the overpressure protection system power operated relief valve (PORV) setpoints be set to appropriate limits.

Additionally, it is essential to safety that a requirement to maintain . .;

i the unit within.the appropriate P/T bounds be retained in the TS.

i However, the specific values of these limits may be modified by j licensees, without affecting safety, provided the changes are made in i accordance with an NRC epproved methodology.

j Ine P R w1 cont the s peific v ues f these ra s, the hod gy us to ca ate se va s wil ec ained i

lIg a AP- 40, thod yU to Dev op Co Over ssure itiaat a -J

Sys Sek oints d RCS eatun a Cool Cur s."1The PTLR will be '

l submitted no the NRC in accordance with improved TS 5.6.6.c.d In eac1 tion, the words "during heatup, cooloown, criticailty, and inservice l

1eak and hydrostatic testing" will be deleted since they are redundant j to the Applicability of improved TS 3.4.3 of "At all times."

! Because the NRC has approved the methodology for updating the RCS g P/T limits for VEGP, the PTLR update for each reactor vessel fluency s s period must be provided NRC x i .;, and the requirement to operate gs fk the units within the re red TS 3.4.3, this change i acce,ptable. /5 boundaries as been retained in improved

~5 the (4) Required Action C.1 requires initiating action immediately to restore P/T prameter(s) to within limits, instead of the existing requirement to ggg restore the parameter (s) within 30 minutes. Requiring initiation of restoration action immediately is less restrictive than specifying when

}yg restoration action must be completed. The proposed Completion Time is g g9 acceptable because most violations are not anticipated to be severe, the RD plant is in MODE 5 or 6, and the new action requirement will allow gE restoration to be accomplished in a more controlled manner.

3.4.7 RCS Loops - M00E 5, Loops Fi11ed

. 2 C (5) Improved TS LCO 3.4.7 Note 4 has been added to corresponding CTS 3.4.1.4.1 to allow all RHR loops to be removed from operation during

% planned heatup to MODE 4 when at least one RCS loop is in operation.

This is acceptable since the running RCS loop provides sufficient heat k( d.

E removal capability, while the RHR loops remain OPERABLE should they be needed. This also facilitates an orderly transition from MODE 5 to MODE 4.

Vogtle Units I and 2 - 105 - Improved STS Conversion W

1

, , ,. w-,--.-,,,n ,,e er,w-

i j

Less Restrictive Requirements LCOs, ACTIONS, and SRs 3.4.10, this allowance is restricted to one valve out of service at a time for lift setting. Considering the importance of adjusting the I setpoints of these valves under conditions similar to their normal l operating conditions (for accurate lift settings) and the limitations provided in the Note, this allowance is reasonable and beneficial to plant operational safety. Therefore, this Note is acceptable.

~

3.4.11 PressurizerPowerOperatedkellefValves(PORVs)

(9) The ACTIONS of CTS 3/4.4.4 for the PORVs are differentiated by whether the PORV is inoperable because of seat leakage (ACTION a), or for other reasons (ACTION b). The ACTIONS of improved TS 3.4.11 are grouped not l according.to seat leakage, but according to whether the PORV is (ACTION A) or is not (ACTIONS B and E) capable of being manually cycled. At VEGP, the PORVs are required for manual actuation only. No automatic function is assumed for these valves in any DBA or transient analysis.

The PORVs may be considered inoperable for many reasons. However, if l

~

the valve can be manually cycled, the safety function is available.

Focusing on the capability for manual operation is consistent with the PORV design and the safety analysis. 7. -In -/4/5 c4mj However, this results in less restrictive action requirements for l a PORV that is inoperable for reasons other tha i seat leakage and loss of manaul actuation capability. Tr =71;, i " th; ^^'".' i ; i ..em ;bi;-

lIa ix x x it de in",a- W a' -"t-st% :;=e ;mn CTS ACTION a would not apply, but ACTION b would apply, and it would require within an hour closing and removing power from the associated block valve. However, improved TS ACTION A would apply to this Condition, and would only require closing the associated block valve. This action is more appropriate since the manual actuation capability has not been lost.

Therefore, the change in the focus of the ACTIONS on the OPERABILITY of the manual actuation function is acceptable.

(10) CTS 4.4.4.1.b, to perform a CHANNEL CALIBRATION on the PORVs every 18 30 months, has been removed from the CTS,.cd pined ! " ? rt prtr. !

This surveillance is not needed because the automatic operation of the PORVs is not assumed in the VEGP accident analyses for MODES 1, 2, or 3.

4 This surveillance is also not contained in the STS.

3.4.12 'old C Overpressure Protection System (CDPS)

(11) The requirement of CTS 4.4.9.3.1.a, to perform an ANALOG CHANNEL OPERATIONAL TEST (ACOT) on the power operated relief valve (PORV) actuation channel within 31 days prior to entering a condition in which the PORV is required te be OPERABLE (entering MODE 4 from MODE 3), has been replaced by a requirement to perform the CHANNEL OPERATIONAL TEST (C0T) within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after decreasing RCS cold leg temperature to s Vogtle Units 1 and 2 - 107 - Improved STS Conversion

_ . ___._~ __._ ._ _ _ __ __ _ .. _ _ . __ ____ __. __._ _ ________

's '

j DRAFT LCOs, ACTIONS, and SRs !

i Less Restrictive Requirements J

i be based on an RCS water inventory balance or by containment radioactivity (or both) plus a containment inspection. Continued operation with an inoperable sump monitor in accordance with ACTION A is acceptable because timely detection of RCS LEAKAGE is ensured by the j diversity of the indication provided by the two remaining sump monitors, e

the radioactivity monitors, and/or containment cooler condensate flow rate, in addition to the daily performance of the RCS water inventory balance.

In the_ event two or more sumps are unmonitored, however, ACTION B, l

i allows 30 days to restore at least two sumps to monitored status, again

provided an RCS water inventory balance is performed once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The 30-day Completion Time is acceptable because the daily RCS water j inventory balance and the other available RCS LEAKAGE detection systems are sufficient to detect RCS LEAKAGE.

l Two RCS LEAKAGE p-tection Systems Inoperable: In the event only one l system is OPERABLE, CTS 3.0.3 would require a plant shutdown. The l proposed ACTIONS, however, ;ay be combined in accordance with Section l 1 j l

1.3, " Completion Times," and, therefore, would permit operation to j -continue for up to 30 days before ACTION F would require a unit i

shutdown. In particular

( d

. With only the three sump level monitors OPERABLE, the ACTIONS l require on a daily baris either an RCS water inventory balance or l~

obtaining and analyzing a grab sample of the containment

atmosphere. g f C . With only one of the two radio etivity monitors and less than three sump level monitors OPERABLE, the ACTIONS require on a daily basis an RCS water inventory balance.

. With only the containment air cooler condensate flow rate monitor and less than three sump level monitors OPERABLE, the ACTIONS require on a daily basis an RCS water inventory balance.

J The 30-day Completion Time is acceptable because the daily RCS water inventory balance is sufficient to detect RCS LEAKAGE, and because other i diverse means of detecting RCS LEAKAGE are still available.

No OPERABLE RCS LEAKAGE Detection Systems: In the event all the

! required RCS LEAKAGE detection systems are inoperable, ACTION G requires l

immediate entry into LCO 3.0.3, which is consistent with the CTS. This j ACTION would apply even if two of the three containment wap level monitors were still OPERABLE. A daily RCS waten hentori balance is not sufficient compensation for operation with an unmonitored sump and no other means of automatically detecting RCS LEAKAGE.

F Vogtle Units 1 and 2 - 112 - Improved STS Conversion a

i

4 DRW Less Restrictive Requirements LCOs, ACTIONS, and SRs of the interlock. Consequently, an 18-month Frequency for testing the interlock is considered sufficient to ensure proper operation of the interlock when challenged by personnel error. Therefore, this change is acceptable.

4 3.6.3 Cs.ntainment Isolation Valves (CIVs)

(12) A Note has been added to CTS 4.6.1.1.a and Note

in the corresponding valve and blind flange surveillance requirements (SR 3.6.3.3 for manual valves and blind flanges outside containment, and SR 3.6.3.4 for manual valves and blind flanges inside containment, respectively). The Note allows verification of valves and blind flanges located in high ,

radiation areas by use of administrative means. This is considered i

acceptable because access to these areas is restricted for ALARA reasons. Therefore, the probability of these devices becoming mis =11gned, once they have been initially verified in the proper position (by other than administrative means), is small. Therefore, i this Note, which is consistent with the STS, is acceptable.

(13)

Note 1 to the ACTIONS of improved TS C50 3.6.3 SproMes a new l allo j intermitently open containment isolation valve ;, required by the ACTIONS to be closed (except for the 24" purge valves) , under administrative 2 controls. This is acceptable because the admi nistrative controls lg consists of a dedicated operator at the valve 41n continuous communication with the control room. This control provides protection 3 4 equivalent to the automatic isolation function. The large purge valves i

are excluded due to size and the direct flow path from inside

! containment to the outside. Note 1 offers flexibility for conducting testing and repair of inoperable CIVs while maintaining sufficient restrictions-through the requirement for administrative controls to ensure the isolation function will be accomplished if needed.

' Therefore, Note 1 is acceptable.

l It should be noted that Note

to CTS 3.6.3 regarding this same !

i allowance for the containment hydrogen monitors is considered to be !

included in the allowance specified by Note 1.

l (14) CTS 3.6.1.7.b has been retained as improved TS SR 3.6.3.2 with an added

allowance to open the 14-inch purge valves under administrative control

. for purge or venting operations and for post-maintenance testing on the purge and exhaust system. The various activities that may be performed '

under administrative controls are described in the Bases discussion of improved TS SR 3.6.3.2. This includes those activities currently listed in CTS 3.6.1.7.b and the additional activity of maintenance testing.

This provision will facilitate troubleshooting and testing of the mini-purge fans in order to maintain the capability of the fans to support l ALARA and respirable air quality considerations for personnel entry.

Vogtle Units 1 and 2 - 121 - Improved STS Conversion i

- - . . - . - =_. . -. -. - . - -. . - - . - - - - - _

DRAFT

Less Restrictive Requirements LCOs, ACTIONS, and SRs I

3.7.5 Auxiliary Feedwater (AFW) Systen

)

(6) The VEGP turbine-driven AFW pump is equipped with redundant steam supply lines. Either line will meet 100% of the steam requirements for the turbine-driven AFW pump. However, CTS 3/4.7.1.2 does not credit this redundancy. Under the CTS, if a steam supply line were inoperable, the

- turbine-driven AFW pump would be considered inoperable, and ACTION a of CTS 3/4.7.1.2 would allow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the pump to OPERABLE i status. The licensee has added improved TS ACTION A to the AFW system l

action requirements to address the redundancy of the steam supply lines j to the turbine-driven AFW pump. ACTION A of improved TS 3.7.2 allows 7 i l

days to restore an inoperable steam supply line. The Completion Time af ]

j 7 days is based on the availability of the redundant OPERABLE steam i l

supply line, the availability of 2 redundaat OPERABLE motor-driven AFW

[ pumps, and the low probability of an event occurring during this time that would require the inoperable steam supply line. Therefore, this

change is acceptable.

l (7) The details of AFW pump performance data in CTS 4.7.1.2.1..a.1) and i 4.7.1.2.1.a.2) have been moved to the plant procedures that implement l( X this surveillance requirement, consistent with the STS. The revised wording of the surveillance, improved TS SR 3.7.5.2, acknowledges that j the pump performance may be verified at other points (beside

recirculation flow) on the head curve, and allows plant procedures to

} define appropriate point (s) on the head curve to verify, consistent with

the IST program requirements. Note that this change falls under less l

restrictive change type 3 as defined in the general discussion of less restrictive requirements at the beginning of Part III of this safety

evaluation.

! (8) CTS 4.7.1.2.1.b.1), the surveillance for verifying automatic valve

actuations in the AFW system, has been revised consistent with the STS to exempt valves from the required testing if those valves are normally locked or sealed in position such that they are not required to actuate j to perform their safety function. This is acceptable because the AFW j system can still perform its safety funi: tion, i

3.7.10 Control Roon Energency Filtration Systen (CREFS) - Both

{ Units Operating; 3.7.11 CREFS - One Unit Operating; and 3.7.12 CREFS - Both Units Shutdown -

l 4

(9) ' ACTION D of improved TS 3.7.10, ACTION F of improved TS 3.7.11, and i ACTION F of improved TS 3.7.12, for control room air temperature not within limits, have been added to the corresponding ACTIONS of CTS 3/4.7.6 for the CREFS. CTS 3/4.7.6 contains a surveillance to verify Vogtle Units 1 and 2 - 128 - Improved STS Conversion 4

DRAFT Less Restrictive Requirements LCOs, ACTIONS, and SRs l

time per fuel cycle Completion Time of either 14 days or 21 days in ACTION H are acceptable given the combination of the Wilson switchyard high reliability, the 97 percent availability of the combustion turbine ,

)

i

' q for electrical generation, along with the weather tolerant direct buried i l

power line capable of supplying emergency power to any of the VEGP ESF buses, and the resulting reduction in CDF. j ACTIONS B and C In the event one DG is discovered to be inoperable, l

ACTION B, consistent with the STS and CTS, allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months days to restore the DG to OPERABLE status. However, if the SAT is available l

(not being used as an offsite AC source or in place of another

inoperable DG, and is OPERABLE), then ACTION C would apply instead, and would allow 7 days to restore the DG to OPERABLE statut. This i 1 l

Completion Time is less restrictive but is acceptable fe the reasons l given above.

l However, if while in Condition C, the SAT becomes unavailable, then Note 2 of Condition C requires initiating operation in accordance with Condition B " concurrently immediately" and also to continue '

l operation in accordance with Condition C. Thus, Condition C would not be " exited" (which would reset the associated Completion Times). If the l

j SAT were not made available before the 3-day Completion Time of ACTION B l

or the 7-day Completion Time of ACTION C expired, whichever occurs l first, then a unit shutdown would be required by ACTION I.

j

! ACTIONS B and H As stipulated in Notes 1 and 2 of Condition H, once

! each refueling cycle, "..'. r t. r r!.....my'the licensee may take each DG i y out of service in accordance with ACTION H g ht., te r.. %c; M..

r: 9 t c;r'; r z r z:f:I !" 2 9 M ;rn ...t h; ; Ute..-...., in lieu i of either ACTION B or C, provided the SAT is available as a standby i source in place of the affected DG. Required Action H.4 allows 14 days

to restore the DG to OPERABLE status for the cyclic preventive

! maintenance for each DG. However, for one DG per unit per cycle, the i Note preceding the second Completion Time of Required Action H.4 allows j this maintenance to be replaced by the performance of what the licensee i

describes as the "25% teardown maintenance." For this more extensive

" preventive maintenance, which is anby expected to be performed once per

! 10 vaars for each DCs, a Completion Time of 21 days has been specified.

The 14-day and 21-day Completion Times allow sufficient time, based upon previous DG overhaul maintenance experience, to properly perform the necessary work, and includes some time to correct any unanticipated i

problems. These Completion Times are acceptable because (a) the DG outage is intended to be a planned activity, (b) the use of ACTION H is

! limited to once per cycle per DG thus it is infrequent, and (c) the

SAT is an acceptable standby AC source in place of the affected DG ]

4 during these time periods, as descibed above. In addition, these Completion Times are acceptable because (d) they are measured from the

Vogtle Units 1 and 2 - 136 - Improved STS Conversion r

/Wvidd 006'erse Mclicef/Ms cht#fNerg ,yg nggg fagam m*M/mone " of *r twest:t f?tfuom i%ra%ce utM Mt j inaqu/nclurertr tecm& inoinfaurc p

l i

DRAFT Less Restrictive Requirements LCOs, ACTIONS, and SRs j

time of initial failure to meet the LCO. As such, it is unlikely the i

< licensee would initiate a DG overhaul and operation in accordance with !

1 4 ACTION H if any other AC Sources or other opposite train safety systems

! S were inoperable.

i In the event the SAT becomes unavailable while operating in j q accordance with ACTION H, Note.4 of Condition H requires initiating 4

y.s operation in accordance with Condition B." concurrently immediately" and also to continue operation in accordance with Condition H. Thus, 9

Condition H would not be " exited" (which would reset the associated j

h g q Completion Times). If the SAT were not made available before the 3-day Ccupletion Time of ACTION B or the 14-day (21-day) Completion Time of i N ACTION H expired, whichever occurs first, then a unit shutdown would be i . required by ACTION I.

ACTIONS C and H c/o pf ag/7 /o 21 i --+ Note 1 to Condition C and i 2 to Condition H specifiy that when the provisions of ACTION H are being used for maintenance on a DG, then the

t provisions of ACTION C r r>rrt 5: r :d T., the same DG concurrently.

9: g - --

n. . void ov6 u'w p m uwu rosiowing otscover n i k inoperable available an ent ondition C, to

subsequently enter Condition h the cyclic overhaul of the

DG, in addition to g the DG correct v e for the i l

ng a unit shutdown when the 7-day Comolet on l

ky L purpose Action C_4 avoiresi Condition H is intended to be used ::h '

j W -t n.t i. M DG :;:? h F;n..tj= maintenancer-edch/

for ;rr':"Its'fensive yky ujjf r jg pg 4.jg 7_

g l

ACTIONS A, B, C, and H C /g 7g g c,gjg g,

~D Required Actions A.3, B.4, and C.4 have a second Completion Time that is measured from the time of initial failure to meet the LCO. For Required

{4g* Actions A.3 (to restore an inoperable offsite AC source) and B.4 (to

,$ restore an inoperable DG), a 6-day Completion time is specified and is w based upon the 72-hour Completion Time for each of these Required ;

D4 Actions. The purpose of the 6-day Completion Time is to limit j continuous operation with the LCO not met to the sum of their respective j 72-hour AC source allowed outage times. Similarly, if the SAT is available, Required Action C.4 specifies a 10-day Completion Time, which

is the sum of the 7-day Completion Time of Required Action C.4 for an

inoperable DG and the 72-hour Completion Time for an inoperable offsite l AC source. -

These Completion Times are considered to be additional operational restrictions, as explained in discussion (3) in Subsection 3.3.3.8 of

Part III of this safety evaluation. However, the adoption of ACTIONS C and H created a potential conflict regarding the use of the 6-day Completion Times for Required Actions A.3 and B.4. In the event the Vogtle Units 1 and 2 - 137 - Improved STS Conversion 1

b ., _ _ _

~

l- DRAFL i

Less Restrictive Requirements LCOs, ACTIONS, and SRs I load being rejected is well within the rating of the transformers, :

i switchgear, and breakers. Furthermore, the current reversal resulting j from a DG full load rejection does not affect the protective relays i (differential or overcurrent) of the reserve auxiliary transformer -

(RAT), the standby auxiliary transformer (SAT) (if being used as an

offsite circuit), or the ESF bus. The resulting voltage transient from 1 .-

the f911 load rejection is not significant (-2.3% on the ESF bus as 4 verified by test, which is acceptable).

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months run will start and operate the DG in the same manner j

as the current monthly surveillance that is performed at power.

Although the DG will be operated in parallei with the grid for a longer

period than the monthly surveillance, the normal DG protection features

. [,r A riate willbeinserviceandwilloperatetoprovidetheapprop/uringthe24 protective function in the event of a grid disturbance.4

, gg J hour run, the DG is loaded to 110%, which is more than the current gI monthly testing load, but is consistent with the DG rating and well .

< within the rating of the transformers, switchgear, and breakers. In addition, the performance of the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months run in and of itself will not ;

! cause perturbations to the electrical distribution systems. The allowance to perform the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months run at power does not preclude the use of procedural controls to ensure the test is not performed or is l

terminated if grid conditions become unstable or if grid stability is

! threatened (approaching storms etc.).

4 Finally, the hot restart test of the DG will have no impact if i

performed during power operation because the DG does not connect to the ESF bus during this test. Verification of.the capability of the fuel

oil transfer system will also not impact DG OPERABILITY. Thus, it also l will have no impact if performed during power operation.

l Based on the preceding discussion, deletion of this performance

! restriction from these surveillances is acceptable.

i l (8) The required load of 7000 kW specified in CTS 4.8.1.1.2.h.3 (DG full load rejection test) has been revised to the load range of 6800 kW to 7000 kW to provide an acceptable range that still meets the objective of

the full load rejection test. This change is consistent with the STS i which specifies a kW range for the performance of this test. Since 6800 i kW is still above the full load of a DG, this change it is acceptable.

(9) CTS 4.8.1.1.2.h.7, the DG 24-hour full load run surveillance, contains I specific time, voltage, and frequency criteria that must be satisfied when starting the DG for the 24-hour run. These criteria are identical 4

to those contained in CTS 4.8.1.1.2.g.1, the 6-month DG start test from

- ambient conditions, and CTS 4.8.1.1.2.h.5, the 18-month test of the DG to start on an ESF actuation signal without a loss of offsite power.

' Because these surveillances, which have been retained as SR 3.8.1.7 and SR 3.8.1.11, adequately demonstrate the capability of the DG to meet Vogtle Units 1 and 2 - 142 - Improved STS Conversion

{

i I Less Restrictive Requirements MAfI LCOs, ACTIONS, and SRs i electrolytes in representative cells. 'Therefore, the remaining ,

' surveillances continue to provide adequate assurance of battery 0PERABILITY.

l (15) The requirement of CTS 4.8.2.1.c.2, to verify terminals " clean and tight," applies only to nickel cadmium batteries, which are not i

_. installed at VEGP. This is based on the. reviewers note in the STS Bases

-for corresponding STS SR 3.8.4.4 and IEEE Standard P1106. In addition, 4

verification of_ tightness may result in unnecessary stress to each j connection when torque is applied to confirm tightness. If the connections _ satisfy the resistance requirements of CTS 4.8.2.1.c.3 i

(improved SR'3.8.4.5) (performed at the same 18-month Frequency) they '

can be assumed to be sufficiently torqued. Therefore, it is acceptable to delete this requirement.

1 3.8.5 DC Sources - Shutdown g j (16) Since improved TS LCO 3.8.5 requires supplying power to all r red g loads, if one or more required DC loads are not being supplie , the DC 4

f[ source is considered inoperable. This represe its an additi 1

! restriction on plant operation as described in! discussion ( of Subsection 3.3.3.8 of Part III of this safety evaluation. wever, in

this event, it may not be necessary to suspend CORE ALTERATIONS, i movement of irradiated fuel, or positive reactivity additions. Plant i safety would also be ensured by declaring inoperable all required l

equipment without DC power and taking the specified ACTIONS of the i j governing specifications. This option is given by Required Action A.1.1 of improved TS 3.8.5. Adopting this optional provision is considered to be less restrictive because it offers additional flexibilty in responding to an inoperable DC source. Therefore, this change, which is consistent with the STS and the ACTIONS of improved TS 3.8.2 for AC j

sources in MODES 5 and 6, is acceptable.

3.8.6 Battery Cell Parameters li i (17) Consistent with the STS, Note (a) of improved TS Table 3.8.6-1 has been

] added to corresponding CTS Table 4.8-2 which specifies the battery cell I parameter limits. This Note provides an allowance for the electrolyte level to temporarily increase above the maximum level during equalizing

charges provided it does not overflow. This level excursion is j acceptable since it is due to gas generation during the charge and is expected to return to normal after the charge.

i (18) Notes (1) and (2) of CTS Table 4.8-2 have been combined in new 3 Specification 3.8.6, " Battery Cell Parameters," as ACTION A. A 31-day Completion Time has been adopted, consistent with the STS, for restoring

! Vogtle Units 1 and 2 - 148 - Improved STS Conversion 4

4

i DNT More Restrictive Requirements LCOs, ACTIONS, and SRs i

additions. CTS would allow the plant to remain between P-6 and P-10 with a single channel inoperable.

3.3.1.16.b Reactor Trip Systen Interlocks - Low Power Reactor Trips Block, P-7 4

(2) Improved TS Table 3.3.3-1 lists the P-7 interlock as a separate function, consistent with the STS. Although P-7 is comprised of inputs 4

from P-10 and P-13, which appear in CTS Table 3.3-1, P-7 was not explicitly listed. This change is actually administrative because the capability of the P-7 logic function to automatically enable / block the associated train of the following RTS functions may be considered necessary for the OPERABILITY of each RTS train for these functions (improved TS function numbers have been used).

8.a Pressurizer Pressure - Low 9 Pessurizer Water Level - High !

10.b Reactor Coolant Flow - Low - Two Loops 11 Undervoltage RCPs 12 Underfrequency RCPs l

Thus, in the event o<foran inoperable P-7 interlock, the ACTIONS of CTSl h 3/4.3.1 would result, in appropriate remedial actions being taken - by i enfer/ng nk the ACTION 4 + each supported function. By calling P-7 out !

s=epara;tely with its own ACTION, the existing ACTIONS have been j simplified, but not relaxed. Improved TS ACTION S requires restoring 1 P-7 to the required state for the existing plant condition within I hour i or being in MODE 2 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . This change is considered more l restrictive because of the explicit requirement of improved TS SR l 3.3.1.5 to perform an ACTUATION LOGIC TEST every 31 days on a STAGGERED ;

TEST BASIS. This surveillance was not previously specified for the !

above RTS functions that P-7 supports.

3.3.1.17 Reactor Trip Breakers (RTBs);

3.3.1.18 RTB Undervoltage and Shunt Trip Mechanisms; and l i 3.3.1.19 Automatic Trip Logic \

1 (3) Improved TS 3.3.1 ACTION V requires immediate entry into LCO 3.0.3 if an inoperable trip mechanism, RTB, or automatic trip logic on opposite l trains are concurrently inoperable. The addition of ACTION V to the l RTBs, trip mechanisms, and Automatic Trip Logic functions ensures that if two channels become inoperable (a loss of function) appropriate action is taken immediately to place the plant in a safe condition. The addition of this condition is consistent with the STS and represents an ,

additional restriction on plant operation. '

. Vogtle Units 1 and 2 - 157 - Improved STS Conversion

l

DRAFT \

$ More Restrictive Requiremerts LCOs, ACTIONS, and SRs 3.3.1.17 Reactor Trip Breakers; and

3.3.1.'18 Reactor Trip Breaker Undervoltage and Shunt Trip Mechanisms i (4) In the event an undervoltage or shunt trip attachment is inoperable, the l first statement of ACTION 13 of CTS Table 3.3-1 allows 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to j restore it to OPERABLE status, or to declare the associated RTB 2 -- inoperable. In this case, CTS ACTION 10-would apply. With one RTB 1 inoperable ACTION 10 requires placing the unit in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . !

However, it also permits bypassing the inoperable RTB for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for i i

surveillance testing of the other channel. l l

The second statement in ACTION 13 of CTS Table 3.3-1, allows '

i bypassing a reactor trip breaker (RTB) for the time required for ;

performing maintenance to restore the trip mechanism to OPERABLE status. ;

In consideration of the first statement, it appears that under ACTION 2

13, the RTB with the inoperable mechanism could be bypassed for a l

[ significant fraction, if not all, of the 48-hour Completion Time.

1 O Because it is desirable to more clearly express the intent of the bypass allowance, the second statement of ACTION 13 has been revised and l- 7 moved in accordance with STS 3.3.1 ACTION R, as a Note in corresponding l ( N M N/ improved TS ACTION T. . This Note allows bypassing one RTB train for 2

g p/ hours for maintenancef as well as surveillance testing (already l

permitted by CTS ACTION 10). This change is considered more restrictive

,gg j because a 2-hour limit is more restrictive than a potential 48-hour l j u bypass limit. i

Improved TS ACTION U, which applies to the diverse trip mechanisms, retains the 48-hour restoration requirement and the 6-hour i

shutdown to MODE 3 requirement.

3.3.2 Engineered Safety Features Actuation Systen (ESFAS)

Instrumentation 3.3.2.2.c Containment Spray - Containment Pressure High - 3 l (5) In the event one channel of the containment pressure high-3 instrument i function is inoperable, ACTION 17 of CTS Table 3.3-2 contained no '

l specific time limit for placing the channel in bypass. Such a limit has been established in ACTION E of improved TS 3.3.2. Required Action l

E.1 allows 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to place an inoperable channel in bypass, consistent i

with the STS. This change is considered more restrictive because the CTS did not specify a time limit.

3.3.4 Remote Shutdown Systen (RSS)

(6) CTS 3/4.3.3.5.1 ACTION b, for one or more inoperable transfer switch and j control circuits, has been replaced by improved TS 3.3.4, ACTIONS A and B. These ACTIONS apply to both the monitoring instruments and the transfer and control circuits; i.e., to all remote shutdown functions.

l Vogtle Units 1 and 2 -

158 - Improved STS Conversion

L

!' DRAFI More Restrictive Requirements LCOs, ACTIONS, and SRs increase compensates for changes in the existing procedural requirement for demonstrating the pu ps are inoperable. Instead of cr"7 ;; the fftu/rsadaf l

Oaf MC motor circuit breakers .w open, the operator must verify that the, ump %

, Seveykts//+4 hand switch is in the pull-to-lock position and est at least one valve in the discharge flow path is closed. In addition, these procedural details will be contained in the associated Bases and plant procedure, l

f. in conformance with the STS. See discussion (3) under Subsection 3.2

-for discussion of the removal of procedural information from the TS.

With the pump hand switch in pull-to-lock, a closed valve in the i l

, discharge flow path isolating the safety injection pumps from the RCS, i and more frequent verification of switch and valve position, adequate

assurance is provided that the safety injection pumps will not inadvertently inject into the RCS while allowing the pumps to be more readily available to respond to a loss of inventory.fM/, *actuys (5a nA&ndi Ne of Br f4 hr4 he 3.4.13 RCS Operational LEAKAGE i (10) CTS 4.4.6.2.1.d require performing an as waw r invenwry ouianc e wn.n in j 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after entering MODE 4. This requirement has been modified in improved TS SR 3.4.13.1, consistent with the STS, to require the initial water inventory balance to be perfomed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving i steady state operation in MODE 3 or 4 and once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months thereafter.

j This is potentially more restrictive because the inventory balance may

be required sooner and more often than currently required. As explained

- in the Bases, were a transient to occur such that the 72-hour interval i plus 25% (18-hour) grace period would expire before reaching steady-j state operation, subsequent performance of'the SR would be required

within the 12-hour period after again achieving steady state operation.

This change is acceptable because steady state operation is required to l

prform a proper, useful inventory balance.

4 3.4.14 RCS PIV LEAKAGE

(11) ACTION C of improved TS 3.4.14 is a new requirement for the RCS PIV l 1eakage limit function. This ACTION addresses an inoperable RHR system i suction isolation valve interlock. Although a surveillance requirement (CTS 4.5.2.d.1) for this function was included in the CTS ECCS Operating i specification, this interlock has never been specifically addressed in the ACTIONS of the ECCS Operating or Shutdown specifications. In the ;

event the interlock is inoperable, the CTS ECCS operating specification, i 3/4.5.2, would require declaring the associated ECCS train inoperable

! and restoring it to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In contrast, new ACTION C only allows 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to restore the interlock to OPERABLE status

(the same as for any other inoperable PIV). Since the interlock i function involves the RHR PIVs, the new ACTION for this interlock

contains an appropriate but more restrictive Action.

i Vogtle Units 1 and 2 - 162 - Improved STS Conversion i

j

I .

H MAFT ,

More Restrictive Requirements LCOs, ACTIONS, and SRs (12) A time limit of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months has been added to CTS 4.4.6.2.2 as the third Frequency of corresponding improved TS SR 3.4.14.1 for testing PIVs that i

'have been actuated. This 24-hour Frequency is potentially more restrictive than the existing surveillance which specificed no time i

! limit. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is a reasonable and practical time limit for j l

! - performing this leak test, and is acceptable.

1 3.4.15 RCS Leakage Detection Instrumentation I (13) The existing RCS leakage detection instrumentation OPERABILITY l requirements in CTS 3.4.6.1 have been retained in improved TS LCO i 3.4.15, but the associated ACTIONS have been revised in conformance with l corresponding STS 3.4.15. In particular, the daily performance of an 1

RCS water inventory balance when the required containment sump monitor, :

J j radioactivity monitor, or containment air cooler condensate flow rate monitor is inoperable, has been added to the ACTIONS (improved TS l

~

Required Actions B.1, C.I.2, and D.2) as an operating condition during b

the ;; ., ,a.-hi. Q

.fjp pg p;&,

l j 3.4.16 RCS Specific Activity

(14) Improved TS SR 3.4.16.3 (corresponding to CTS Table 4.4-4, item 3, Note

- - , radiochemical analysis of E-bar) contains a new requirement to l

determine E-bar within the 31 days after a minimum of 2 effective full power days and 20 days of MODE 1 operation since the reactor was last subcritical for a 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . This 31-day condition for the initial performance of this surveillance following a plant shutdown a 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months may result in determining E-bar more often than the existing 6-month

Frequency. In addition, delaying this determination up to 31 days allows sufficient time to ensure that the radioactive materials in the reactor coolant have reached an equilibrium concer.tration fallowing the shutdown and startup transients.

l.

3.3.3.5 Emergency Core Cooling ' Systems (ECCS)

J

3.5.1 Accumulators

(

4 (1) ACTION D of improved TS 3.5.1 for the Condition of more than one accumulator being inoperable is potentia ~11y more restrictive than the

! existing ACTIONS of CTS 3/4.5.1. If an accumulator were inoperable because of a closed isolation valve, CTS ACTION b would apply. And if a l

second accumulator were inoperable for any other reason, CTS ACTION a :

l would apply also. Thus, the CTS would allow operation for a short time i i period before requiring a shutdown by either of these ACTIONS. In contrast, improved TS ACTION D would require entering LC0 3.0.3 i

l Vogtle Units 1 and 2 - 163 - Improved STS Conversion l

1

J l DMFI LCOs, ACTIONS, and.SRs More Restrictive Requirements

_(b) emergency operating procedures require decreasing AFW flow to the point where the recirculation valves on the motor-driven AFW pumps open.

2' Modification Description and Schedule Modifications to the CSTs and the AFW system for each unit are planned der my4996 to allow the AFW pump i

{O[)l recirculation flow to be routed to the CST that is supplying the AFW pump suction. This planned modification.and the revision of associated 3

j operating procedures will make the two CSTs completely redundant.

TS Change Proposal The proposed changes to current TS 3/4.7.1.3, to be reflected in corresponding improved TS 3.7.6, for the CST, are based on j the post modification CST design with two 100% capacity CSTs. The

proposed changes in the LCO, ACTIONS, and Surveillance Requirement are consisdered appropriate and acceptable for a system with two redundant CSTs.

4 Interim Specification Since the planned CST modification is not anticipated to be complete until after implementation of the improved TS, the licensee has has proposed an interim specification based on the existing design, improved TS 3.7.6a. This interim specification includes ACTIONS and surveillance requirements appropriate for the non-redundant CSTs. This specification is more restrictive because it requires maintaining 420,000 gallons of safety-related CST volume and

keeping the AFW pumps aligned to a CST with 340,000 gallons of safety-i related CST volume. pn aoamon, to ensure the safety analyses j [ sumptions for the volume required in the.TS bases are met e lic has committed to implement the following prac s in plant operatin cedures

~

4

. When the AFW are in operatio pon the level of the tank i' aligned to the AFW reac the level associated with 340,000 gallons, three o four RCPs will be stopped; I N . If CST 2 is in ser e and the tu e-driven AFW pump is not be stopped; and needed to mai n SG 1evel, the pump l 1

I . SG lev will be raised with the motor-driven umps at a flow ra sufficient to ensure the recirculation flow con valves l re closed, and if this is not possible, then the pumps be I i started and stopped as necessary to maintain SG levels. _)

Decrease in Regulatory Burden This required CST volume in improved TS , 3.7.6a is consistent with the existing design assumptions and j established operating practices at VEGP. Specification 3.7.6a will be i superceded by improved TS 3.7.6 once the licensee has implemented the I new CST AFW recirculation design. This arrangement will relieve the Vogtle Units 1 and 2 - 167 - Improved STS Conversion l l

1'!

DRAFT i i

More Restrictive Requirements LCOs, ACTIONS, and SRs

" licensee and the NRC of the burden of processing an additional license

amendment for the CST Specification within a short time after the

' improved TS are implemented.

l

' Difference Between the Current TS CST Required Volume and the CST l

Required Volume in Proposed Specification 3.7.6a The interim

- requirement for 420,000 gallons of safety-related CST volume is based on

. two main differences between thi calculation that was used as a basis

for the original 340,000 gallon requirement, reflected in the current .

TS, and current plant operating procedures. The original calculation !

assumed that the recirculation flow from the motor-driven AFW pumps j

automatically isolates after approximately one minute of operation.

However, plant procedures currently instruct the operator to throttle j AFW pump flow to the extent that the recirculation flow from the motor- ,

driven pumps will be automatically reestablished. If AFW pump suction is taken from CST V4001 initially, then the calculation did not account ;

i for the recirculation flow transferred from CST V4001 to CST V4002.

Furthermore, the original calculation assumed only one RCP running '

i whereas current operating procedures would allow all four RCPs to be i running. This requires additional water volume to accommodate the

< increased heat input to the RCS from the operating RCPs. Currently, l

because of these issues, administrative controls are in place that require both CSTs OPERABLE (both tanks > 340,000 gallons) so that

suction can be transferred to CST V4002 to recover the volume transferred by the recirculation flow.

I Finally, the requirement to maintain 340,000 gallons in the CST

! aligned to supply the AFW pumps is based on the need to ensure

' sufficient time exists for the operator to switch the AFW pump suction supply to the other CST. The requirement to maintain the AFW pumps aligned to the CST with a safety-related volume of 340,000 gallons j allows much more time than is actually required to switch AFW pump suction. With the procedural controls in place to ensure that the i unnecessary RCPs and AFW pumps are removed from operation and to ensure

! appropriate management of the recirculation flows, the poter,tial for consuming the full 340,000 gallons, thus requiring a switch to the other i CST, is significantly reduced.

Evaluation The proposed interim specification for the CST systems will i

27 apply until M _... . v. M.. x;h ti;i. ...a , J.J .; st;;; ...J C..

Jk appropriate modifications and procedure revisions have been made for pN//d/g,, .4eek unit. It contains restrictions sufficient to ensure that the l

safety analysis assumptions for the CST function will be satisfied.

Following implementation of the CST design modification, proposed l

improved TS 3.7.6 will apply. It also contains restrictions appropriate ,

for redundant CSTs to ensure that the CST function assummed in the

! safety analysis will continue to be satisfied. Therefore, the L

Vogtle Units 1 and 2 - 168 - Improved STS Conversion i

1 ,

l-4

_ + - , , - - - - .+,,--u- ,. - .--c ,1 --,,*,-,--n

4 More Restrictive Requirements LCOs, ACTIONS, and SRs l

i

^

3.9.2 Unborated Water Source Isolation Valves ,

(2) Consistent with the STS, additional requirements have been added to e ACTION b, to immediately close and secure any open or unsecured valves,

of CTS 3/4.9.1 in corresponding ACTION A of improved TS 3.9.2. These

' are Required Action A.1, to immediately suspend CORE ALTERATIONS, and Required Action A.3, to perform SR 3.9.L1 (verify boron concentration) within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The 12-hour Completion Time, although greater than the ,

i- 4-hour time given in the STS, is consistent with the current VEGP ,

i licensing basis for the performance of this surveillance as required in ACTION b of CTS 3/4.9.2 in the event both required source range monitors are inoperable. ACTION A is also modified by a Note that requires performing Required Action A.3 any time Condition A is entered, consistent with the STS. This requirement ensures boron concentration

- will be verified, regardless of how fast the affected valve is closed, 1

by preventing the Condition from being exited until Required Action A.3

. has been completed.

3.9.3 Nuclear Instrumentation

' (3) ACTION b of CTS 3/4.9.2, to determine boron concentration of the RCS every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months in the event both source range monitors are inoperable, has been retained as Required Action B.2 of corresponding improved TS

3.9.3. In addition, ACTION b has been revised to also require

. initiation of action to restore one monitor to OPERABLE status immediately in Required Action B.1, consistent with the STS.

l 3.9.5 'RHR and Coolant Circulation - High Water Level i e-j l h )

(4) Note

to CTS 3.9.8(1, an allowance to remove the RHR train from operation for up to y hour per 8-hour period, is been retained as a Note to improved TS LCO 3.9.5. In addition, it has been made more

, restrictive by adding a provision that prevents any action from being taken that might reduce the boron concentration while the RHR Loop is out of service. In this condition, without forced circulation, uniform j

boron concentration in the RCS can not be assured. This change is j

consistent with the STS.

l Refueling Cavity Water Level

~

3.9.7 1

(5) The Applicability of CTS 3/4.9.10.1, for reactor vessel water level during movement of fuel assemblies or with irradiated fuel assemblies seated within the reactor vessel, has been increased in corresponding

! improved TS.3.9.7, the refueling cavity water level specification, 2 consistent with the STS. The additional restriction of "During CORE j ALTERATIONS, except during latching and unlatching control rod drive i Vogtle Units 1 and 2 - 175 - Improved STS Conversion 4

+ - w a - , , - ---

i

~ *

DRAFT ,

Relocated Specifications LCOs, ACTIONS, and SRs i

3/4.9 Refueling Operations (18) Decay' Time r 4

This specification places a time limit on reactor subcriticality prior to the movement of irradiated fuel assemblies in the reactor vessel.

- This ensures that sufficient time has elapsed for the radioactive decay ,

of short-lived fission products and is consistent with the assumptions used in the safety analysis. However, the schedule restraints of the ;

activities required prior to moving irradiated fuel in the reactor - l vessel after a shutdown prevents the time limit of this specification from being exceeded. The preparations for moving fuel include RCS cooldown, depressurization, boration, removal of the reactor vessel head l

and upper internals and flooding the reactor cavity to the required level. Thus, in practice, it not physically possible to violate the ;

// time limitation of this spec ication. Therefore, CTS 3/4.9.5 may be

/ relocated to the TRM. l

'(19) Communications

~

/

i This specification requires communication between the control room and

the refueling station, to ensure that any significant change in the

. facility status observed on the control room instrumentation can be i

communicated to the refueling station personnel. However, this

communication is not credited in any DBA or transient analyses.

Therefore, CTS 3/4.g.5 may be relocated to the TRM.

l (20) Refueling Machine

! x l

This specification ensures that the refueling machine and auxiliary i

hoist in the containment will have sufficient load capacity for their

! intended purposes and will be used correctly during refueling.

Additionally, this specification ensures that the core internals and re:ctor vessel are protected from excessive lifting force during l

refueling operations. Although this specification contains requirements designed to prevent damage to fuel assemblies, core internals, and the ;

reactor vessel, these requirements are not relied upon to prevent or l i mitigate the consequences of the design basis fuel handling accident in !

the containment. The limitations of this specification only apply to design requirements. Design control requirements are adequately governed by regulation and the licensee's quality assurance plan. These requirements need not be repeated in the TS. Therefore, CTS 3/4.9.6 may j be relocated to the TRM.

[ Vogtle Units I and 2 - 230 - Improved STS Conversion 4

, .l DRAFT :

' Administrative Controls 50.54(m)(2)(iv) and repeating it in TS is not necessary to ensure safe i operation of the facility.

5.5 Programs and Manuals :

5.5.6 Prestressed Concrete Containment Tendon Surveillance Progran d

'(13) CTS 3.6.1.6, " Containment Structural Integrity," requires maintaining ,

i the structural integrity of the prestressing tendons of the containments consistent with the acceptance criteria of associated specification 4.6.1.6, " Containment Prestressing System" (which has a more appropriate i title). Also associated with CTS 3.6.1.6 are action requirements in the event the criteria are not satisfied. '

However, this LCO represents just one aspect of containment OPERABILITY, which is required by improved TS 3.6.1, " Containment."

Thus, this requirement is retained as improved TS LCO 3.6.1

(" Containment shall be OPERABLE.") and associated SR 3.6.2, regarding verifying the structural integrity of the containment in accordance with a new programmatic specification, improved TS 5.5.6, " Prestressed

Concrete Containment Tendon Surveillance Program." Thus, failure to meet the program is failure to meet the containment LCO.

The detailed information contained in CTS 4.6.1.6 for performing the tendon surveillances has, therefore, been relocated to the specified l (Note that this corresponds to less program and associated procedures.

j restrictive change type 3 as defined inthe general discussion of less restrictive requirements at the beginning of Part III of this safety i

(tsa) s.s.nevaluation.)fyphsia Ga ad Skye we Ak%ctiry y awinty i

l 9 5.5.17 Containment Leakage Rate Testing Progran l

l (14) The licensee has proposed to adopt Option B of Appendix J to 10 CFR Part i 50. As required for adopting Option B, the licensee has proposed adding a containment leakage rate testing programmatic specification in the administrative controls chapter of the TS. The adoption of Option B

! and this specification is fully addressed in discussion (1) of

Subsection 3.2.3.6 of Part III of this safety evaluation.

5.6 Reporting Requirenents i

(15) Consistent with the STS, the requirement of CTS 6.8.1.1 to submit a !

startup report to the NRC has been deleted from the TS. This report

< required no staff approval and was submitted following startup.

Therefore, it does not contribute to safe operation of the facility.

1 The approved quality assurance plan and the FSAR startup testing program will ensure that the activities associated with the preparation of this report are adequately performed and that appropriate corrective actions, if required, are taken.

l Vogtle Units 1 and 2 - 246 - Improved STS Conversion 4

ENCLOSURE 2 GPC COMMENTS ON DRAFT SAFETY EVALUATION OF PROPOSED TECIINICAL SPECIFICATIONS -

VOGTLE ELECTRIC GENERATING PLANT UNITS 1 AND 2 NRC LETTER DATED FEBRUARY 1,1996

1. The proposed change reflects the actual wording of the improved TS.

2. The proposed change corrects a typographical error.

3. The proposed change clarifies the applicability ofimproved TS LCO 3.7.6.

4. The valves must be administratively controlled when they are open whether a purge or vent operation is in progress or not.

5. The proposed change reflects the actual wording of the improved TS Bases.

6. The referenced STS difference was withdrawn with our revised submittal.

E2-1

FEB-00-1996 16:33 FROM VOGTLE TECH. SUPPORT TO SNC ENG/LIC P.02 STS Differences LCos, ACTIONS, and SRs l I

3.2.4 QuadrantPowerTiltRetfo(QPTR) l (7) The wording of STS 3.2.4, Required Act16n A.1, has been revised from l 1

1 Reduce THERMAL POWER to LM RTE _ for each 1% of QPTR > 1.00. LQ ;

i f Lieft THEIMAL POWER to 1 35*RTP for each 15 of QPTR > 1.00.

It is not unusual, upon startup, for QPTR to be > 1.02 because of transient core conditions. These transient conditions are usually self-correcting as a direct result of power ascension. Since ACTION A of STS it is 3.2.4 prpvides for continued operation for anlicability unlimited period,3.2.4 of STS acceptable per STS LCO 3.0.4 to enter the ;

with in excess of 1.02 provided the utred Actions are met.

Statt Required Action A.1~,to require ifeft ny rather than reduefag l

THE . POWER is more compatible with the case where the Applicability of STS 3.2.4 is entered with QPTR in excess of 1.02.

(8) STS 3.2.4 Required Action A.2 has been adopted as Required Actions A.2.1 ,

and A.2.2 in order to make it clear that if the once-per-12-hour 0PTR measurement determines that an additional reduction in power is required, below the level initially determined by Required Action A.1then 2 Note has been added to the Completion time column to clarify that the 2-hour Completion Time of Required Action A.2.2 begins upon completion of the 12-hour QPTR measurement. These differences from STS Required Action A.2 are considered clarifications of the intent of the STS and are acceptable.

(9) As discussedthe evaluation, in Subsection initial Completion 3.2.3.2 ofTim!forart III 3.2.4 STS of this safeted Action Requi A.3 hasbeenmodifiedfrom"24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months "to"24hoursafterachieving equllibrium conditions with THERMAL POWER limited by Required Action i A.1," in improved TS 3.2.4, Required Action A.3. i

' l (10) A new Note would be to clarify that added to STS improved TS3.2.4 ACTION 3.2.4 R uiredAAction in the condition A.6 must be !

column, complete d whenever Required Action A.5 is i lesented. This is based on i the concern that completion of Required Acti n A.5 would restore compliance,with the LC0 and Required Action A.6 would never be

, perforsid.

(11) Required Action A.5 of STS LC0 3.2.4 states that the excore detectors should be calibrated to show zero QPTR. Quadrant power tilt is expressed in terms of a ratio. Thus, the absence of a tilt will manifest itself as GPTR - 1.00 rather than zero. Therefore Reouired Action A.5 of improved TS 3.2.4 requires calibrating to s$ow QPTR - 1.00.

1 (12) The-Note of the CTS 1 definition to STS SR of QPTR13.2.4.1 (which is adopted has been consistent with the last in improved TS SR sentence I 3.2.4.1 but has been revised ho reflect the fact'that the three-channel l power level above 50% RTP not .1ust below i measurementisvalidatadnR 755 RTP. When THERMAL P0 is 1 755 RTP, the incore, detectors are used j Vogtle Units 1 and 2 - 169 - Improved STS Conversion i

! ORAFT

____._._.___-_____m__._.________________.__m- - - - - - - - _ -- -- -v--- -

, FEB-08-1996 16:34 FROM UOGTLE TECH. SUPPORT TO SNC EMPLIC P.03 5T5 Differences LCOs, ACTIONS, and SRs 1

J 3.b Containment Isolation - Phase B Isolation

- 4.e and Steam Line Isolation - High Steam Line Flow in i 4.f Two Steam Lines

4.e and Steam Line Isolation - High Steam Line Flow l 4.fi 1 6.b Auxiliary Feedwater - Automatic Actuation Logic and j Actuation. relays 6.f Auxiliary Feedwater - Un(8alance of Plant ESFAS1dervaltage ant Pump Re

6.h Auxiliary Feedwater - AFW Pump Suction Transfer on Section Pressure - Low i 7.c Automatic $witchever to Containment Sump - RWST Level - Low l 8.c ESFAS Interlocks - - Low Low i 8.d E5FAS Interlocks - atorLeveiP-12High High, P-14 y ,

i these functions have not been adopted in Specification 3.3.2.

Therefore,in The Notes Table 3.3.2-1 have been renumbered accordingly. p ots o

]

l (17) The ESFAB action statements in the CTS allow bypassing "a channel" and are not 'imited to "the in rable channel." The corresponding Notes i the improved TS 3.3.2 ACTI_ c D. L C. H. I. and K hawa '-- revis 2

1

- to agree with the CTS. A1 instrumentation functional groups i

I exc t Number 8 unctions ESFA5 Inte 1.b,1.c, reflectand this STS 2.bdifference.

1 1.o; and 2.c; 3. )-

5 ifical

, , 4.c, a ,4.d;5.a,5.b.and$.c.d ;i.aand6.b;and7.aand7(..j i

3.3.2.1.a safe injectton - Manual Inftiation; 3.3.2.2.a Cent neent ray - Manual Enitiation I

3.3.2.3.s Phase A Cent neentisolation-Manushinitiation; Staan line Isolation - Manual initiation; and l 3.3.2.4.a 3.3.2.8.a ESFAS Interlocks - Reactor Trip, 9-4 l

f (18) The word " train" in STS ACT!0NS B and F and Function 2.a of Table 3.3.2-1 were not adopted, consistent wIth the CTS terminology for i

single hannel trains.

I j 3.2.2.4 Steen line Esolation

! (Ig) At VEGP, each steam line has two isolation valves in series. Each

1 solation valve has a bypass valve associated with it. Only onc isolation valve and associated pass must be closed to isolate a steam

line. App 11cabilit Note (1, o STS Table 3.3.2-1 has not been adopted.

l Instead corres i Note i of Table 3.3.2-1 retains the re Utrement of Notation"f f CTS Table 3. -2, to be consistent with VEGP d sign.

i l

3.3.2.5 Turbine Trip and feeduster !selstion

(20) At VEGP, each feedwater line has two isolation valves (includes the in feedwater series. Each regulating isolationvalvevalvewhich has a is a credited bypass valveisolation associated at VEGP)it.

with

Only one isolation valve and associated bypass must be closed in each feedwater line to isolate feedwater. Applicability Note j of STS i Table 3.3.2-1 has not been adopted. Instead correspond 1 te f of

! Table 3.3.2-1 has been adopted to be consistent with VEGP desien(. )This new VEGP-specific Note recoenizes that V t1e has two main isoTation valves per main feedwater IIna (NFIV and FRV) each with its own bypass Vogtle Units 1 and 2 - 175 - Improved STS Conversion

[

\ . !

_ __ . _ _ _ - _ _ _ _ _ . ~ _ . _ _ . . . _ _ _ _ __ _ __.

l

..e l i

j STS Differences DMFI LCOs, ACTIONS, and SRs i

are consistent'with the ACTIONS in CTS Table 3.3-8 and CTS 3/4.3.3.6, which clearly define the diverse channel OPERABILITY requirements. t Second the format and presentation of the roposed ACTIONS more- l 4

closelymatebtheformatandpresentationofthe$TSreactor.tripsystem !

RTS) TS and ESFAS TS. The VEGP specific ACTIONS work the same way i i

same Condition A to reference applicable Conditions from the Table) as ;

i he STS RTS and ESFAS specifications. Since the STS PAM TS use a different format and addresses the Conditions listed on the associated '

Table diff6rently than the STS RTS and ESFAS TS, the VEGP specific PAM -

1 ACTIONS represent a human factors and consistency improvement over the STS PAM TS. Note that this change combined with the proposed ACTIONS ,

t Table change in the Remote Shutdown TS make all the VEGP instrument TS i

ACTIONS Tables work and look similar.

Third, the proposed ACTIONS Conditions contain Notes for the .

' containment isolation valve position indication channels. The Notes allow the Condition to be entered on a per penetration basis for this function. Without this allowance, Condition entry for a second valve position indication channel on a different penetration could be '

interpretedtobegrohibitedbytheConditionwordingof"Onerequired channel inoperable . This change is considered a clarification of the ,

4 intent of the STS to allow this Condition to be entered on a per ,

penetration basis. The addition of this Note is consistent with the i application of this type of Note in other areas of the STS for similar l purposes.

l (30) The phrase in STS SR 3.3.3.1 "that is normally energized" describing PAM l

instrument functions requiring a CHANNEL CHECK has been omitted from SR -

L 3.3.3.1. All PAM instrument channels listed in improved TS Table 3.3.3- :

I are.normally energized. Thus, this condition to the SR is not !

necessary at VEGP. shed o/& cong,y/N//artc,M m ap ,e rupacNet inepAwrardds4 (a)koflevel ins mentation is required OPERABLE to be

- l . 3-1 clarifies that only one set of

{ (31) VEGP-specific condensate storage Notetan consistent with Specification 3.7.6 wh4e> requires only one of the two condensatestoragetanksineachunItto OPERABLE. This Note is not '

found in STS Table 3.3.3 because only one ank is assumed in the plant l

l desi n u)on which the STS is based. Accor ingl , (b) 4

! and c ? 1 ave been renumbered as (b), (c), and (y}

d in STSimprov Notes h{S Table '

f 3.3. a.

! Spac;&wm s.n, l

3.3.4 Renote Shutdown System l (32) Theword"monitoringCK,"

3.3.4.1, CHANNEL CH hasSR and been inserted 3.3.4.3, CHANNEL in the STS wording CALIBRATION, to of SR J

- describe to which instrumentation these surveillances apply. VEGP-specific Table 3.3.4-1 contains two types of instruments, Monitoring" and " Transfer and Control Circuits". SR 3.3.4.1 and SR 3.3.4.3 apply

instrument channels. This clarification f

only to indicating is consistent with CTS 4.3.3.5. (monitoring)1.a and 4.3.3.5.1.b, and also the intent m of the STS.

3.3.5 4.16 kV ESF Bus Loss of Power (LOP) Instrumentation t

5 (33) The ACTIONS of improved TS 3.3.5 differ from the ACTIONS of STS 3.3.5 because of plant-specific design and existing TS requirements that have Vogtle Units 1 and 2 - 178 - Improved STS Conversion L DRAFE

. I STS Differences LCOs, ACTIONS, and SRs 1

STS 3.3.5 ACTIONS Improved TS 3.3.5 ACTIONS t'

E.1 Enter applicable

, C.1 Enter applicable and and Condition Required Act (s) ion (s) for 1

Required Act(s)

Condition ion ) for the associated DG made the associated made inoperable by. LOP DG inoperable by LOP DG start instrumentation.

start instrumentation. Immediately

,' Immediately The licensee stated that the STS phrase "per bus" could be interpreted )

! to mean that channels on ESF buses must be inoperable in order for STS Conditions A or B to a p y. To prevent this misinterpretation this phrase has been replaced b hephrase"ononeorbothbuses"whic$more

clearly describes the situation addressed by STS Conditions A and B. In addition, the word "only" has been added to render Condition A exclusive j with respect to the other conditions in which multi le channels are inoperable. This was necessary because with multip e channels

inoperable, placing more than one channel of one function on the same bus in trip would result in actuation of the diesel generators, which l d

was not the intent of STS Re uired Action A.I. ;

Condition B has been d vided into improved TS Conditions B and C. 1

Improved TS Condition B clearly addresses the situation in which one or '

2 two functions with two or more channels inoperable on a sd nale bus. '

Once in this Condition, the affected instrument function (loss of or degraded volta e) y no lon er be sin le failure proof or may no longer

+

be functional or e affect d bus. I this case,d o S eration ACTION inB the allows i Applicability of the LCO must be limited. Improve

. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to restore the instrument function to the capability of

continued operation permitted by ACTION A. The 12-hour Completion Time i is based on the improved TS allowance for an inoperable ESF bus load sequencer. This time is appropriate because the affected instrument i

channels (loss of or degraded voltage) are inputs to the load sequencer 3 and rel on. sequencer circuits to perform their re uired actuations.

Thus, t e inoperability of more than one channel o either the loss of t voltage or degraded voltage function, associated with a given ESF bus, is no worse than the inoperabilit of a load sequencer associated with

that bus. Since the actuation lo ic and relays for the loss of power

' instruments (both AF pump and diesel generator start) are an integral l part of the sequencer, an inoperable sequencer may prevent the loss of f j ower instruments from performing their intended functions. Therefore l l

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months provides a reasonable and consistent Completion Time, based on .

- the time allowed for an inoperable sequencer, for these instruments when Condition B becomes applicable. l

Improved TS Condition C corresponds to the situation in which bath buses each have at least one function with at least two inoperable channels. In this Condition, STS Required Action B.1 has been revised

to require restoring at least three channels of the affected function to

OPERABLE sta ne of the buses within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The effect of this action woul e eturn to the situation addressed by improved TS Condition B. .adMr avided its 12-hour Completion Time has not expired.

I

111ty of STS 3.4.10 is not applicab EGP. ] 3.4.10 Pressurizer Safety Valves; and 3.4.12 Cold Overpressure Protection Systems (C0PS) (9) of STS 3.4.10 and STS 3.4.12 TheMODE4Applicabilitf75'Fands275'F,respectively)(MODE cold leg temperature > 4withRCS has not been , ado >ted because the VEGP cold overpressure protection system (COPS) I enaple temperature is 350*F, the transition temoerature between MODES 3 and 4. The COPS is required to be OPERA 8LE in N00ES 4, 5, and 6 with 1 Vogtle Units 1 and 2 - 184 - Improved STS Conversion RAFT' l_ _ _ _ _ _ _ _ _ _ _ _ _ - .___- _____ . - - _ _ . -. - . - _ . - _ . [:.. STS Differences LCOs, ACTIONS, and SRs Specification 3.6.3 are listed in FSAR table 16.3-4. None of these

valves are associated with closed systems. Rather, the associated

, system TS governs OPERABILITY of such valves. Therefore, there is no need for STS Condition C and no need for the Notes to Conditions A and B. Accordingly, these provisions have not been adopted. . In addition, STS ACTION D, pertaining to shield building leakage, does not appl to the VEGP design, and has also not been ado ted. STS an in ACTIONS Specificat E, ion 3.6.3.F have thus been designated as ACTIONS C and (4) CTS 4.6.1.7.2, leak test requirement for valves with resilient seals (containment ventilation purge and exhaust onisolation valvestoatchangeVEGP)the July 7, 1995, 2 was revisedfrom Frequency by Amendment 3 months to.18 Nos. 89 andre67, fueling outage).Corresponding months improved TS SR 3.6.3.6 retains this 1 -month Frequency. Consequently - the 92-da FrequencyofcorrespondingSTSSR3.6.3.6andRequiredActIon E.3 of ST 3.6.3, with its 92-day periodic Completion Time for performing this surveillance when such valves are used for isolating an

inoperable penetration, have not been adopted. The licensee has proposed to retain the existing requirement and will not backfit. The ,

18-month Frequency of purge valve leakage testing ensures that a purge l' valve with resilient seals used for isolation in accordance with . improved TS 3.6.3 ACTION C (correspondin to STS ACTION E), will be in thecurrenttestInterval i.e., OPERABLE in the event its isolation i function is needed. There ore,-this STS ifference is acceptable. l (5) As previously addressed in discussion (14? of Subsection 3.2.3.6 of Part ' ! . III of this safety evaluation, the conditions under which CTS 3.6.I.7.b - allows the 14-inch pu ge valves to be o ened have been broadened in ! correspondin rove TS SR 3.6.3.2. he revised conditions stipulate, i' gfw sM however, tha 4 e n: V inis change is 1 inistrativ contro s rest

f th.

ctive tE. p man the .xt :;:. 1 m conditions given in . STS;SR 3.6.3.2 for opening 14-1 valves. , } (6) Note 2 to SR 3.6.3.4 is no ntain $STSSR3.6.3.4,butis l consistent with the last sentence of Note

to CTS 4.6.1.1.a. This Note :

~ L clarifies the requirement for checking the blind flange on the fuel transfer canal (7) Specification 3.6.3 omits the following STS surveillances that do not ' appl to the VEGP design: SR 3.6.3.6, SR 3.6.3.9, SR 3.6.3.10, and SR L 3.6. 11. STS SR 3.6.3.7 and SR 3.6.3.8 have according y been

desi nated SR 3.6.3.6 and SR 3.6.3.7, respectively, in pecification

3.6. .

l 1 3.6.6 Containment Spray and Cooling Systems , i (8) Consistent with CTS 3/4.6.2.1 and 3 4.6.2.3, im roved TS 3.6.6 does not contain ACTIONS D E and F of STS .6.6. But TS ACTIONS A,dop,ted B and C, with $ correspondingtoImpr,ovedTSACTIONSA,C and B, have been a 4 the following difference. ACTIONBspecifies3 days,not7 days,to restore an inoperable cooling train to OPERABLE status. : i 4 Vogtle Units 1 and 2 - 190 - Improved STS Conversion j i DMFT l I e STS Differences LCOs, ACTIONS, and SRs i moisture content accumulated in the filters has been reduced to less 4 than or equal to 70% relative humidity (an assumption of the applicable safety analysis).

(20) CTS 4.7.6.a, the VEGP-specific surveillance to monitor control room air temperature every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months has been retained as SR 3.7.10.1. This surveillanceensuresthatthecontrolroomcoolingfunctionoftheCREFS is OPERABLE. The VEGP CREFS contains the cooling coils that provide control room air temperature control after a control room isolation

! (CRI). The chilled water is supplied by the essential chilled water I system which is covered by CTS 3/4.7.11, "ESF Room Coolers and Safety- " that has been retained as Specification . I 'Related 3.7.14. Chiller Systems, The essential c hilled water system supplies other systems in l addition to the CREFS. The maintenance of the control room air - l temperature below 85'F ensures the operational re j -located in the control room will not be exceeded.quirements of equipment The design cooling ; capacity of the essential chilled water system combined with the CREFS '

- and the limitation of the normal control room ambient temperature (before CRI) ensure the capability of the CREFS to maintain the control i

room temperature within limit after a CRI. 3.7.14 ESF Roon Cooler and Safety-Related Chiller System (21) CTS 3/4.7.11 for the ESF room cooler and safety-related chiller system has been retained as VEGP-specific Specification 3.7.14, which is not

contained in the STS.

3.4.3.8 Electrical Power Systems General

3.8.1 AC Sources - Operating

(1) The automatic load sequencers are listed in STS LCO 3.8.1 as AC Sources.

Although an automatic load sequencers may affect an AC Source, it does not constitute an AC Source distinct from the offsite circuits and diesel generators. Thus, LC0 3.8.1 has been worded differently from STS ' LCO 3.8.1 to diffarantiate the automatic load sequencers from the list of AC Sources $r acfWifier sued M E4 pm&w W &y & 4 (2) The ACTIONS of Specification 3.8.1 differ from the ACTIONS of STS 3.8.1 I because of the reliance on the standby auxiliary transformer to l justify longer allowed outage times (A0Ts) for a diesel genera tor (SAT)(DG) ! in one unit at a time. S improved TS ACTIONS C and H are not contained in the STS.pecifically, G becomes inoperable and the SAT Anytime a D is verified to be available as a backup standby AC source, ACTION C + allows 7 days to restore the DG to OPERABLE status. Once_oer re#ueling i cycle each DG may be made inoperablejsoji ry wi ne 1 nttoruc + I penrunn ,v u a (i .i nartMT tear wn e[ma m insu [u,tion 9 pro.-L videdantana the SAT is ava'lable as a backup ms nt = stanaoy a source, oy entering ACTION H, instead of ACTION C. ACTION H specifies either a 14-day or a 21-day A0T to complete the maintenance 1 and to restore the DG to OPERABLE status. Specification 3.8.1 also I .contains Notes at the beginning of the ACTIONS table and in ACTIONS A, B, C, and H to specify the correct use of these VEGP-specific ACTIONS. i !' -Vogtle Units 1 and 2 - 196 - Improved STS Conversion l DRAFT

ML20100G037

Text

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