NL-21-0925, Adoption of TSTF-269-A, Revision 2, Allow Administrative Means of Position Verification for Locked or Sealed Valves

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Adoption of TSTF-269-A, Revision 2, Allow Administrative Means of Position Verification for Locked or Sealed Valves
ML21356B499
Person / Time
Site: Vogtle, Farley  Southern Nuclear icon.png
Issue date: 12/22/2021
From: Gayheart C
Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-21-0925
Download: ML21356B499 (35)
v • d • e


Text

Cheryl A. Gayheart 3535 Colonnade Parkway Regulatory Affairs Director Birmingham, AL 35243 205 992 5316

cagayhea@southernco.com

December 22, 2021

Docket Nos.: 50-348 50-424 NL-21-0925 50-364 50-425

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001

Southern Nuclear Operating Company Farley Nuclear Plant Units 1&2 Vogtle Electric Generating Plant Units 1&2 Adoption of TSTF-269-A, Revision 2, Allow Administ rative Means of Position Verification for Locked or Sealed Valves

Ladies and Gentlemen:

Pursuant to 10 CFR 50.90, Southern Nuclear Operatin g Company (SNC) hereby requests a license amendment to the Joseph M. Farley Nuclear P lant (FNP) Unit 1 Renewed Facility Operating License (RFOL) NPF-2 and Unit 2 RFOL NPF-8, and the Vogtle Electric Generating Plant (VEGP) Unit 1 RFOL NPF-68 and Unit 2 RFOL NPF -81. The proposed amendment is consistent with NRC-approved Technical Specificatio n Task Force (TSTF) Traveler 269-A, Revision 2, Allow Administrative Means of Position Verification for Locked or Sealed Valves.

The proposed changes modify Technical Specification (TS) 3.6.3, Containment Isolation Valves. Consistent with TSTF-269-A, Notes would b e added to allow isolation devices that are locked, sealed or otherwise secured be verified by use of administrative means.

Approval of the proposed amendment is requested wit hin one year of completion of the NRCs acceptance review. Once approved, the amendment sh all be implemented within 60 days.

In accordance with 10 CFR 50.91, a copy of this app lication is being provided to the designated Alabama and Georgia Officials.

This letter contains no regulatory commitments. If you have any questions, please contact Ryan Joyce at 205.992.6468.

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ENCLOSURE

Farley Nuclear Plant - Units 1 and 2 Vogtle Electric Generating Plant - Units 1 and 2

Adoption of TSTF-269-A, Revision 2, Allow Administrative Means of Position Verification for Locked or Sealed Valves

Evaluation of the Proposed Changes

Enclosure to NL-21-0925 Evaluation of the Proposed Changes

1

SUMMARY

DESCRIPTION

Southern Nuclear Operating Company (SNC) hereby requests a lice nse amendment to the Joseph M. Farley Nuclear Plant (FNP) Unit 1 Renewed Facility Op erating License (RFOL)

NPF-2 and Unit 2 RFOL NPF-8, and the Vogtle Electric Generating Plant (VEGP) Unit 1 RFOL NPF-68 and Unit 2 RFOL NPF-81. The proposed amendment is consi stent with NRC-approved Technical Specification Task Force (TSTF) Traveler 269-A, Revis ion 2, "Allow Administrative Means of Position Verification for Locked or Sealed Valves (Reference 1).

The proposed changes modify Technical Specification (TS) 3.6.3, Containment Isolation Valves. Consistent with TSTF-269-A, Notes would be added to a llow isolation devices that are locked, sealed or otherwise secured be verified by use of administrative means.

2 DETAILED DESCRIPTION

2.1 Description of the Proposed Change The proposed change modifies TS 3.6.3, Containment Isolation V alves. This specification requires penetration flow paths with inoperable isolation devic es be isolated and periodically verified to be isolated. Consistent with TSTF-269-A, Revision 2, notes are proposed to be added to FNP TS 3.6.3, Required Actions A.2, C.2 and D.2, and VEGP TS 3.6.3, Required Actions A.2 and C.2, to allow isolation devices that are locked, sealed, or otherwise secured to be verified using administrative means.

SNC is proposing the following variations from the TS changes described in TSTF-269-A. There are two differences in the Required Action identifiers between TSTF-269-A and the FNP TS and the VEGP TS. TSTF-269-A identifies a change to TS 3.6.3 Require d Action E.2. The equivalent action in the FNP TS is Required Action D.2. The equivalent Required Action in the VEGP TS is C.2. These Required Actions are equivalent, and the identifier differences do not affect the applicability of TSTF-269-A to FNP or VEGP. In addition, the VEGP TS do not contain a Condition equivalent to Condition C in TSTF-269-A. Therefore, that change is not applicable to VEGP.

3 TECHNICAL EVALUATION

3.1 Summary of the Approved Traveler Justification The purpose of the periodic verification that a penetration wit h an inoperable isolation valve continues to be isolated is to detect and correct inadvertent r epositioning of the isolation device.

However, the function of locking, sealing, or securing an isola tion device is to ensure that the device is not inadvertently repositioned. Therefore, it is sufficient to assume that the initial establishment of component status (e.g., isolation valves close d) was performed correctly and subsequent periodic re-verification need only be a verification of the administrative control that ensures that the component remains in the required state. It is unnecessary and undesirable to remove the lock, seal, or other means of securing the component solely to perform an active verification of the required state as it would increase the cha nce of mispositioning due to the frequent manipulation.

The justification presented in approved Traveler TSTF-269-A is applicable to FNP and VEGP.

The Traveler is being adopted by FNP and VEGP with no changes beyond that described above in Section 2.1.

E-1 Enclosure to NL-21-0925 Evaluation of the Proposed Changes

The NRC implemented the approved Traveler, and its contents are reflected in NUREG-1431, Revision 5.

4 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met.

The regulations of Title 10 of the Code of Federal Regulations (10 CFR) 50.36, Technical Specifications, establish the requirements related to the content of the Technical Specifications.

Section 50.36(c)(2) states: When a limiting condition for operation of a nuclea r reactor is not met, the licensee shall shut down the reactor or fo llow any remedial action permitted by the technical specifications until the condition can be met. There is no regulatory requirement that specifies what remedial actions are to be taken whe n a limiting condition for operation is not met. The proposed changes remove an operational res triction not needed for safety. The proposed changes are consistent with the Standard W estinghouse Technical Specifications (i.e., NUREG-1431).

4.2 Precedent Precedent for a plant-specific NRC approval of the changes in TSTF-269-A includes:

Brunswick Steam Electric Plant (Reference 2)

4.3 No Significant Hazard Consideration Determinati on Analysis Southern Nuclear Operating Company (SNC) has evalua ted the proposed changes to the Technical Specifications using the criteria in 10 C FR 50.92 and has determined that the proposed changes do not involve a significant hazar ds consideration.

The proposed amendment is consistent with NRC-appro ved Technical Specification Task Force (TSTF) Traveler 269-A, Revision 2, Allow Administr ative Means of Position Verification for Locked or Sealed Valves. The proposed changes mod ify Farley Nuclear Plant (FNP) and Vogtle Electric Generating Plant (VEGP) Technical S pecification (TS) 3.6.3, Containment Isolation Valves by adding Notes to allow isolatio n devices that are locked, sealed or otherwise secured be verified by use of administrative means.

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

1) Does the proposed change involve a significant i ncrease in the probability or consequences of an accident previously evaluated ?

Response: No

The proposed change modifies TS 3.6.3, Containment Isolation Valves. This specification requires penetration flow paths with inoperable isolation devices be isolated and periodically verified to be isolated. Consistent with TSTF-269-A, Revision 2, Notes are proposed to be added to FNP T S 3.6.3, Required Actions A.2, C.2 and D.2, and VEGP TS 3.6.3, Required Actions A. 2 and C.2, to allow isolation devices that are locked, sealed, or otherwise secur ed to be verified using administrative means. The proposed change does not affect any plant equipment, test methods, or plant operation, and is not an ini tiator of any analyzed accident

E-2 Enclosure to NL-21-0925 Evaluation of the Proposed Changes

sequence. The inoperable containment penetrations will continue to be isolated, and hence perform their isolation function. Operation in accordance with the proposed Technical Specifications will ensure that all analyzed accidents will continue to be mitigated as previously analyzed.

Therefore, the proposed changes do not involve a significant in crease in the probability or consequences of an accident previously evaluated.

2) Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No

The proposed changes do not involve a physical alteration to th e plant (i.e., no new or different type of equipment will be installed) or a change t o the methods governing normal plant operation. The changes do not alter the assumptions made in the safety analysis.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3) Does the proposed change involve a significant reduction in a margin of safety?

Response: No

The proposed change will not affect operation of plant equipment or the function of any equipment assumed in the accident analysis. Affected contai nment penetrations will continue to be isolated as required by the existing Technical Specifications.

Therefore, the proposed change does not involve a significant r eduction in a margin of safety.

4.4 Conclusion In conclusion, based on the considerations discussed above, SNC concludes: (1) there is reasonable assurance that the health and safety of the public w ill not be endangered by operation in the proposed manner, (2) such activities will be c onducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or the health and safety of the pub lic.

5 ENVIRONMENTAL CONSIDERATION

The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, and would change an inspection or surveillance requirement. However, the propose d change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released of fsite, or (iii) a significant increase in individual or cumulative occupational radiation exp osure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusio n set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed cha nge. Accordingly, the

E-3 Enclosure to NL-21-0925 Evaluation of the Proposed Changes

amendment meets the eligibility cri teria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6 REFERENCES

1. Technical Specification Task Force (TSTF)-269-A, Rev 2, Allow Administrative Means of Position Verification for Locked or Sealed Valves, ap proved July 26, 1999.
2. Letter from Nuclear Regulatory Commission to Brunswick Steam El ectric Plant, "Issuance Of Amendment Nos. 296 And 324 To Adopt Technical Spec ification Task Force Traveler TSTF-269-A, Revision 2, "Allow Administrative Means Of Position Verification For Locked Or Sealed Valves," dated November 21, 2019

[ML19281A330].

E-4 Southern Nuclear Operating Company Farley Nuclear Plant - Units 1 and 2

Adoption of TSTF-269-A, Revision 2, Allow Administrative Means of Position Verification for Locked or Sealed Valves

Attachment 1a

Proposed Technical Specification Changes (Marked-up Pages)

Containment Isolation Valves 3.6.3

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. ------------NOTE------------- A.1 Isolate the affected 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Only applicable to penetration flow path by penetration flow paths use of at least one closed OR with two containment and de-activated isolation valves. automatic valve, closed In accordance with

manual valve, blind the Risk Informed flange, or check valve Completion Time One or more penetration with flow through the Program flow paths with one valve secured.

containment isolation valve inoperable except AND for purge valve penetration leakage not A.2 -------------NOTES-----------

within limit. 1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per 31 days for penetration flow path is isolation devices isolated. outside containment

AND

Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment

Farley Units 1 and 2 3.6.3-2 Amendment No. 225 (Unit 1)

Amendment No. 222 (Unit 2)

Containment Isolation Valves 3.6.3

ACTIONS

CONDITION REQUIRED ACTION COMPLETION TIME

C. ------------NOTE------------ C.1 Isolate the affected 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Only applicable to penetration flow path by penetration flow paths use of at least one closed OR with only one and de-activated containment isolation automatic valve, closed In accordance with valve and a closed manual valve, or blind the Risk Informed system. flange. Completion Time

Program AND One or more penetration flow paths with one C.2 -------------NOTES-----------

containment isolation 1. Isolation devices in valve inoperable. high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per 31 days penetration flow path is isolated.

Farley Units 1 and 2 3.6.3-4 Amendment No. 225 (Unit 1)

Amendment No. 222 (Unit 2)

Containment Isolation Valves 3.6.3

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

D. One or more penetration D.1 Isolate the affected 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> flow paths containing penetration flow path by containment purge use of at least one valves, with penetration closed and de-activated leakage such that the automatic valve, closed sum of the leakage for all manual valve, or blind Type B and C tests is not flange.

within limits.

AND

D.2 ------------NOTES-----------

1. Isolation devices in high radiation areas may be verified by use of administrative means.
2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per 31 days for penetration flow path is isolation devices isolated. outside containment

AND

Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment

AND (continued)

Farley Units 1 and 2 3.6.3-5 Amendment No. 225 (Unit 1)

Amendment No. 222 (Unit 2)

Southern Nuclear Operating Company Vogtle Electric Generating Plant - Units 1 and 2

Adoption of TSTF-269-A, Revision 2, "Allow Administrative Means of Position Verification for Locked or Sealed Valves

Attachment 1b

Proposed Technical Specification Changes (Marked-up Pages)

Containment Isolation Valves 3.6.3

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. (continued) A.2 -----------NOTES-------------

1. Isolation devices in high radiation areas may be verified by use of administrative means.
2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per 31 days for penetration flow path is isolation devices isolated. outside containment

AND

Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment

(continued)

Vogtle Units 1 and 2 3.6.3-2 Amendment No. 188 (Unit 1)

Amendment No. 171 (Unit 2)

Containment Isolation Valves 3.6.3

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

C. ----------NOTES----------- C.1 Isolate the affected 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

1. Not applicable when penetration flow path by the second use of at least one closed OR containment purge and de-activated valve is intentionally automatic valve, closed In accordance with made inoperable. manual valve, or blind the Risk Informed
2. The following Section flange. Completion Time 5.5.22 constraints are Program applicable: parts b, AND c.2, c.3, d, e, f, g, and
h. C.2 -------------NOTES-----------

1. Isolation devices in high radiation areas One or more penetration may be verified by use flow paths with one or of administrative more containment purge means.

valves not within purge 2. Isolation devices that valve leakage limits. are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per 31 days for penetration flow path is isolation devices isolated. outside containment

AND

Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment

(continued)

Vogtle Units 1 and 2 3.6.3-4 Amendment No. 188 (Unit 1)

Amendment No. 171 (Unit 2)

Southern Nuclear Operating Company Farley Nuclear Plant - Units 1 and 2

Adoption of TSTF-269-A, Revision 2, "Allow Administrative Means of Position Verification for Locked or Sealed Valves

Attachment 2a

Revised Technical Specification Changes

Containment Isolation Valves 3.6.3

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. ------------NOTE------------- A.1 Isolate the affected 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Only applicable to penetration flow path by penetration flow paths use of at least one closed OR with two containment and de-activated isolation valves. automatic valve, closed In accordance with

manual valve, blind the Risk Informed flange, or check valve Completion Time One or more penetration with flow through the Program flow paths with one valve secured.

containment isolation valve inoperable except AND for purge valve penetration leakage not A.2 -------------NOTES-----------

within limit. 1. Isolation devices in high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per 31 days for penetration flow path is isolation devices isolated. outside containment

AND

Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment

Farley Units 1 and 2 3.6.3-2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Containment Isolation Valves 3.6.3

ACTIONS

CONDITION REQUIRED ACTION COMPLETION TIME

C. ------------NOTE------------ C.1 Isolate the affected 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Only applicable to penetration flow path by penetration flow paths use of at least one closed OR with only one and de-activated containment isolation automatic valve, closed In accordance with valve and a closed manual valve, or blind the Risk Informed system. flange. Completion Time

Program AND One or more penetration flow paths with one C.2 -------------NOTES-----------

containment isolation 1. Isolation devices in valve inoperable. high radiation areas may be verified by use of administrative means.

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per 31 days penetration flow path is isolated.

Farley Units 1 and 2 3.6.3-4 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Containment Isolation Valves 3.6.3

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

D. One or more penetration D.1 Isolate the affected 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> flow paths containing penetration flow path by containment purge use of at least one valves, with penetration closed and de-activated leakage such that the automatic valve, closed sum of the leakage for all manual valve, or blind Type B and C tests is not flange.

within limits.

AND

D.2 ------------NOTES-----------

1. Isolation devices in high radiation areas may be verified by use of administrative means.
2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per 31 days for penetration flow path is isolation devices isolated. outside containment

AND

Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment

AND (continued)

Farley Units 1 and 2 3.6.3-5 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Containment Isolation Valves 3.6.3

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

D. (continued) D.3 Perform SR 3.6.3.5 for Once per 92 days the penetrations containing resilient seal purge valves closed to comply with Required Action D.1.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A, B, AND C, or D not met.

E.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />

F. One or more penetration F.1 Reduce leakage to within Prior to entering flow paths containing limit. MODE 4 from MODE containment purge 5 if the exiting leakage valves, with penetration is determined during leakage not within the quarterly testing per penetration limits. SR 3.6.3.5.

OR

Prior to entering MODE 4 if excess leakage is determined during MODE 5 per SR 3.6.3.5

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.6.3.1 Verify each 48 inch purge valve is seal ed closed, In accordance with except for one purge valve in a penetration flow pa th the Surveillance while in Condition D of this LCO. Frequency Control Program

Farley Units 1 and 2 3.6.3-6 Amendment No. ( Unit 1)

Amendment No. (Unit 2)

Containment Isolation Valves 3.6.3

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.6.3.2 -----------------------------NOTE------------------ --------------

Valves and blind flanges in high radiation areas may be verified by use of administrative controls.

Verify each containment isolation manual valve and In accordance with blind flange that is located outside containment and the Surveillance not locked, sealed, or otherwise secured and required Frequency Control to be closed during accident conditions is closed, Program except for containment isolation valves that are open under administrative controls.

SR 3.6.3.3 -----------------------------NOTES-------------------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.
2. The blind flange on the fuel transfer canal flange is only required to be verified closed after each draining of the canal.

Verify each containment isolation manual valve and Prior to entering blind flange that is located inside containment and MODE 4 from not locked, sealed, or otherwise secured and MODE 5 if not required to be closed during accident conditions is performed within closed, except for containment isolation valves that the previous are open under administrative controls. 92 days

SR 3.6.3.4 Verify the isolation time of each automatic power In accordance with operated containment isolation valve in the the INSERVICE INSERVICE TESTING PROGRAM is within limits. TESTING PROGRAM

Farley Units 1 and 2 3.6.3-7 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Containment Isolation Valves 3.6.3

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.6.3.5 Perform leakage rate testing for containment In accordance with penetrations containing containment purge valves the Surveillance with resilient seals. Frequency Control Program

AND

Within 92 days after opening the valve

SR 3.6.3.6 Verify each automatic containment isolation valve In accordance with that is not locked, sealed or otherwise secured in the Surveillance position, actuates to the isolation position on an Frequency Control actual or simulated actuation signal. Program

Farley Units 1 and 2 3.6.3-8 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Southern Nuclear Operating Company Vogtle Electric Generating Plant - Units 1 and 2

Adoption of TSTF-269-A, Revision 2, "Allow Administrative Means of Position Verification for Locked or Sealed Valves

Attachment 2b

Revised Technical Specification Changes

Containment Isolation Valves 3.6.3

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. (continued) A.2 -----------NOTES-------------

1. Isolation devices in high radiation areas may be verified by use of administrative means.
2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per 31 days for penetration flow path is isolation devices isolated. outside containment

AND

Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment

(continued)

Vogtle Units 1 and 2 3.6.3-2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Containment Isolation Valves 3.6.3

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

B. ----------NOTES----------- B.1 Isolate the affected 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

1. Not applicable when penetration flow path by the second use of at least one closed OR containment isolation and de-activated valve is intentionally automatic valve, closed In accordance with made inoperable. manual valve, or blind the Risk Informed
2. The following Section flange. Completion Time 5.5.22 constraints are Program applicable: parts b, c.2, c.3, d, e, f, g, and h.

One or more penetration flow paths with two containment isolation valves inoperable except for purge valve leakage not within limit.

(continued)

Vogtle Units 1 and 2 3.6.3-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Containment Isolation Valves 3.6.3

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

C. ----------NOTES----------- C.1 Isolate the affected 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

1. Not applicable when penetration flow path by the second use of at least one closed OR containment purge and de-activated valve is intentionally automatic valve, closed In accordance with made inoperable. manual valve, or blind the Risk Informed
2. The following Section flange. Completion Time 5.5.22 constraints are Program applicable: parts b, AND c.2, c.3, d, e, f, g, and
h. C.2 -------------NOTES-----------

1. Isolation devices in high radiation areas One or more penetration may be verified by use flow paths with one or of administrative more containment purge means.

valves not within purge 2. Isolation devices that valve leakage limits. are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected Once per 31 days for penetration flow path is isolation devices isolated. outside containment

AND

Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment

(continued)

Vogtle Units 1 and 2 3.6.3-4 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Containment Isolation Valves 3.6.3

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND

D.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.6.3.1 Verify each 24 inch purge valve is sealed closed, In accordance with except for one purge valve in a penetration flow path the Surveillance while in Condition D of this LCO. Frequency Control Program

SR 3.6.3.2 Verify each 14 inch purge valve is closed, except In accordance with when the associated penetration(s) is (are) the Surveillance permitted to be open for purge or venting Frequency Control operations and purge system surveillance and Program maintenance testing under administrative control.

SR 3.6.3.3 -----------------------------NOTE--------------------------------

Valves and blind flanges in high radiation areas may be verified by use of administrative controls.

Verify each containment isolation manual valve In accordance with and blind flange that is located outside the Surveillance containment and not locked, sealed, or otherwise Frequency Control secured and required to be closed during accident Program conditions is closed, except for containment isolation valves that are open under administrative controls.

(continued)

Vogtle Units 1 and 2 3.6.3-5 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Containment Isolation Valves 3.6.3

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

SR 3.6.3.4 -----------------------------NOTES-------------------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.
2. The fuel transfer tube blind flange is only required to be verified closed once after refueling prior to entering MODE 4 from MODE5.

Verify each containment isolation manual valve Prior to entering and blind flange that is located inside containment MODE 4 from and not locked, sealed, or otherwise secured and MODE 5 if not required to be closed during accident conditions is performed within the closed, except for containment isolation valves previous 92 days that are open under administrative controls.

SR 3.6.3.5 Verify the isolation time of each automatic power In accordance operated containment isolation valve is within with the INSERVICE limits. TESTING PROGRAM

SR 3.6.3.6 Perform leakage rate testing for containment In accordance with purge valves with resilient seals. the Surveillance Frequency Control Program

SR 3.6.3.7 Verify each automatic containment isolation valve In accordance with that is not locked, sealed, or otherwise secured in the Surveillance position, actuates to the isolation position on an Frequency Control actual or simulated actuation signal. Program

Vogtle Units 1 and 2 3.6.3-6 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Southern Nuclear Operating Company Farley Nuclear Plant - Units 1 and 2

Adoption of TSTF-269-A, Revision 2, "Allow Administrative Means of Position Verification for Locked or Sealed Valves

Attachment 3a

Proposed Technical Specification Bases Changes (Marked-up Pages )

For Information Only

Containment Isolation Valves B 3.6.3

BASES

ACTIONS A.1 and A.2 (continued)

Required Action A.2 is modified by atwo Notes. Note 1 that applies to isolation devices located in high radiation areas and allows th ese devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Note 2 applies to isolation devices that are locked, sealed, or otherwise secured in positi on and allows these devices to be verified closed by use of administra tive means. Allowing verification by administrative means is consid ered acceptable, since the function of locking, sealing, or securing components is to ensure that these devices are not inadvertentl y repositioned. Therefore, the probability of misalignment of these devices, once they have been verified to be in the proper posit ion, is small.

B.1

With two containment isolation valves in one or more penetrati on flow paths inoperable, the affected penetration flow path must be is olated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a si ngle active failure. Isolation barriers that meet this criterion ar e a closed and de-activated automatic valve, a closed manual valve, and a blind flange. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is consistent with the ACTIO NS of LCO 3.6.1. Alternatively, a Completion Time can be determined using the Risk Informed Completion Time Program (Ref. 6). In the eve nt the affected penetration is isolated in accordance with Required Action B.1, the affected penetration must be verified to be iso lated on a periodic basis per Required Action A.2, which remains in effect. This periodic verification is necessary to assure leak tightness of containment and that penetrations requiring isolation following an accident are isolated. The Completion Time of once per 31 days for verifying each affected penetration flow path is isolated is ap propriate considering the fact that the valves are operated under adminis trative control and the probability of their misalignment is low.

Condition B is modified by two Notes. The first Note states t he Condition is only applicable to penetrations with two containme nt isolation valves. The second Note states RICT entry is not per mitted for this loss of function Condition when the second containment isolation valve is intentionally made inoperable. The RICT pro gram cannot be used for the voluntary removal of systems or componen ts which would result in a loss of safety function. RICT entry is only permitted for situations where a second containment isolation valve is found inoperable or when both isolation valves are simultaneous ly (continued)

Farley Units 1 and 2 B 3.6.3-7 Revision 96 Containment Isolation Valves B 3.6.3

BASES

ACTIONS C.1 and C.2 (continued)

Required Action C.2 is modified by atwo Notes. Note 1 that applies to valves and blind flanges located in high radiation areas and al lows these devices to be verified closed by use of administrative me ans.

Allowing verification by administrative means is considered acc eptable, since access to these areas is typically restricted. Note 2 applies to isolation devices that are locked, sealed, or otherwise secured in position and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since the function of locking, sealing, or securing components is to ensure that these devices are not inadvertently repositioned. Therefore, the probability of misalignment of these valves, once they have been verified to be in the prop er position, is small.

D.1, D.2, and D.3

In the event one or more penetration flow paths containing containment purge valves, have penetration leakage such that th e sum of the leakage for all Type B and C tests is not within limits, purge valve penetration leakage must be restored such that the overal l Type B and C testing limit is not exceeded, or the affected penetrat ion flow path must be isolated. The method of isolation must be by the use of at least one isolation barrier that cannot be adversely affecte d by a single active failure. Isolation barriers that meet this crite rion are a closed and de-activated automatic valve, closed manual valve, o r blind flange. A purge valve with resilient seals utilized to satisfy Required Action D.1 must have been demonstrated to support the penetrati on meeting the leakage requirements of SR 3.6.3.5. The specified Completion Time is reasonable, considering that one containment purge valve remains closed so that a gross breach of containmen t does not exist.

In accordance with Required Action D.2, this penetration flow path must be verified to be isolated on a periodic basis. The perio dic verification is necessary to ensure that containment penetratio ns required to be isolated following an accident, which are no lon ger capable of being automatically isolated, will be in the isolati on position should an event occur. This Required Action does not require a ny testing or valve manipulation. R ather, it involves verificatio n, through a system walkdown, that those isolation devices outside containme nt capable of being mispositioned are in the correct position. Fo r the isolation devices inside containment, the time period specified as "prior to entering MODE 4 from MODE 5 if not performed within the prev ious

(continued)

Farley Units 1 and 2 B 3.6.3-9 Revision 96 Containment Isolation Valves B 3.6.3

BASES

ACTIONS D.1, D.2, and D.3 (continued)

For the containment penetration containing a containment purge valve with resilient seal that is isolated in accordance with Require d Action D.1, SR 3.6.3.5 must be performed at least once every 92 days. This assures that degradation of the resilient seal is detected and confirms that the leakage rate of the containment purge val ve penetration does not increase during the time the penetration i s isolated. Since more reliance is placed on a single valve whil e in this Condition, it is prudent to perform the SR more often. T herefore, a Frequency of once per 92 days was chosen and has been shown t o be acceptable based on operating experience.

Required Action D.2 is modified by two Notes. Note 1 applies t o isolation devices located in high radiation areas and allows th ese devices to be verified closed by use of administrative means.

Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Note 2 applies to isolation devices that are locked, sealed, or otherw ise secured in position and allows these devices to be verified clo sed by use of administrative means. Allowing verification by administ rative means is considered acceptable, since the function of locking, sealing, or securing components is to ensure that these devices are not inadvertently repositioned.

E.1 and E.2

If the Required Actions and associated Completion Times of Con dition A, B, C, or D are not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plan t must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 with in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based o n operating experience, to reach the required plant conditions fr om full power conditions in an orderly manner and without challenging p lant systems.

F.1

In the event one or more penetration flow paths containing containment purge valves have penetration leakage which exceeds the individual purge valve penetration leakage limit, purge val ve penetration leakage must be reduced to within the limit prior t o the next time that the unit transitions from MODE 5 to MODE 4. Pro vided that the penetration flow path leakage does not cause the total leakage

(continued)

Farley Units 1 and 2 B 3.6.3-10 Revision 52 Southern Nuclear Operating Company Vogtle Electric Generating Plant - Units 1 and 2

Adoption of TSTF-269-A, Revision 2, "Allow Administrative Means of Position Verification for Locked or Sealed Valves

Attachment 3b

Proposed Technical Specification Bases Changes (Marked-up Pages )

For Information Only

Containment Isolation Valves B 3.6.3

BASES

ACTIONS A.1 and A.2 (continued)

Required Action A.2 is modified by atwo Notes. Note 1 that applies to isolation devices located in high radiation areas and allows th ese valves to be verified closed by use of administrative means. A llowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Note 2 applies to isolation devices that are locked, sealed, or otherwise secured in position and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since the function of locking, sealin g, or securing components is to ensure that these devices are not inadvertently repositioned. Therefore, the probability of misalignment, once they have been verified to be in the proper position, is s mall.

B.1

With two containment isolation valves in one or more penetratio n flow paths inoperable, the affected penetration flow path must be is olated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The method of isolation must include the use of at least one isolation barrier that cannot be adversely affected by a si ngle active failure. Isolation barriers that meet this criterion ar e a closed and de-activated automatic valve, a closed manual valve, and a blind flange. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is consistent with the ACTI ONS of LCO 3.6.1. Alternatively, a Completion Time can be determin ed in accordance with the Risk Informed Completion Time Program. In the event the affected penetration is isolated in accordance with Required Action B.1, the affected penetration must be verified to be iso lated on a periodic basis per Required Action A.2, which remains in effe ct.

This periodic verification is necessary to assure that penetrat ions requiring isolation following an accident are isolated. The Co mpletion Time of once per 31 days for verifying each affected penetration flow path is isolated is appropriate considering the fact that the valves are operated under administrative control and the probability of th eir misalignment is low.

CONDITION B is modified by two Notes. The first Note states it is not applicable when the second containment isolation valve is intentionally made inoperable. This Required Action is not intended for voluntary removal of redundant systems or components from service. The Required Action for two containment isolation valv es inoperable is only intended when the second containment isolati on valve is found inoperable and the first valve in the line is al ready

(continued)

Vogtle Units 1 and 2 B 3.6.3-7 REVISION 48 Containment Isolation Valves B 3.6.3

BASES

ACTIONS B.1 (continued)

inoperable, or when both valves are found inoperable at the same time. The second Note indicates the parts of Section 5.5.22, Risk Informed Completion Time Program, which are applicable to this LCO Condition. The Risk Informed Completion Time for this LCO Condition can be no longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (Ref. 4).

C.1, C.2, and C.3

In the event one or more containment purge valves in one or more penetration flow paths are not within the purge valve leakage limits, purge valve leakage must be restored to within limits, or the affected penetration flow path must be isolated. The method of isolation must be by the use of at least one isolation barrier that cannot be adversely affected by a single active failure. Isola tion barriers that meet this criterion are a closed and de-activated automatic valve, closed manual valve, or blind flange. The spe cified Completion Time is reasonable, considering that one containment purge valve remains closed so that a gross breach of containmen t does not exist.

In accordance with Required Action C.2, this penetration flow path must be verified to be isolated on a periodic basis. The perio dic verification is necessary to ensure that containment penetratio ns required to be isolated following an accident, which are no lon ger capable of being automatically isolated, will be in the isolation position should an event occur. This Required Action does not require any testing or valve manipulation. Rather, it involves verification, through a system walkdown, that those isolation devices outside contain ment capable of being mispositioned are in the correct position. Fo r the isolation devices inside containment, the time period specified as "prior to entering MODE 4 from MODE 5 if not performed within t he previous 92 days" is based on engineering judgment and is considered reasonable in view of the inaccessibility of the iso lation devices and other administrative controls that will ensure that isolation device misalignment is an unlikely possibility.

Required Action C.2 is modified by two Notes. Note 1 applies to isolation devices located in high radiation areas and allows th ese devices to be verified closed by use of administrative means.

Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted. Note 2

(continued)

Vogtle Units 1 and 2 B 3.6.3-8 REVISION 48 Containment Isolation Valves B 3.6.3

BASES

ACTIONS C.1, C.2, and C.3 (continued)

applies to isolation devices that are locked, sealed, or otherw ise secured in position and allows these devices to be verified clo sed by use of administrative means. Allowing verification by administ rative means is considered acceptable, since the function of locking, sealing, or securing components is to ensure that these devices are not inadvertently repositioned.

Condition C is modified by two Notes. The first Note states it is not applicable when the second containment purge valve is intention ally made inoperable. The Required Action for two containment purge valves inoperable is not intended for voluntary removal of redu ndant systems or components from service. The Required Action is onl y intended if the second containment purge valve is found inopera ble and the first purge valve in the line is already inoperable or if both containment purge valves were found inoperable at the same time.

The second Note indicates the parts of Section 5.5.22, Risk In formed Completion Time Program, which are applicable to this LCO Condition. The Risk Informed Completion Time for this LCO Condition can be no longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (Ref. 4).

D.1, and D.2

If the Required Actions and associated Completion Times are not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowe d Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.6.3.1 REQUIREMENTS (HV-2626A, HV-2627A, HV-2628A, HV-2629A)

Each 24 inch containment purge valve is required to be verified sealed closed. This Surveillance is designed to ensure that a gross breach of containment is not caused by an inadvertent or spurio us opening of a containment purge valve. Detailed analysis of the purge valves failed to conclusively demonstrate their ability to close during

(continued)

Vogtle Units 1 and 2 B 3.6.3-9 REVISION 48

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