NL-22-0757, Units 1 & 2, Supplement to License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b
| ML22273A096 | |
| Person / Time | |
|---|---|
| Site: | Hatch |
| Issue date: | 09/30/2022 |
| From: | Gayheart C Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-22-0757, TSTF-505, Rev 2 | |
| Download: ML22273A096 (18) | |
Text
3535 Colonnade Parkway Birmingham, AL 35243 205 992 5316 tel 205 992 7601 fax cagayhea@southernco.com Cheryl A. Gayheart Regulatory Affairs Director September 30, 2022 Docket Nos.: 50-321 NL-22-0757 50-366 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Edwin I. Hatch Nuclear Plant - Units 1 and 2 Supplement to License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b" Ladies and Gentlemen:
On October 26, 2021 [ADAMS Accession Number ML21300A153], pursuant to the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations, Southern Nuclear Operating Company (SNC) requested amendments to Edwin I. Hatch Nuclear Plant (HNP), Units 1 and 2 renewed facility operating licenses (RFOLs) DPR-57 and NPF-5, respectively. The proposed amendment requested U.S. Nuclear Regulatory Commission (NRC) approval to modify Technical Specifications (TS) requirements to permit the use of Risk Informed Completion Times in accordance with TSTF-505, Revision 2, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b" [ML18183A493]. The LAR impacted several TS sections, including TS 3.6.1.3 On December 6, 2021, subsequent to the submittal of the HNP TSTF-505 license amendment request (LAR), SNC submitted a LAR to adopt certain aspects of TSTF-207 [ML21340A255].
On September 2, 2022, the NRC issued Amendments 317 and 262 to the HNP Units 1 and 2 RFOLs, respectively, approving SNCs Hatch TSTF-207 LAR. Amendments 317 and 262 include changes to some of the same pages in TS 3.6.1.3 as SNCs HNP TSTF-505 LAR.
The Enclosure to this letter describes the TS markup changes and assesses their impact on SNCs Hatch TSTF-505 LAR.
The Attachment to this letter updates the TS markups, provided initially in the license amendment request dated October 26, 2021, to include the effects of Amendments 317 and 262. These markups supersede only the TS 3.6.1.3 markups provided in the initial license amendment request dated October 26, 2021.
SNC requests the same approval and implementation schedule as requested in its original application [ML21300A153]. The conclusions of the No Significant Hazards Consideration Determination and Environmental Consideration contained in the original application have been reviewed and are unaffected by this supplement.
U. S. Nuclear Regulatory Commission NL-22-0757 Page 2 of 2 In accordance with 10 CFR 50.91, SNC is notifying the State of Georgia of this supplement to license amendment request by transmitting a copy of this letter, with attachment, to the designated State Official.
This letter contains no regulatory commitments. If you have any questions, please contact Amy Chamberlain at 205.992.6361.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 30th day of September 2022.
Respectfully submitted, C. A. Gayheart Director, Regulatory Affairs Southern Nuclear Operating Company CAG/agq
Enclosure:
Assessment of Amendments 317 and 262 Impact on HNP TSTF-505 License Amendment Request
Attachment:
Revised TSTF-505 Markups Reflecting Amendments 317 and 262 cc:
Regional Administrator, Region ll NRR Project Manager - Hatch Senior Resident Inspector - Hatch Director, Environmental Protection Division - State of Georgia RType: CHA02.004
Edwin I. Hatch Nuclear Plant - Units 1 and 2 Supplement to License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b" NL-22-0757 Enclosure Assessment of Amendments 317 and 262 Impact on HNP TSTF-505 License Amendment Request Enclosure consists of 6 pages, excluding this cover page
NL-22-0757 Assessment of Amendments 317 and 262 Impact on HNP TSTF-505 License Amendment Request E - 1
1.0 INTRODUCTION
On October 26, 2021 [ADAMS Accession Number ML21300A153], Southern Nuclear Operating Company (SNC) requested amendments to Edwin I. Hatch Nuclear Plant (HNP), Units 1 and 2 renewed facility operating licenses (RFOLs) DPR-57 and NPF-5, respectively. The proposed amendment requested U.S. Nuclear Regulatory Commission (NRC) approval to modify Technical Specifications (TS) requirements to permit the use of Risk Informed Completion Times in accordance with TSTF-505, Revision 2, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b" [ML18183A493]. The LAR impacted several TS sections, including TS 3.6.1.3, Primary Containment Isolation Valves.
On December 6, 2021, subsequent to the submittal of the HNP TSTF-505 license amendment request (LAR), SNC submitted a LAR to adopt certain aspects of TSTF-207 [ML21340A255].
On September 2, 2022, the NRC issued Amendments 317 and 262 to the HNP Units 1 and 2 RFOLs, respectively, approving SNCs HNP TSTF-207 LAR. Amendments 317 and 262 include changes to some of the same pages in TS 3.6.1.3 as SNCs TSTF-505 LAR.
2.0 DESCRIPTION
OF CHANGE AND ASSESSMENT OF IMPACT The issuance of HNP RFOL Amendments 317 and 262 included issuance of revised TS pages 3.6-7 through 3.6-12 (impacts TS 3.6.1.3 Conditions A through D and Required Action D.1 Completion Time). The Hatch TSTF-505 LAR included changes to TS pages 3.6-7 through 3.6-9 (impacts Condition A Required Actions and Completion Times and Required Action Completion Time C.2), thus there is overlap in the affected pages. Table 1 provides descriptions of the changes and assess the impact Amendments 317 and 262 have on SNCs HNP TSTF-505 LAR.
NL-22-0757 Assessment of Amendments 317 and 262 Impact on HNP TSTF-505 License Amendment Request E - 2 Table 1: Descriptions of Changes and Assessment of Impact (Sheet 1 of 5)
TS 3.6.1.3 Condition (1)(2)
Amendment 317 and 262 Changes (3)
HNP TSTF-505 LAR Proposed Changes (3)
Assessment of Impact to HNP TSTF-505 LAR A
Revised Condition A Note as follows:
Only applicable to penetration flow paths with two or more PCIVs.
Adds following Note to Required Action A.1:
Not applicable to main steam line.
The addition of or more to the Note of TS 3.6.1.3, Condition A, clarifies that the Condition applies to penetration flow paths with more than two PCIVs. This was an administrative change aligning the HNP TS with TSTF-207-A, Revision 5 as implemented in the Boiling Water Reactor (BWR) Owners Group Standard Technical Specifications (STS), NUREG-1433. Due to the administrative nature of this change, there is no impact to the proposed note that the HNP TSTF-505 LAR adds to Required Action A.1 (which is also an administrative change itself as described in Attachment 1, Section 2.3 of the HNP TSTF-505 LAR [ML21300A153]).
Revised Condition A as follows:
One or more penetration flow paths with one PCIV inoperable except due to leakage not within limit for reasons other than Condition D.
Revises Required Action A.1 Completion Time as follows:
4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> except for main steam line OR In accordance with the Risk Informed Completion Time Program AND 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for main steam line Rewording the exception to refer to reasons other than TS 3.6.1.3 Condition D is an administrative/equivalent change since TS 3.6.1.3 Condition D and TS 3.6.1.1 have required actions for leakage not within limits. Due to the administrative nature of this change, other than changes to background text in the TS markups, there is no impact to the proposed change that the HNP TSTF-505 LAR makes to Required Action A.1 (which is also an administrative change itself as described in, Section 2.3 of the HNP TSTF-505 LAR).
NL-22-0757 Assessment of Amendments 317 and 262 Impact on HNP TSTF-505 License Amendment Request E - 3 Table 1: Descriptions of Changes and Assessment of Impact (Sheet 2 of 5)
TS 3.6.1.3 Condition (1)(2)
Amendment 317 and 262 Changes (3)
HNP TSTF-505 LAR Proposed Changes (3)
Assessment of Impact to HNP TSTF-505 LAR A (contd)
Adds new Required Action A.2 as follows:
NOTE---------------
Only applicable to main steam line.
Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.
The assessment of Required Action A.1 in previous row also applies to the addition of a new Required Action A.2.
Adds new Required Action A.2 Completion Time as follows:
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> OR In accordance with the Risk Informed Completion Time Program The assessment of Required Action A.1 in previous row also applies to the addition of a Completion Time for new Required Action A.2.
NL-22-0757 Assessment of Amendments 317 and 262 Impact on HNP TSTF-505 License Amendment Request E - 4 Table 1: Descriptions of Changes and Assessment of Impact (Sheet 3 of 5)
TS 3.6.1.3 Condition (1)(2)
Amendment 317 and 262 Changes (3)
HNP TSTF-505 LAR Proposed Changes (3)
Assessment of Impact to HNP TSTF-505 LAR A (contd)
Renumbers Required Action A.2 to A.3 as follows:
A.23 This is an administrative change due to making Required Action A.1 two separate Required Actions, A.1 and A.2. Amendments 317 and 262 have no impact on this change.
Revises first part of new Required Action A.3 Completion Time as follows:
Once per 31 days following isolation for isolation devices outside primary containment The HNP TSTF-505 LAR adds following isolation in accordance with TSTF-505-A, Revision 2 to account for the time change caused by RICT implementation. The Amendment 317 and 262 change to Condition A have no impact on this change.
B Revised Condition B Note as follows:
Only applicable to penetration flow paths with two or more PCIVs.
The addition of or more to the Note of TS 3.6.1.3, Condition B, clarifies that the Condition applies to penetration flow paths with more than two PCIVs. This was an administrative change aligning the HNP TS with TSTF-207-A, Revision 5 as implemented in the BWR Owners Group STS, NUREG-1433. Due to the administrative nature of this change, there would be no change in application of the HNP TSTF-505 LAR proposed changes, and there is no impact to the HNP TSTF-505 LAR other than changes to background information in the TS markups.
NL-22-0757 Assessment of Amendments 317 and 262 Impact on HNP TSTF-505 License Amendment Request E - 5 Table 1: Descriptions of Changes and Assessment of Impact (Sheet 4 of 5)
TS 3.6.1.3 Condition (1)(2)
Amendment 317 and 262 Changes (3)
HNP TSTF-505 LAR Proposed Changes (3)
Assessment of Impact to HNP TSTF-505 LAR B (contd)
Changed Condition B as follows:
One or more penetration flow paths with two or more PCIVs inoperable except due to leakage not within limit for reasons other than Condition D.
See discussion of Condition A change above. Additionally, Condition B is not involved in the HNP TSTF-505 LAR, so there is no impact to the HNP TSTF-505 LAR other than changes to background text in the TS markups.
C Changed Condition C as follows:
One or more penetration flow paths with one PCIV inoperable except due to leakage not within limit for reasons other than Condition D.
Revises Required Action C.2 Completion Time as follows:
Once per 31 days following isolation The discussion of the Condition A change above also applies to Condition C.
The HNP TSTF-505 LAR adds following isolation in accordance with TSTF-505-A, Revision 2 to account for the time change caused by RICT implementation. The Amendment 317 and 262 changes to Condition C have no impact on this change.
D Changed Condition D as follows:
One or more penetration flow paths with leakage secondary containment bypass leakage rate, MSIV leakage rate, or EFCV leakage rate not within limit.
This change specifies the individual types of penetration flow paths to which the Condition applies. The HNP TSTF-505 LAR does not propose applying Risk Informed Completion Time to the Condition D Required Action. Therefore, there is no impact to the HNP TSTF-505 LAR aside from changes to background text in the TS markups.
NL-22-0757 Assessment of Amendments 317 and 262 Impact on HNP TSTF-505 License Amendment Request E - 6 Table 1: Descriptions of Changes and Assessment of Impact (Sheet 5 of 5)
TS 3.6.1.3 Condition (1)(2)
Amendment 317 and 262 Changes (3)
HNP TSTF-505 LAR Proposed Changes (3)
Assessment of Impact to HNP TSTF-505 LAR D (contd)
Changed Required Action D.1 Completion Time as follows:
4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for secondary containment bypass leakage AND 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for MSIV leakage AND 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for EFCV leakage This change specifies Completion Times for the Required Actions associated with the individual types of penetration flow paths identified.
The HNP TSTF-505 LAR does not propose applying Risk Informed Completion Time to the Condition D Required Action. Therefore, there is no impact to the HNP TSTF-505 LAR aside from changes to background text in the TS markups.
Notes:
- 1. Due to formatting of tracked changes, some text rolls to pages 3.6-8, 3.6-9, and 3.6-10. Therefore, the changes are compared on a TS Condition basis.
- 2. Conditions listed apply to Unit 1 TS and Unit 2 TS pages.
- 3. Underline format (e.g., underline) text indicates added text, and strikethrough format (e.g., deleted) text indicates deleted text.
Edwin I. Hatch Nuclear Plant - Units 1 and 2 Supplement to License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b" NL-22-0757 Attachment Revised TSTF-505 Markups Reflecting Amendments 317 and 262 Note:
Blue underline indicates new text proposed in submittal dated October 26, 2021 Red strikethrough indicates deleted text proposed in submittal dated October 26, 2021 Green underline indicates new text added by Amendments 317 and 262 Grey strikethrough indicates text deleted by Amendments 317 and 262 Attachment consists of 8 pages, excluding this cover page
PCIVs 3.6.1.3 HATCH UNIT 1 3.6-7 Amendment No. 317 3.6 CONTAINMENT SYSTEMS 3.6.1.3 Primary Containment Isolation Valves (PCIVs)
LCO 3.6.1.3 Each PCIV, except reactor building-to-suppression chamber vacuum breakers, shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, and 3.
ACTIONS
NOTES-----------------------------------------------------------
- 1.
Penetration flow paths except for 18 inch purge valve penetration flow paths may be unisolated intermittently under administrative controls.
- 2.
Separate Condition entry is allowed for each penetration flow path.
- 3.
Enter applicable Conditions and Required Actions for systems made inoperable by PCIVs.
- 4.
Enter applicable Conditions and Required Actions of LCO 3.6.1.1, "Primary Containment," when PCIV leakage results in exceeding overall containment leakage rate acceptance criteria.
CONDITION REQUIRED ACTION COMPLETION TIME A.
NOTE---------------
Only applicable to penetration flow paths with two or more PCIVs.
One or more penetration flow paths with one PCIV inoperable except due to leakage not within limit for reasons other than Condition D.
A.1
NOTE----------
Not applicable to main steam line.
Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.
AND 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> except for main steam line ANDOR 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for main steam line In accordance with the Risk Informed Completion Time Program (continued)
PCIVs 3.6.1.3 HATCH UNIT 1 3.6-8 Amendment No. 317 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
(continued)
A.2
NOTE-----------
Only applicable to main steam line.
Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.
AND A.32
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 administrative means.
Verify the affected penetration flow path is isolated.
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> OR In accordance with the Risk Informed Completion Time Program Once per 31 days following isolation for isolation devices outside primary containment AND (continued)
PCIVs 3.6.1.3 HATCH UNIT 1 3.6-9 Amendment No. 317 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
(continued)
Prior to entering MODE 2 or 3 from MODE 4 if primary containment was de-inerted while in MODE 4, if not performed within the previous 92 days, for isolation devices inside primary containment B.
NOTE---------------
Only applicable to penetration flow paths with two or more PCIVs.
One or more penetration flow paths with two or more PCIVs inoperable except due to leakage not within limit for reasons other than Condition D.
B.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> C.
NOTE-------------
Only applicable to penetration flow paths with only one PCIV.
One or more penetration flow paths with one PCIV inoperable except due to leakage not within limits for reasons other than Condition D.
C.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.
AND 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> except for excess flow check valve (EFCV) line and penetrations with a closed system AND 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for EFCV line and penetrations with a closed system (continued)
PCIVs 3.6.1.3 HATCH UNIT 1 3.6-10 Amendment No. 317 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C.
(continued)
C.2
NOTES----------
- 1. Valves and blind flanges 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 administrative means.
Verify the affected penetration flow path is isolated.
Once per 31 days following isolation D.
One or more penetration flow paths with leakage secondary containment bypass leakage rate, MSIV leakage rate, or EFCV leakage rate not within limit.
D.1 Restore leakage to within limit.
4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for secondary containment bypass leakage AND 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for MSIV leakage AND 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for EFCV leakage E.
Required Action and associated Completion Time of Condition A, B, C, or D not met.
E.1 Be in MODE 3.
AND E.2 Be in MODE 4.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours
PCIVs 3.6.1.3 HATCH UNIT 2 3.6-7 Amendment No. 262 3.6 CONTAINMENT SYSTEMS 3.6.1.3 Primary Containment Isolation Valves (PCIVs)
LCO 3.6.1.3 Each PCIV, except reactor building-to-suppression chamber vacuum breakers, shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, and 3.
ACTIONS
NOTES------------------------------------------------------------
- 1.
Penetration flow paths except for 18 inch purge valve penetration flow paths may be unisolated intermittently under administrative controls.
- 2.
Separate Condition entry is allowed for each penetration flow path.
- 3.
Enter applicable Conditions and Required Actions for systems made inoperable by PCIVs.
- 4.
Enter applicable Conditions and Required Actions of LCO 3.6.1.1, "Primary Containment," when PCIV leakage results in exceeding overall containment leakage rate acceptance criteria.
CONDITION REQUIRED ACTION COMPLETION TIME A.
NOTE---------------
Only applicable to penetration flow paths with two or more PCIVs.
One or more penetration flow paths with one PCIV inoperable except due to leakage not within limit for reasons other than Condition D.
A.1
NOTE-----------
Not applicable to main steam line.
Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.
AND 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> except for main steam line ANDOR 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for main steam line In accordance with the Risk Informed Completion Time Program (continued)
PCIVs 3.6.1.3 HATCH UNIT 2 3.6-8 Amendment No. 262 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
(continued)
A.2
NOTE-----------
Only applicable to main steam line.
Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.
AND A.32 ------------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 administrative means.
Verify the affected penetration flow path is isolated.
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> OR In accordance with the Risk Informed Completion Time Program Once per 31 days following isolation for isolation devices outside primary containment AND (continued)
PCIVs 3.6.1.3 HATCH UNIT 2 3.6-9 Amendment No. 262 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
(continued)
Prior to entering MODE 2 or 3 from MODE 4 if primary containment was de-inerted while in MODE 4, if not performed within the previous 92 days, for isolation devices inside primary containment B.
NOTE---------------
Only applicable to penetration flow paths with two or more PCIVs.
One or more penetration flow paths with two or more PCIVs inoperable except due to leakage not within limit for reasons other than Condition D.
B.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> C.
NOTE---------------
Only applicable to penetration flow paths with only one PCIV.
One or more penetration flow paths with one PCIV inoperable except due to leakage not within limits for reasons other than Condition D.
C.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.
AND 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> except for excess flow check valve (EFCV) line and penetrations with a closed system AND 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for EFCV line and penetrations with a closed system (continued)
PCIVs 3.6.1.3 HATCH UNIT 2 3.6-10 Amendment No. 262 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C.
(continued)
C.2
NOTES-----------
- 1. Valves and blind flanges 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 administrative means.
Verify the affected penetration flow path is isolated.
Once per 31 days following isolation D.
One or more penetration flow paths with leakage secondary containment bypass leakage rate, MSIV leakage rate, or EFCV leakage rate not within limit.
D.1 Restore leakage to within limit.
4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for secondary containment bypass leakage AND 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for MSIV leakage AND 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for EFCV leakage E.
Required Action and associated Completion Time of Condition A, B, C, or D not met.
E.1 Be in MODE 3.
AND E.2 Be in MODE 4.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours