ML25247A004

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SNC Slides - Pre-Submittal Meeting - Vogtle 3 and 4 - TSTF-505, 50.69, and TSTF-425 LARs
ML25247A004
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 09/17/2025
From:
Southern Nuclear Operating Co
To: John Lamb
NRC/NRR/DORL/LPL2-1
References
Download: ML25247A004 (1)
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Text

Pre-Submittal Meeting - Vogtle 3 and 4 Proposal to Adopt Three License Amendment Requests (LARs)

(1) Risk-Informed Completion Time (RICT),

(2) 10 CFR 50.69, and (3) Surveillance Frequency Control Program (SFCP)

September 17, 2025

Proposed Vogtle Electric Generating Plant Units 3 & 4 License Amendment Request Revise Technical Specifications to Adopt Risk Informed Completion Times September 17, 2025

Agenda Description Technical Evaluation Regulatory Evaluation PRA Adequacy Schedule Discussion / Feedback

Adopt Risk Informed Completion Times DESCRIPTION

  • Based on Technical Specification Task Force (TSTF) Travelers

- TSTF-505, Provide Risk-Informed Extended Completion Times

- RITSTF Initiative 4b (ADAMS Accession No. ML18183A493)

  • Generally consistent with TSTF-505, Revision 2, with variations (to be discussed),

including incorporation of TSTF-591, Revision 0 (ML22081A224)

  • Modifies Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Technical Specification (TS)

Completion Times (CTs) for Required Actions to provide the option to calculate a longer, risk-informed Completion Time CT (RICT)

  • Adds a new program, the Risk-Informed Completion Time Program, and a new reporting requirement, the Risk-Informed Completion Time (RICT) Program Update Report, are added to TS Section 5, Administrative Controls
  • Applies methodology described in NEI 06-09, "Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines," Revision 0-A (ML12286A322) as approved by the NRC (ML071200238). Adherence to NEI 06-09-A is required by the RICT Program 4

Adopt Risk Informed Completion Times Proposed Changes Example (Typical, from TSTF-505)

ACTIONS 5

A.

One subsystem inoperable.

A.1 Restore subsystem to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program

Adopt Risk Informed Completion Times DESCRIPTION (continued)

  • New Program
  • TS 5.5.15 Risk Informed Completion Time Program

- No variations, other than incorporation of TSTF-591

  • New Report
  • TS 5.6.7 Risk Informed Completion Time (RICT) Program Upgrade Report

- No variations from TSTF-591 6

Adopt Risk Informed Completion Times DESCRIPTION (continued)

  • Variations (proposed)

- RICTs will only be applied in MODE 1 and MODE 2

- As noted above, SNC is also incorporating changes to TSTF-505 identified in TSTF-591.

SNC is not proposing any variations from the TS changes described in TSTF 591, Revision 0

- No revised, clean typed TS pages per the model application

- To preclude the RICT from being applied where a loss of safety function might be possible (e.g.,

Conditions that allow for one or more channels inoperable), TSTF-505, Revision 2, specifies the addition of a Note, where appropriate, that reads Not applicable when [all] required [channels] are inoperable

- For some VEGP TS, a Note is not considered necessary where a separate Condition exists which addresses a loss of function and does not apply use of RICT (e.g., for TS 3.3.1.1, Reactor Protection System (RPS) Instrumentation, One or more Functions with RPS trip capability not maintained).

These separate actions (without use of RICT) must be applied regardless, and thus, a loss of Function is adequately addressed without the need for additional Notes 7

Adopt Risk Informed Completion Times Proposed Changes Example (Separate Condition for LOSF)

ACTIONS for TS 3.3.1, RCS Instrumentation 8

CONDITION REQUIRED ACTION COMPLETION TIME C.

Required Action and associated Completion Time of Condition A or B not met.

C.1 Enter the Condition Referenced in Table 3.3.1-1 for the channel(s).

Immediately OR One or more Functions with three or more channels inoperable.

D.

As required by Required Action C.1 and referenced in Table 3.3.1-1.

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 /> E.

As required by Required Action C.1 and referenced in Table 3.3.1-1.

E.1 Reduce THERMAL POWER to <

P-10.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />

Adopt Risk Informed Completion Times DESCRIPTION (continued)

Variations (proposed) ACTIONS for TS 3.5.2, CMTs - Operating

- The model application provided in TSTF-505 includes mark-ups to Completion Times in a format using an "OR" Logical Connector followed by "In accordance with the Risk Informed Completion Time Program"

- SNC TS 3.5.2 Condition E already has an AND logic in the existing Completion Time for the Required Action, i.e., 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of LCO 3.5.2 Condition E entry concurrent with LCO 3.5.1 Condition B entry AND 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />

- TS Section 1.2, "Logical Connectors," specifies that Completion Times only use first level logic.

- Therefore, the proposed markups have been modified for Condition E to split the Condition in two parts, adding a new Condition F to provide equivalent requirements.

- The revised TS 3.5.2 formatting meets the intent of the existing TS Actions and provides the identical requirements

- Further, the revised formatting follows VEGP TS Section 1.2 and does not create a second level logic for the Completion Times.

- This is an administrative deviation from TSTF-505 with no impact on the NRC's model safety evaluation 9

Adopt Risk Informed Completion Times Proposed Changes Example ACTIONS for TS 3.5.2, CMTs - Operating 10 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One CMT inoperable due to one CMT outlet isolation valve inoperable.

A.1 Restore outlet isolation valve to OPERABLE status.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OR In accordance with the RICT PROGRAM B.

One CMT inoperable due to water temperature or boron concentration not within limits.

B.1 Restore water temperature and boron concentration to within limits.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OR In accordance with the RICT PROGRAM C.

Two CMTs inoperable due to water temperature or boron concentration not within limits concurrent with LCO 3.5.1 Condition B entry.

C.1 Restore water temperature and boron concentration to within limits for one CMT.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of LCO 3.5.2 Condition C entry concurrent with LCO 3.5.1 Condition B entry AND 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> D.

Two CMTs inoperable due to water temperature or boron concentration not within limits.

D.1 Restore water temperature and boron concentration to within limits for one CMT.

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 RICT PROGRAM

Adopt Risk Informed Completion Times Proposed Changes Example ACTIONS for TS 3.5.2, CMTs - Operating (continued) 11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ED.

One CMT inlet line with noncondensible gas volume not within limit.

ED.1 Restore CMT inlet line noncondensible gas volume to within limit.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> OR In accordance with the RICT PROGRAM FE.

One CMT inoperable for reasons other than Condition A, B, or E concurrent with LCO 3.5.1 Condition B entry.

FE.1 Restore CMT to OPERABLE status.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of LCO 3.5.2 Condition C entry concurrent with LCO 3.5.1 Condition B entry AND 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> G.

One CMT inoperable for reasons other than Condition A, B, or E.

G.1 Restore CMT to OPERABLE status.

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 RICT PROGRAM HF.

Required Action and associated Completion Time of Condition A, B, C, D, ED, or FE, or G not met.

OR Two CMTs inoperable for reasons other than Condition C or D.

HF.1 AND HF.2 Be in MODE 3.

Be in MODE 5.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours

Adopt Risk Informed Completion Times DESCRIPTION (continued)

  • Variations (proposed)

- TSTF does NOT apply RICT for Required Action of Place inoperable channel in bypass TSTF does apply RICT for Required Action of Place inoperable channel in tri.

- VEGP has Required Actions with option of Place inoperable channel in bypass or trip VEGP plans to request application of RICT for these Required Actions including bypass or trip

- The results of necessary actuations or trips from the inoperable instrumentation are the same before the action is taken, whether you are planning to put the inoperable change in trip or in bypass.

- Per TS 3.3.1 Bases:

  • With one channel bypassed, the logic becomes two-out-of-three, still meeting single failure criterion
  • With one channel tripped, the logic becomes one-out-of-three, still meeting single failure criterion
  • A failure in one of the three remaining channels will not prevent the protective function
  • 2oo3 bypassed logic is less risk of trip actuation and subsequent transient than 1003 tripped logic 12

Adopt Risk Informed Completion Times Proposed Changes Example ACTIONS (Typical for Instrumentation Channels) 13 CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more Functions with one channel inoperable.

A.1 Place inoperable channel in bypass or trip.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> OR In accordance with the RICT PROGRAM

Adopt Risk Informed Completion Times TECHNICAL EVALUATION

  • Technical Evaluations from TSTF are applicable In accordance with Section 4.0, Limitations and Conditions, of the safety evaluation for NEI 06 09-A (ML12286A322), the following 12 Enclosures are provided:

- Enclosure 1 identifies each of the TS Required Actions to which the RICT Program will apply, with a comparison of the TS functions to the functions modeled in the unit-specific probabilistic risk assessment (PRA) for the structures, systems and components (SSCs) subject to those actions. identifies the associated NUREG-1431 TS identified by TSTF-505 and TSTF 591 for RICT application most closely associated with the VEGP Units 3 and 4 TS for which RICT application is proposed and includes additional justifications as requested by TSTF 505. Estimated RICTs are provided for in-scope electrical TS Actions. An evaluation of instrumentation and control systems for redundancy and diversity is also provided

- Enclosure 2 provides a discussion of the results of peer reviews and self-assessments conducted for the plant-specific PRA models which support the RICT Program, as discussed in Regulatory Guide (RG) 1.200, Revision 3, Section C.4.2

- Enclosure 3 is not applicable since each PRA model used for the RICT Program is addressed using a standard endorsed by the Nuclear Regulatory Commission

- Enclosure 4 provides appropriate justification for excluding sources of risk not addressed by the PRA models 14

Adopt Risk Informed Completion Times TECHNICAL EVALUATION Technical Evaluations from TSTF are applicable (continued)

- Enclosure 5 provides the unit-specific baseline core damage frequency (CDF) and large early release frequency (LERF) to confirm that the potential risk increases allowed under the RICT Program are acceptable

- Enclosure 6 is not applicable since the RICT Program is not being applied to shutdown modes

- Enclosure 7 provides a discussion of SNCs programs and procedures that assure the PRA models that support the RICT Program are maintained consistent with the as built, as-operated plant

- Enclosure 8 provides a description of how the baseline PRA model, which calculates average annual risk, is evaluated and modified to assess real-time configuration risk, and describes the scope of, and quality controls applied to the real-time model

- Enclosure 9 provides a discussion of how the key assumptions and sources of uncertainty in the PRA models were identified, and how their impact on the RICT Program was assessed and dispositioned

- Enclosure 10 provides a description of the implementing programs and procedures regarding the plant staff responsibilities for the RICT Program implementation, including risk management action (RMA) implementation

- Enclosure 11 provides a description of the implementation and monitoring program as described in NEI 06-09-A, Section 2.3.2, Step 7

- Enclosure 12 provides a description of the process to identify and provide RMAs 15

Adopt Risk Informed Completion Times REGULATORY EVALUATION

  • Variations fit within the RICT Program requirements evaluation 16

Adopt Risk Informed Completion Times Related Bases Changes Insert (Typical from TSTF)

Alternatively, a Completion Time can be determined for Required Action A.1 in accordance with the Risk Informed Completion Time Program Other Bases Changes Associated with Variations discussed above 17

PRA Overview Information PRA TECHNICAL ADEQUACY AP1000 Design Control Document (DCD) related PRA model (and seismic margin analysis) submitted and reviewed for Design Certification (APP-GW-GL-022)

- DCD PRA revised to plant-specific PRA prior to Vogtle 3&4 operation.

  • Upgraded to the ASME/ANS NRC-endorsed standard
  • Expanded to evaluate the site seismic hazard by PRA methods
  • Models peer reviewed in accordance with current industry practices endorsed by the NRC
  • Peer reviewed PRA models demonstrate NRC safety goals are met

- RICT utilizes plant-specific PRA updated (2025) prior to submittal

  • Findings and Observations closure independent validation 18

PRA Overview Information PRA TECHNICAL ADEQUACY - RICT LAR

- Peer reviews and self-assessments conducted for the plant-specific PRA models which support the RICT Program, as discussed in Regulatory Guide (RG) 1.200, Revision 3, Section C.4.2

- Sources of risk not addressed by the PRA models justified

- Unit-specific baseline core damage frequency (CDF) and large early release frequency (LERF) confirm that the potential risk increases allowed under the RICT Program are acceptable

- SNCs PRA configuration control program and procedures assure the PRA models that support the RICT Program are maintained consistent with the as built, as-operated plant

- Key assumptions and sources of uncertainty in the PRA models identified, and their impact on the RICT Program assessed and dispositioned

- Open F&Os and their impact on the application will be addressed 19

PRA Overview Information CRMP Model for RICT and RMAT calculations

- Baseline PRA models, which calculate average annual risk, modified to assess real-time configuration risk

- CRMP model/tool to have attributes specified in NEI 06-09

- One-top model

  • Internal Events, Internal Flood, and Fire
  • Seismic penalty calculated by plant-level evaluation

- CRMP model/tool quality controls 20

Adopt Risk Informed Completion Times Schedule

  • Target submittal - 1Q2026
  • Outage related

- No

  • Target approval - 4Q2026 21

Adopt Risk Informed Completion Times Discussion / Feedback 22

23

Vogtle Electric Generating Plant Units 3 & 4 License Amendment Request License Amendment Request to Adopt 10 CFR 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors September 17, 2025

Agenda Meeting Purpose Background Information Licensing Approach License Amendment Request (LAR) Scope LAR Overview Approach for Addressing Seismic Risks Schedule / Q&A

Vogtle 3&4 Adoption of 10 CFR 50.69 Meeting Purpose SNC intends is to submit an application to modify the Combined Licenses (COLs) for Vogtle Electric Generating Plant, Units 3 and 4 (Vogtle 3&4)

The proposed amendment would add a license condition to document the NRCs approval for the use of 10 CFR 50.69 The purpose of this meeting is to discuss some background information, the licensing approach, the proposed change, contents of the submittal, and a preliminary timeline 26

Vogtle 3&4 Adoption of 10 CFR 50.69 Background Information - 10 CFR 50.69 Rulemaking On November 22, 2004, the NRC issued the final rule for 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors (69 FR 68047)

Per Section V.3.0 of the final rule posting, Section 50.69(b) may be voluntary implemented by:

1)

A holder of a license to operate a light water reactor (LWR) nuclear power plant under this part; 2)

Holders of Part 54 renewed LWR licenses; 3)

An applicant for a construction permit or operating license under this part; and 4)

An applicant for a design approval, a combined license, or manufacturing license under Part 52 of this chapter 27

Vogtle 3&4 Adoption of 10 CFR 50.69 Background Information - 10 CFR 50.69 Rulemaking The FR posting goes on to state, in part (emphasis added):

The final rule excludes applicants for standard design certifications from the group of entities who may take advantage of the provisions of §50.69. In considering whether to extend the applicability of §50.69 to design certifications, the Commission identified a number of difficult issues which would have to be resolved to support such an extension. ; and that:

Part 52 cross-references regulations from other parts of Chapter 10 of the [CFR], most notably Part 50. Therefore, it was initially considered for inclusion in this rulemaking effort. However, the applicability paragraph (§50.69(b)) makes clear that §50.69 is available to applicants for, and holders of a facility license. Accordingly, there is no need to revise Part 52 to assure the availability of §50.69. There are issues associated with Part 52 design certifications and these are currently excluded from the group of entities who may adopt the provisions of 50.69 as discussed in Section V.3.0.

28

Vogtle 3&4 Adoption of 10 CFR 50.69 Background Information - 10 CFR 50.69 Applicability and Scope It appears from rulemaking documentation that the NRC intended that Part 52 holders be able to apply for 10 CFR 50.69; however, paragraph (b)(1) of the final rule states, in part (emphasis added):

(b) Applicability and scope of risk-informed treatment of SSCs and submittal/approval process. (1) A holder of a license to operate a light water reactor (LWR) nuclear power plant under this part; a holder of a renewed LWR license under part 54 of this chapter; an applicant for a construction permit or operating license under this part; or an applicant for a design approval, a combined license, or manufacturing license under part 52 of this chapter; may voluntarily comply with the requirements in this section as an alternative to compliance with the following requirements for RISC-3 and RISC-4 SSCs 29

Vogtle 3&4 Adoption of 10 CFR 50.69 Background Information - Petition for Rulemaking The issue of Part 52 holders being unable to adopt 10 CFR 50.69 was the subject of a petition for rulemaking (PRM) submitted by the Nuclear Energy Institute (NEI)

On January 15, 2015, NEI petitioned for a rule change to extend the applicability of 10 CFR 50.69 to Part 52 COL holders (ML15037A481)

A similar petition was submitted by NEI on February 25, 2014 (ML14056A278),

which stated, in part, [w]e believe the omission of applicability to COL holders is an oversight that should be corrected through an administrative change to the existing regulation. There is no practical or safety basis to limit applicability in this manner, and the statement of considerations for the rule provides no basis for such a limitation 30

Vogtle 3&4 Adoption of 10 CFR 50.69 Licensing Approach - Options Option 1 - Pursue completion of rulemaking activities to amend § 50.69 to include Part 52 holders in paragraph § 50.69(b)(1)

Option 2 - Develop a program that includes requirements similar to those in § 50.69 and seek NRC approval for the program under § 50.90 o The risk-informed categorization and treatment program would follow NEI 00-04 and be defined within the proposed license condition o This approach would necessitate exemptions from the regulations referenced in

§ 50.69(b)(1)(i) through (xi) - Part 21, § 50.49, § 50.72, Appendix B to Part 50, etc.

o Option 2 would be similar to the proof-of-concept described in Section IV.2.0 in the § 50.69 final rule posting (69 FR 68047) 31

Vogtle 3&4 Adoption of 10 CFR 50.69 Licensing Approach - Options Option 3 - Pursue an exemption request to expand the scope of the rules applicability to include Part 52 COL holders o The request would seek exemption from § 50.69(b)(1), where it states, an applicant for a combined license under part 52 of this chapter may voluntarily comply with the requirements in this section as an alternative to compliance with the following requirements for RISC-3 and RISC-4 SSCs o Seeking exemption from this paragraph would allow a Part 52 COL holder to apply for the rule under § 50.90, in accordance with § 50.69(b)(2).

SNCs preferred approach is Option 3 - seek exemption from § 50.69(b)(1) 32

Vogtle 3&4 Adoption of 10 CFR 50.69 License Amendment Request (LAR) Scope The proposed amendment would add a condition to the Vogtle 3&4 license to document the NRCs approval for the use of 10 CFR 50.69 The license condition will identify the processes to be used for categorization of structures, systems and components (SSCs):

o Internal events, internal flooding, fire risk - PRA model o Shutdown risk - Shutdown safety assessment process o Passive component risk - Arkansas Nuclear One, Unit 2 (ANO-2) method o External hazards - Screened per the ASME/ANS PRA Standard, except for seismic risk o Seismic risk - EPRI alternative approach as described in the LAR 33

Vogtle 3&4 Adoption of 10 CFR 50.69 LAR Overview - Categorization The categorization process will follow NEI 00-04 (except for the seismic risk evaluation) o PRA-based evaluations utilizing internal events, internal flooding, and fire PRA models o Other external hazards screened per the ASME PRA Standard o Shutdown safety assessment based on NUMARC 91-06 o Seven qualitative criteria in Section 9.2 of NEI 00-04 o Defense-in-depth assessment o Passive categorization using ANO-2 methodology o Integral assessment The EPRI alternative seismic approach will be used for addressing seismic risk 34

Vogtle 3&4 Adoption of 10 CFR 50.69 LAR Overview - PRA PRA maintenance and updates Uncertainty evaluations Feedback and adjustment process PRA model technical adequacy (discussed during the RICT presentation) o Summary of peer review activities o Open F&Os and their impact on the application o Key assumptions and sources of uncertainty and their impact on the application To improve efficiency, the LAR will request that the NRC conduct their review of the PRA technical adequacy details in coordination with the review of the RICT application 35

Vogtle 3&4 Adoption of 10 CFR 50.69 LAR Layout and Content

  • The LAR will be presented in a similar format as other plants that requested adoption of § 50.69 using the EPRI alternative seismic approach (e.g.,

Turkey Point - ML25182A034), with additional information relevant to Vogtle 3&4, such as:

Information related to the Regulatory Treatment of Non-Safety Systems (RTNSS) for passive advanced LWRs Section 3.2.3, Seismic Hazards, will provide updated information from POANHI activities

  • Draft and subject to change 36

Vogtle 3&4 Adoption of 10 CFR 50.69 Approach for Addressing Seismic Risks

  • In 2014, SNC provided information that supported the conclusion that the standard AP1000 design bounded the site-specific seismic demand (ML14339A849) 37

Vogtle 3&4 Adoption of 10 CFR 50.69 Approach for Addressing Seismic Risks The NRCs August 12, 2015, letter, stated

[t]he staff reviewed these figures, which demonstrate that the updated in-structure seismic demands are bounded by the AP1000 standard design seismic demands.

(ML15139A516)

The LAR will also discuss the results from the process for the ongoing assessment of natural hazards information (POANHI).

(ML23006A091)

Since the seismic design basis exceeds the hazard, Vogtle 3&4 meets the Tier 1 criteria in EPRI 3002017583 (ML21082A170) 38 Updated GMRS for Vogtle Site

Vogtle 3&4 Adoption of 10 CFR 50.69 Schedule

  • Target Submittal - 1Q2026
  • Outage Related - No
  • Target Approval - 4Q2026 39

Adopt Surveillance Frequency Control Programs Discussion / Feedback 40

41

Proposed Vogtle Electric Generating Plant Units 3 & 4 License Amendment Request Revise Technical Specifications to Adopt Surveillance Frequency Control Program (SFCP)

September 17, 2025

Agenda Description Technical Evaluation Regulatory Evaluation Schedule Discussion / Feedback

Adopt Surveillance Frequency Control Program DESCRIPTION Based on Technical Specification Task Force (TSTF) Travelers

  • TSTF-425, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b Rev. 3

- (ADAMS Accession No. ML090850642)

- (ADAMS Accession No. ML18333A152)

- (ADAMS Accession No. ML24362A056) 44

Adopt Surveillance Frequency Control Program TSTF-425 Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b Rev. 3 45

Adopt Surveillance Frequency Control Program DESCRIPTION

  • TSTF-425, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b

- Generally consistent with TSTF-425, Revision 3, with few minor variations.

- Modifies Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Technical Specification (TS) to:

- Applies methodology described in NEI 04-10, "Risk-Informed Technical Specifications Initiative 5b, Risk-Managed Method for Control of Surveillance Frequencies," Revision 1 [ML12286A322] as approved by the NRC

[ML062700012]. Adherence to NEI 04-10 is required by the SFCP 46

Adopt Surveillance Frequency Control Program DESCRIPTION

  • Relocates periodic Surveillance Frequencies from TS and places Frequencies in the SFCP, except Frequencies that:

- Reference other programs for the specific interval (see variation regarding TSTF-596),

- Are purely event-driven,

- Are event-driven, but have a time component for performing the surveillance on a one-time basis once the event occurs, or

- Are related to specific conditions

  • Frequencies changed to In accordance with the SFCP
  • The Bases for each affected Surveillance is revised to state that the Surveillance Frequency is controlled under the SFCP 47

Adopt Surveillance Frequency Control Program Proposed Changes Example (Typical, from TSTF-425)

SURVEILLANCE REQUIREMENTS 48 SURVEILLANCE FREQUENCY SR 3.3.4.1 Verify RTS RESPONSE TIME is within limit.

24 months on a STAGGERED TEST BASIS In accordance with the SFCP

Adopt Surveillance Frequency Control Program Proposed Changes Example (Complex, from TSTF-425) 49 SURVEILLANCE FREQUENCY SR 3.5.1.4 Verify the boron concentration in each accumulator is 2600 ppm and 2900 ppm 31 Days In accordance with the SFCP AND NOTE -

Only required for affected accumulators.

Once within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after each solution volume increase of 51 cu. ft. that is not the result of addition from the in-containment refueling water storage tank

Adopt Surveillance Frequency Control Program VARIATIONS (proposed) 1.

Add definition of Surveillance Frequency Control Program (SFCP) to TS 1.1, Definitions:

The SFCP documents the Surveillance Frequencies that reference the SFCP and provides controls for changes to the Frequencies, in accordance with Specification 5.5.16.

  • Allows use of defined term SFCP throughout TS.

2.

Did not delete TS 1.1 definition of STAGGERED TEST BASIS

  • Term is used in the Completion Time for LCO 3.3.19, DAS Manual Controls, Required Action B.1 to Perform SR 3.3.7.1.
  • Completion Time is Once per 31 days on a STAGGERED TEST BASIS.

50

Adopt Surveillance Frequency Control Program VARIATIONS (proposed) (continued) 3.

SNC is also incorporating changes to TSTF-425 identified in TSTF-596

  • Change TS with Surveillance Frequencies of In accordance with the Inservice Testing Program

- These are administrative deviations from TSTF-425 with no impact on the NRC's model SE 51

Adopt Surveillance Frequency Control Program TECHNICAL / REGULATORY EVALUATION Technical Evaluations from TSTF are applicable SFCP implementation will follow the methodology in NEI 04-10, Rev. 1, in evaluating proposed surveillance frequency changes

- PRA Model adequacy (per RG 1.200) was previously discussed for TSTF-505 Risk-Informed Completion Times (RICT) LAR

- Open F&Os and their impact on the application will be addressed Regulatory Evaluation is consistent with Safety Evaluation Regulatory Requirements 52

Adopt Surveillance Frequency Control Program TSTF-563 Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program Rev. 0 53

Adopt Surveillance Frequency Control Program DESCRIPTION

- TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program, Rev. 0

- Applies to licensees that have adopted TSTF-425, Rev. 3 to relocate Surveillance Frequencies to licensee control in a Surveillance Frequency Control Program (SFCP).

- Revises definitions of instrumentation and controls tests to allow the required frequency for testing the components or devices in each step to be determined in accordance with the SFCP.

- Involves changes to the TS definitions that currently permit performance by any series of sequential, overlapping, or total channel steps:

  • Channel Calibration,
  • Channel Functional Test,
  • Channel Operational Test, and
  • Trip Actuating Device Operational Test 54

Adopt Surveillance Frequency Control Program Proposed Changes Example (Typical, from TSTF-563)

DEFINITIONS 55 Term Definition CHANNEL OPERATIONAL TEST (COT)

A COT shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY of all devices in the channel required for channel OPERABILITY. The COT shall include adjustments, as necessary, of the required alarm, interlock, and trip setpoints required for channel OPERABILITY such that the setpoints are within the necessary range and accuracy. The COT may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

Adopt Surveillance Frequency Control Program DESCRIPTION (continued)

  • Variations

- None

  • Related Bases Changes

- None 56

Adopt Surveillance Frequency Control Program TECHNICAL / REGULATORY EVALUATION

Adopt Surveillance Frequency Control Program TSTF-596 Expand the Applicability of the Surveillance Frequency Control Program (SFCP)

Rev. 2 58

Adopt Surveillance Frequency Control Program DESCRIPTION TSTF-596, Expand the Applicability of the Surveillance Frequency Control Program (SFCP), Rev. 2 Changes related to how the Inservice Testing (IST) Program is referenced

- Revise SR test Frequencies that state in accordance with the Inservice Testing Program to read in accordance with the SFCP

- Revise SRs that reference the IST Program in the Surveillance column by replacing the reference with a description of the required test

- Revise TS Bases for each SR that is required by the IST Program to indicate that it is to be performed in accordance with 10 CFR 50.55a(f), which is the regulatory requirement for licensees to meet the IST requirements of the ASME BPV and OM Codes

- Revise TS Bases for SR Frequencies for surveillances that are required by the IST Program to state, The Surveillance Frequency is controlled under the SFCP in accordance with the requirements of 10 CFR 50.55a(f). (Add references to 10 CFR 50.55a(f).)

59

Adopt Surveillance Frequency Control Program DESCRIPTION (continued)

- Changes the periodic testing frequencies required by four TS Section 5.5 programs to reference the SFCP.

- The specific revised testing frequencies are in the following programs:

- Related Submittals

  • Entergy submitted a fleet LAR as a CLIIP in April 2025 [ML25119A223]

Adopt Surveillance Frequency Control Program Proposed Changes Example (Frequency refers to IST Program)

SURVEILLANCE REQUIREMENTS:

Bases mark-up (for information only):

The Surveillance Frequency for demonstrating valve OPERABILITY references the Inservice Testing Program is controlled under the SFCP in accordance with the requirements of 10 CFR 50.55a(f) (Ref. 6).

61 SURVEILLANCE FREQUENCY 3.4.11.2 Verify each stage 1, 2, and 3 ADS valve strokes open.

In accordance with the Inservice Testing Program SFCP

Adopt Surveillance Frequency Control Program Proposed Changes (Surveillances that refer to IST Program)

LAR proposes: Revising SRs by replacing IST references with a test description.

- SR 3.4.6.1, Pressurizer Safety Valves

  • Verify each pressurizer safety valve OPERABLE, in accordance with the IST Program.

- SR 3.4.14.5, Low Temperature Overpressure Protection (LTOP)

  • Verify the lift setting of each RNS suction relief valve...

- SR 3.6.9.3, Vacuum Relief Valves

- SR 3.7.1.1, Main Steam Safety Valves (MSSVs)

  • Verify each MSSV lift setpoint per Table 3.7.1-2 62

Adopt Surveillance Frequency Control Program Proposed Changes (Surveillances that refer to IST Program)

Bases mark-up (for information only):

SRs are specified in the Inservice Testing Program. Pressurizer safety valves are to be tested one at a time and in accordance with the requirements of ASME OM Code 10 CFR 50.55a(f) (Ref. 4), which provides the activities and Frequency necessary to satisfy the SRs. No additional requirements are specified. The Surveillance Frequency is controlled under the SFCP in accordance with the requirements of 10 CFR 50.55a(f).

The pressurizer safety valve setpoint is +/- 1% for OPERABILITY, and the values are reset to remain within +/- 1% during the Surveillance to allow for drift.

63 SURVEILLANCE FREQUENCY 3.4.6.1 Verify each pressurizer safety valve OPERABLE in accordance with the Inservice Testing Program lift setting is 2460 psig and 2510 psig.

Following testing, lift settings shall be within +/-1%.

In accordance with the Inservice Testing Program SFCP

Adopt Surveillance Frequency Control Program Proposed Changes (Surveillances that refer to IST Program)

Retaining IST references in Surveillance and Frequency:

- SR 3.4.11.3, Automatic Depressurization System (ADS) - Operating

- SR 3.5.6.8, In-containment Refueling Water Storage Tank (IRWST) - Operating

Adopt Surveillance Frequency Control Program Variations - proposed 1.

TSTF-596 proposes changes to testing programs not in VEGP 3&4 TS

  • Primary Coolant Sources Outside Containment (N/A for VEGP 3&4)
  • Diesel Oil Testing Program (N/A for VEGP 3&4)

Omission of these programs does not impact technical or regulatory justification of the TSTF 65

Adopt Surveillance Frequency Control Program COORDINATION WITH 10 CFR 50.69 LAR

- As discussed in NRC SE for TSTF-596 [ML24362A056] reviews are not linked

- Proposed TS paragraph 5.5.15.b.2 requires changes to Frequencies in accordance with 10 CFR 50.69(d)(2) for testing permitted under §50.69(b)(1)(v) in lieu of §50.55a(f)

- 10 CFR 50.69(b)(3) requires NRC approval prior to implementation of §50.69

- Review of both LARs may be performed in parallel, and either LAR may be approved before the other 66

Adopt Surveillance Frequency Control Program TECHNICAL / REGULATORY EVALUATION Technical Evaluations from TSTF are applicable for changes to TS 5.5, Programs &

Manuals 67

Adopt Surveillance Frequency Control Program ADDITIONAL CHANGES

1. Changes are proposed to TS 5.5.13, VFTP, similar to TSTF-596 changes, except:
  • Additional changes are proposed to 5.5.13.a to delete expired test requirements, as follows:

- 1st paragraph: Delete reference to tests performed initially

- 1st & 3rd paragraphs: Delete the exception for testing performed prior to startup from first refueling outage (added by Amendment Nos. 198 & 181)

  • Deleted text describes expired requirements, similar to those deleted by Vogtle 3&4 Amendment Nos. 202 & 199 2.

Vogtle 3&4 SRs for System Level OPERABILITY Testing Program (TS 5.5.9 will be changed from 10 years to In accordance with the SFCP.)

SR 3.6.6.6, PCS: At first refueling is proposed to be deleted Expired - Both Units 3 & 4 will have had first refueling outages 68

Adopt Surveillance Frequency Control Program Schedule

  • Target submittal 1Q2026
  • Outage related No
  • Target approval 4Q2026 69

Adopt Surveillance Frequency Control Program Discussion / Feedback 70

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