ND-22-0831, (Vegp), Units 3 and 4, Comments on AP1000 Standard Technical Specifications (STS) Draft NUREG-2194, Revision 1

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(Vegp), Units 3 and 4, Comments on AP1000 Standard Technical Specifications (STS) Draft NUREG-2194, Revision 1
ML22304A227
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 10/31/2022
From: Whitley B
Southern Nuclear Operating Co
To: Victor Hall
Office of Nuclear Reactor Regulation, Document Control Desk
References
ND-22-0831
Download: ML22304A227 (1)
v • d • e


Text

Brian H. Whitley Southern Nuclear Director, Regulatory Affairs Operating Company, Inc.

3535 Colonnade Parkway Birmingham, AL 35243 Tel 205.992.7079 October 31, 2022 ND-22-0831 U.S. Nuclear Regulatory Commission Victor E. Hall, Chief Vogtle Project Office Office of Nuclear Reactor Regulation Washington, DC 20555-0001 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Docket Nos.: 52-025 & 52-026

Subject:

Southern Nuclear Company VEGP Comments on AP1000 Standard Technical Specifications (STS) - Draft NUREG-2194, Revision 1 Ladies and Gentlemen:

On August 10, 2022, NRC Staff requested comments from Southern Nuclear Operating Company (SNC) (i.e., an AP1000 plant COL holder) on the draft of Revision 1 of the AP1000 Standard Technical Specifications (STS) to provide assurance that any technical inaccuracies are identified and corrected [ADAMS Accession No. ML22220A197]. The request asked that comments be provided by September 30, 2022; however, in subsequent discussions it was agreed that SNC would provide comments by October 31, 2022.

The SNC review identified many Technical Specification (TS) Bases (TSB) differences from NUREG-2194 Revision 0 that appeared to be editorial and/or presentation preference type changes. A number of these changes depart from other STS NUREGs (e.g., NUREG-1431) and from Vogtle Electric Generating Plant (VEGP) Unit 3. Since the request was to focus on technical inaccuracies, many of these differences are not addressed in the comments provided.

Through this letter SNC provides the requested review in the allotted timeframe and with the SNC resources available at the time; however, since there were no markups provided showing differences from NUREG-2194 Revision 0, SNC was challenged to ensure all potential differences have been identified and evaluated. Furthermore, since there were no discussions or justifications provided for those differences (i.e., as would be the case for generic changes to other STS NUREGs in accordance with the Technical Specification Task Force [TSTF]

process), evaluating the appropriateness of the NUREG-2194 Revision 1 text, including its technical accuracy, was also difficult in many cases. For example, TSB design detail and logic descriptions that differ from the approved VEGP Unit 3 TSB could not be fully technically evaluated. Comments were provided when revision to the draft Revision 1 text was clearly warranted. However, the review effort did encompass providing the requested comments to include appropriate changes related to VEGP TS Bases Revision 70. provides the review comments associated with NUREG-2194, Volume 1, Specifications.

U.S. Nuclear Regulatory Commission ND-22-0831 Page 2 of 3 provides the review comments associated with NUREG-2194, Volume 2, "Bases."

This letter contains no regulatory commitments. This letter has been re:viewed and determined not to contain security-related information .

If you have any questions, please contact Amy Chamberlain at 205.992.6361.

Respectfully submitted, Regulatory Affairs Director Southern Nuclear Operating Company Attachments: 1) NUREG-2194 Volume 1, Technical Specification (TS) Comments

2) NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments

U.S. Nuclear Regulatory Commission ND-22-0831 Page 3 of 3 cc: w/o Attachments Regional Administrator, Region ll VPO Project Manager Senior Resident Inspector - Vogtle 3 & 4 Director, Environmental Protection Division - State of Georgia Document Services RTYPE: VND.LI.L00 File AR.01.02.06

Southern Nuclear Operating Company ND-22-0831 Attachment 1 NUREG-2194 Volume 1, Technical Specification (TS) Comments

NUREG-2194 Volume 1, Technical Specifications (TS) Comments Page 1 of 4 Item Comment Justification Abstract Revise the first paragraph to describe the past-tense origin Current description is silent on the more complete history leading to NUREG-of Revision 0 and add sentence acknowledging 2194, Revision 1.

Subsequently, the NRC has issued additional amendments to the VEGP Unit 3 TS (i.e., through Amendment 186), which informs the basis for Revision 1 of the AP1000 STS.

Various Delete numerous blank pages throughout Volume 1. Blank pages provide a misleading suggesting that there is an intended format to include blank pages.

Various Revise use of Trip Setpoint[s] to lower initial capitalization This capitalization is consistent with VEGP Unit 3 and with NUREG-1431 trip setpoint[s] unless specifically referring to Nominal instances. This editorial change would establish consistency.

Trip Setpoint.

Table of Contents Sections 4.1, 4.2, and 4.3 page numbers to be added. For consistency with all other Sections in the Table of Contents.

1.1 Definitions, Add definition for ACTUATION LOGIC TEST Refer to Vogtle Electric Generating Plant (VEGP) Unit 3 Amendment 168 Actuation Logic (ML19297C791), which retained this definition as used in Surveillance Test Requirement (SR) 3.3.20.3.

1.1 Definitions, Second paragraph or thermocouple sensors should be Refer to VEGP Unit 3 Amendment 166 (ML19282D340), which justifies this Channel revised to , thermocouples, or reactor coolant pump speed change.

Calibration sensors 1.3 Completion Revise the title of LCO 3.5.1 from Passive Core Cooling LCO 3.5.1 title is Accumulators. Passive Core Cooling System (PXS) is the Times (p.1) System (PXS) to Accumulators title of Section 3.5.

LCO 3.1.2, Delete Action C Action C appears to have been added to Revision 1 in error. There is no TSTF Action C or VEGP Amendment that adds an Action C. Furthermore, Condition C addresses a specific condition that is not called out in LCO 3.1.2.

LCO 3.1.4 Replace Required Actions B.1.1 AND B.1.2 OR B.2 with The draft NUREG-2194 Revision 1 Required Action B.1.1 requires a once per ACTIONS VEGP Required Action B.1. Renumber the B.3.x series to hour verification the Applicability of TS 3.2.5 being met (i.e., OPDMS be B.2.x series monitoring parameters). This imposes an unnecessary operator administrative burden that was not required in NUREG-2194 Revision 0 or required in VEGP TS. VEGP Unit 3 Required Action B.1 was revised in Amendment 138 (ML18100A110).

NUREG-2194 Volume 1, Technical Specifications (TS) Comments Page 2 of 4 Item Comment Justification LCO 3.1.9, Add use of acronyms DWI and MLI in LCO Title. These acronyms are not spelled out or defined in LCO, Table of Contents, or Header Bases. Adding definitions (DWI) and (MLI) in LCO Title would provide a basis for these terms in the header for this LCO.

LCO 3.1.9, Action Flow paths revised to Flow path(s) - add parentheticals An inoperability leading to entering the Actions might affect only one flow path.

Note around s. Parenthetical (s) infers one or more and is more appropriate. This is consistent with VEGP Unit 3 TS as revised in Amendment 13 (ML13238A337).

LCO 3.1.10, Revise Applicability to MODE 5 with LCO 3.4.4 not met. LCO 3.1.10 was added by VEGP Unit 3 Amendment 117 (ML18060A411) with Applicability the Applicability MODE 5 with LCO 3.4.4 not met with no further Amendments. LCO 3.4.4 can be not met (and LCO 3.1.10 Applicability met) with only one (or more) of four reactor coolant pumps (RCPs) not in operation, while the NUREG-2194 draft Revision 1 Applicability can only be entered with all four RCPs not in operation. This technical difference is overly restrictive and not aligned with the VEGP licensing basis.

LCO 3.2.1 and Format the Applicability with an indented second line. This format aligns with the Writers Guide for LCO Applicabilities.

LCO 3.2.3 Applicability LCO 3.2.3, Revise reference to SR 3.3.1.5 to SR 3.3.1.4. SR 3.3.1.5 was revised to SR 3.3.1.4 for VEGP Unit 3 in Amendment 168 Note 4 (ML19297C791) due to deletion of SR 3.3.1.1.

Table 3.3.4-1 Remove yellow highlighting in Surveillance Requirement Yellow highlighting is not an allowed format option.

column.

LCO 3.3.5, Revise instances of division[s] to channel[s] NUREG-2194 Revision 0, as well as VEGP Unit 3 Amendment 13, used Various channel[s] for LCO, Actions, and Table 3.3.5-1. NUREG-2194 Revision 1 draft division[s] does not align with the design. While the RTS actuation logic (see LCO 3.3.6) consists of four divisions, the manual actuations consist of two channels each.

NUREG-2194 Volume 1, Technical Specifications (TS) Comments Page 3 of 4 Item Comment Justification Table 3.3.5-1, Delete parenthetical additions to 2 for Functions 1, 2, and The Required Channels for Functions 1 and 2 have been 2 for NUREG-2194 Required 4 Required Channels. Revise Function 3 Required Revision 0, as well as VEGP Unit 3 initial COL and Amendment 13. The Channels Channels to 2 switch sets Required Channels for Function 3 have been 2 switch sets for NUREG-2194 Revision 0, as well as VEGP Unit 3 initial COL and Amendment 13. The Required Channels for Function 4 were revised to 2 in VEGP Unit 3 Amendment 138 (ML18100A110). The proposed parenthetical modifiers in NUREG-2194 Revision 1 draft are not in accordance with the design.

Table 3.3.17-1 Revise to include Surveillance Requirement column and This more typical format for presenting which SRs apply to each Function was revise the Surveillance Requirements Note to Refer to implemented in VEGP Unit 3 Amendment 168 (ML19297C791).

Table 3.3.17-1 to determine which SRs apply for each PAM Function.

Table 3.3.19-1 Revise Footnote (b) value 6.0 to 7.0 Reactor decay heat value of 6.0 MWt was revised to 7.0 MWt in Amendment 126 (ML18100A069) to align with revised safety analyses.

Table 3.3.20-1 Function 2, MODES 4, 5, and 6 listing of Surveillance The applicable SRs for Function 2 in MODES 4, 5, and 6 were approved in Requirements revise SR 3.3.20.2 and SR 3.3.20.3 to VEGP Unit 3 Amendment 168 (ML19297C791). NUREG-2194 listing of SR 3.3.20.3 and SR 3.3.20.4. Channel Calibration (SR 3.3.20.2) in lieu of TADOT (SR 3.3.20.4) is not appropriate for surveillance of a manual switch function.

LCO 3.4.12 Revise A.1 Four flow paths... to Five flow paths... VEGP Unit 3 Amendment 118 (ML18075A094) revised the required Required Actions Automatic Depressurization System (ADS) requirements to support vacuum fill operations.

LCO 3.5.2, Delete SR 3.5.2.2 and renumber remaining SRs. VEGP Unit 3 Amendment 176 (ML20049A655) deleted this Surveillance.

SR 3.5.2.2 LCO 3.5.3, Replace listed Surveillance SR 3.5.2.3 with SR 3.5.2.4 VEGP Unit 3 Amendment 176 (ML20049A655) revised the referenced SR 3.5.3.1 and delete listed Surveillance SR 3.5.2.8. Surveillances based on deleting SR 3.5.2.2 and renumbering the remaining SRs.

LCO 3.7.10 Add Applicability Note: PORV OPERABILITY is not NUREG-2194, Revision 0, for LCO 3.7.10 (refer to ML16111A200) included Applicability required in MODE 4 with Reactor Coolant System (RCS) discussion of adding this Applicability Note, and added a description of it in being cooled by the Normal Residual Heat Removal Volume 2, Bases (as also appears in draft NUREG-2194 Revision 1 System (RNS). Volume 2). The Applicability Note was inadvertently omitted in Revision 0 and draft Revision 1 from Volume 1, Specifications.

NUREG-2194 Volume 1, Technical Specifications (TS) Comments Page 4 of 4 Item Comment Justification LCO 3.7.11 Revise Applicability to read When fuel assemblies are This ensures the LCO applies even after a spent fuel pool storage verification Applicability stored in the spent fuel pool. has been performed. VEGP Unit 3 Amendment 172 (ML19343C013) revised this Applicability.

LCO 3.7.11 Modify the Required Actions to This change is consistent with the change to the Applicability (comment Required Actions above). VEGP Unit 3 Amendment 172 (ML19343C013) provided these

  • Change Required Action A.2.1 number to A.2 changes.
  • Delete Required Action A.2.2 (and the OR preceding it)

LCO 3.7.13 Format the Applicability with an indented second line. This format aligns with the Writers Guide for LCO Applicabilities.

Applicability LCO 3.9.3 Add SR 3.9.3.1 Perform a CHANNEL CHECK with a 12 SR 3.9.3.1, Perform CHANNEL CHECK was included in NUREG-2194 Surveillance hour frequency, and renumber current SR 3.9.3.1 to SR Revision 0 (refer to ML16111A220) and remains included in VEGP Unit 3 TS 3.9.3.2 3.9.3. While VEGP Unit 3 Amendment 168 (ML19297C791) removed many CHANNEL CHECK Surveillances, the CHANNEL CHECK was retained for Source Range Neutron Flux monitors.

Figure 4.3-1 Include Figure 4.3-1. Figure 4.3-1 is referenced in TS 4.3.1.1.f and 4.3.1.1.g. NUREG-2194, Revision 0 included Figure 4.3-1 (refer to ML16111A239), as does current VEGP Unit 3 TS.

TS 5.1.1 Correct indentation of 2nd paragraph This is a format correction.

TS 5.2.2.b Reference to 5.2.2.f to be revised to 5.2.2.e In NUREG-2194 Revision 0, TS 5.5.2.d was deleted and 5.2.2.f renumbered to 5.2.2.e (see ML16111A242); however, the 5.5.2.b reference was not updated.

TS 5.5.4 and Consider revising TS 5.5.4 to reflect changes from NUREG-2194 Revision 0 incorporated TSTF-510. Since then, TSTF-577 has TSTF-577 TSTF-577 proposed additional changes to TS 5.5.4, Steam Generator (SG) Program.

TSTF-577 is showing approved for all PWROGs, but not for AP1000. VEGP has a future plan to evaluate these TSTFs for adoption.

TS 5.5.12.c Regulatory Guide 1.197 should be cited as Revision 0 Draft TS 5.5.12.c cites Regulatory Guide 1.197 as Revision 1; however, currently the issued revision is still Revision 0.

Southern Nuclear Operating Company ND-22-0831 Attachment 2 NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 1 of 22 Item Comment Justification General Consider removing editorial and/or Many Technical Specification (TS) Bases (TSB) changes from NUREG-2194 presentation preference changes made to Revision 0 appear to be editorial and/or presentation preference type changes.

NUREG-2194 Revision 0 as shown in draft Since there was no markup of the NUREG showing the changes, it was difficult to NUREG-2194 Revision 1. identify and evaluate each and every change. Furthermore, there are no discussions or justifications provided for changes, so evaluating the appropriateness of the change is also difficult in many cases. A number of these changes depart from other Standard Technical Specification (STS) NUREGs (e.g.,

NUREG-1431) and from Vogtle Electric Generating Plant (VEGP) Unit 3.

For example, NUREG-2194 Volume 2 (TSB) Revision 1 has removed at least from the discussions of Actions that refer to a required shutdown to at least MODE ... . This phrase continues to be found in all STS NUREGs as well as VEGP Unit 3 TSB.

This kind of disconnect will lead to future work to justify differences when proposing to incorporate approved TSTF changes where these differences arise.

Various Delete numerous blank pages throughout Blank pages provide a misleading suggesting that there is an intended format to Volume 2. include blank pages.

B 2.1.1 (p. 2) APPLICABLE Items a and b: Revise hot to hottest Editorial correction. Intent is hottest and not just any hot fuel rod or fuel pellet SAFETY ANALYSES B 2.1.1 (p. 2) SAFETY Items a and b: Revise hot to hottest Editorial correction. Intent is hottest and not just any hot fuel rod or fuel pellet LIMITS B 3.0 (p. 6) LCO 3.0.5 Incorporate changes from TSTF-529 In most cases NUREG-2194 draft Revision 1 has incorporated TSTF-529 (as applicable to AP1000 (even though the TSTF was not applicable to AP1000 at the time of approval). It is likely that the LCO 3.0.5 Bases changes were overlooked.

B 3.1.4 (p. 7) Delete but from the first sentence in the Editorial correction. The word but was inappropriately added to read, Power second paragraph operation may continue with one control rod but misaligned, B.3.1.1. and B.3.1.2 B 3.1.4 (p. 7) Revise Action B Bases to align with If Attachment 1 comment is not incorporated, the Bases require (1) Additional comment in Attachment 1 for LCO 3.1.4 Bases for Required Action B.1.1 including basis for the Completion Time, and ACTIONS for Required Action B.x series (2) editorial corrections to the header for the B.x series; the spaces and periods in this heading need to be corrected to read, B.3.2, B.3.3.1, B.3.3.2.1, B.3.3.2.2, B.3.3.2.3, and B.3.4.

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 2 of 22 Item Comment Justification B 3.1.4 (p. 7) Revise third paragraph, 1st sentence to These changes were added in VEGP Unit 3 TS Bases Revision 48 as a clarification read: SDM and core margin to thermal to include that misaligned rods have a potential to impact core margin to thermal B.3.2, B.3.3.1, limits. limits as well as shutdown margin.

Revise third paragraph, 2nd sentence to read, verification of SDM these parameters is required.

B 3.1.4 (p. 8) Revise the first sentence under C.1 to Clarification change for consistency. LCO 3.1.4 Condition C states, "Required read, When Required Actions for a single Action and associated Completion Time of Condition B not met." Condition B C.1 misaligned control rod cannot be states, "One rod not within alignment limits." The change makes it clear Required completed Action C.1 involves a single rod misaligned. This change was made in VEGP Unit 3 TS Bases Revision 48 B 3.1.4 (p. 9) Revise the first paragraph, third sentence Editorial correction. The word or was added to the NUREG, so that the sentence by deleting the word or after does not make grammatical sense. The first or should be deleted as follows:

D.2 misalignment. Since automatic bank sequencing could continue to cause misalignment, or the unit must be brought to a MODE or Condition in which the LCO requirements are not applicable.

B 3.1.4 (p. 10) SR 3.1.4.3 In the last sentence of the first paragraph, Editorial correction. The Surveillance being addressed is SR 3.1.4.3 and reference replace 3.1.4.2 to 3.1.4.3. to SR 3.1.4.2 is not an appropriate basis for the requirements of SR 3.1.4.3. VEGP Unit 3 TS Bases Revision 32 made the correct changes to this sentence.

B 3.1.5 (p. 1) Third paragraph rod cluster control Control banks consist of both RCCAs and gray rod cluster assemblies (GRCAs),

BACKGROUND assemblies (RCCAs) to be replaced with therefore the reference to RCCAs is not correct. VEGP Unit 3 TS Bases Revision control rods 48 made this correction.

B 3.1.6 (p. 3) APPLICABLE At the end of the first paragraph, add the This sentence provides additional detail on the role of LCO 3.1.6 limits in the event SAFETY ANALYSES following sentence: OPDMS is not monitoring SDM. This detail was added in VEGP Unit 3 TS Bases Revision 48.

"In addition, when the OPDMS is not monitoring parameters, the applicable control bank insertion limits are required to maintain SHUTDOWN MARGIN."

B 3.1.9 (p. 1) Define the abbreviation AOO at the end Editorial change to define abbreviations/acronyms when first used. (VEGP Unit 3 of the first paragraph, as anticipated TS Bases Revision 70 made this change)

APPLICABLE SAFETY operational occurrence (AOO).

ANALYSES

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 3 of 22 Item Comment Justification B 3.1.9 (p. 2) Add the following sentence after the first DCD GTS LCO 3.4.17, Chemical and Volume Control System (CVS) Makeup sentence in the LCO section: Isolation Valves, was combined with LCO 3.1.9, Chemical and Volume Control LCO System (CVS) Demineralized Water Isolation Valves and Makeup Line Isolation The requirement that at least two CVS Valves in NUREG-2194 Revision 0. LCO 3.4.17 required CVS Makeup Valve makeup isolation valves (CVS-PL-V090 operability to protect from overfill, while LCO 3.1.9 required operability to protect and V091) be OPERABLE also assures from boron dilution events. However, when combining applicable Bases from LCO that there will be redundant means 3.4.17 the appropriate LCO Bases were inadvertently not updated. The change available to terminate CVS makeup to adds the appropriate LCO Bases discussion of CVS makeup isolation valves the RCS during a non-LOCA event or a operability requirement to terminate CVS makeup to the RCS during a non-LOCA steam generator tube rupture accident event or a steam generator tube rupture accident to provide protection from should that become necessary to overfilling the pressurizer or steam generator. (VEGP Unit 3 TS Bases Revision 70 provide protection from overfilling the made this change) pressurizer or steam generator.

B 3.1.9 (p. 2) In the first paragraph, second and third Editorial / grammatical changes. (VEGP Unit 3 TS Bases Revision 70 made these sentences, delete also (2 places). changes)

APPLICABILITY In the fourth sentence, change In the to read, In these The pressurizer overfill event is also possible in MODES 1, 2, and 3, and MODE 4 with all four cold leg temperatures > 275°F. The steam generator tube rupture (SGTR) event is also possible in MODES 1, 2, and 3, and in MODE 4 at an RCS temperature 350°F. In MODE 4 with an RCS temperature < 350°F and MODES 5 and 6, the RCS pressure and temperature are reduced and an SGTR is not credible. In these applicable MODES,

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 4 of 22 Item Comment Justification B 3.1.9 (p. 2) Relocate the following text from the Editorial change to improve reader understanding. (VEGP Unit 3 TS Bases second and third paragraphs to the first Revision 70 made these changes)

APPLICABILITY paragraph after the current first sentence.

Start a new second paragraph beginning with the current second sentence in the APPLICABILITY section:

In MODES 1 and 2, the detection and mitigation of a boron dilution event does not assume the detection of the event by the source range instrumentation. In these MODES, the event would be signaled by an intermediate range trip, a trip on the Power Range Neutron Flux -High (low setpoint nominally at 25% RTP), or Overtemperature delta T. The two demineralized water isolation valves close automatically upon reactor trip.

In MODE 6, a dilution event is precluded by the requirement in LCO 3.9.2 to close, lock and secure at least one valve in each unborated water source flow path.

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 5 of 22 Item Comment Justification B 3.1.9 (p. 3) Change the first sentence from: Editorial change to improve reader understanding and more accurately reflect the TS requirements. (VEGP Unit 3 TS Bases Revision 70 made these changes)

ACTIONS A.1 If only one of the demineralized water isolation valve and/or the makeup line isolation valve is/are OPERABLE, the redundant valve must be restored to OPERABLE status in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

To read:

If only one demineralized water isolation valve and/or only one makeup line isolation valve are/is OPERABLE, the redundant valve(s) must be restored to OPERABLE status in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Also, change the second sentence by adding and/or RCS makeup after clean water source.

B 3.2.1 (p. 3) Change the second sentence in the fourth FM/Q(Z) is defined as the measured value of the heat flux hot channel factor FQ(Z).

paragraph by replacing F(Z) with FM/Q(Z) NUREG-2194, Rev. 0, correctly used FM/Q(Z) in this. F(Z) is not a defined term.

LCO B 3.2.2 (p. 6) Change the first paragraph (2 places) for This discussion refers to the incore detector system providing a flux distribution SR 3.2.2.1 and SR 3.2.2.2 by replacing map. The incore detector system provides data, which then could be used to SURVEILLANCE flux distribution map with data. create a flux distribution map. (VEGP Unit 3 TS Bases Revision 48 made these REQUIREMENTS changes)

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 6 of 22 Item Comment Justification B 3.2.3 (p. 7) Change the first and second sentences in The surveillance requirement is to Determine, by measurement, the target flux the first paragraph for SR 3.2.3.3 by difference. A flux map is the product that is created from the power distribution SURVEILLANCE replacing text referring to a flux map with measurement. (VEGP Unit 3 TS Bases Revision 48 made these changes)

REQUIREMENTS text referring to the measurements that are taken, as follows:

Measurement of the target flux difference is accomplished by taking a flux map when the core is determined from an incore power distribution measurement at, or very near equilibrium xenon conditions, preferably at high power levels with the control banks at a reference position. This flux map power distribution measurement provides the equilibrium xenon axial power distribution from which the target value can be determined.

B 3.2.4 (p. 2) In the last sentence, change F to FNH. Editorial correction. FNH is defined as the ratio of the integral of the linear power along the fuel rod with the highest integrated power to the average integrated fuel LCO rod power. NUREG-2194, Rev. 0, correctly used FN/H(Z) in this occurrence.

B 3.2.5 (p. 4) In the first paragraph after the lettered The units for linear heat rate is kW/ft. Because this sentence is discussing the bullets, change kW/ft to linear heat rate. parameter, in this context it would be more appropriate to use the term linear heat APPLICABLE SAFETY rate. (VEGP Unit 3 TS Bases Revision 48 made these changes)

ANALYSES B 3.2.5 (p. 5) In the second sentence in last paragraph Editorial clarification.

for LCO, add any of before the three LCO parameters.

B 3.2.5 (p. 5) First paragraph, second sentence: Add Editorial correction.

space between 1 and with.

APPLICABILITY

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 7 of 22 Item Comment Justification B 3.2.5 (p. 7) Revise the third sentence to include or This is an editorial correction to provide consistency with the first sentence in this SDM after the parenthetical, as follows: paragraph, which includes SDM as one of the OPDMS monitoring parameters.

SURVEILLANCE (VEGP Unit 3 TS Bases Revision 48 made these changes)

REQUIREMENTS The first alarm provides a warning before these parameters (peak linear heat rate, FN/H, and DNBR) or SDM exceed their limits.

B 3.3.1 (p. 28,31,33) Relocate the lead in sentence (below) The lead-in for the Surveillance Requirements Bases for TS 3.3.1, 3.3.2, and 3.3.3 B 3.3.2 (p. 5) regarding CHANNEL CALIBRATION from contain an informational sentence for the CHANNEL CALIBRATION. This is an B 3.3.3 (p. 4,5) p. B 3.3.1-28, p. B 3.3.2-5, p. B 3.3.3-4 to inappropriate location; it should be included with the associated CHANNEL the end of the first paragraph for each CALIBRATION SR Bases. (VEGP Unit 3 TS Bases Revision 70 made these SURVEILLANCE individual SR discussion of CHANNEL changes)

REQUIREMENTS CALIBRATION for the following SRs:

SR 3.3.1.5 SR 3.3.1.5 (p. 3.3.1-31); SR 3.3.1.6 SR 3.3.1.6 (p. 3.3.1-33); SR 3.3.2.2 (p. 3.3.2-5); and SR 3.3.2.2 SR 3.3.3.2 (p. 3.3.3.5).

SR 3.3.3.2 The CHANNEL CALIBRATION is performed in a manner that is consistent with the assumptions used in analytically calculating the required channel accuracies.

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 8 of 22 Item Comment Justification B 3.3.1 (p. 28,34,36) Delete the final two sentences in the lead The lead-in for the Surveillance Requirements Bases for TS 3.3.1, 3.3.2, and 3.3.3 B 3.3.2 (p. 5,6,7) in regarding Surveillance Requirement contain two informational sentences related to response time testing. This is an B 3.3.3 (p. 4,6,7) response time testing for the SR Bases for inappropriate location; the topic should be included with the associated response B 3.3.4 (p. 4,5) TS 3.3.1, TS 3.3.2, and TS 3.3.3. time testing SR Bases.

B 3.3.8 (p. 63-65)

Revise individual SR Bases listed to Removal of SR 3.3.1.8 references to, and discussion of use of, WCAP-13632-P-A B 3.3.10 (p. 6,7) remove references to, and discussion of and WCAP-13787 is made since the sensors used in the AP1000 design are not B 3.3.11 (p. 3,4) use of, WCAP-13632-P-A and WCAP- included in the scope of these WCAPs, and therefore, not appropriate for reference B 3.3.13 (p. 6,7) 13787. in the Bases.

B 3.3.14 (p. 5,6)

For individual response time testing SR

  • For NRC accepted applications for allocated values reference to the approval is SURVEILLANCE Bases listed (except as noted with (*)), appropriate (similar to the intent of the current WCAP references).

REQUIREMENTS edits are made as shown in VEGP Unit 3 SR 3.3.1.8 TS Bases Revision 70 for the following:

  • References to response times being measured are revised to verified SR 3.3.2.3 (*) consistent with the allowance for some response times to be based on SR 3.3.3.3 (*)
  • Add new Reference citation following allocations SR 3.3.4.1 allocated values where the new Reference is:
  • References to summation of response times are removed since summations SR 3.3.8.3 are not required if the channel is allotted specific response time limits whose sum SR 3.3.10.2 Safety Evaluation by the Office of meets the channel response time requirement. If each individual portion of the SR 3.3.11.2 Nuclear Reactor Regulation related to channel meets its allotment, the total channel response time will also meet its SR 3.3.13.2 Amendment Nos. 168 and 166 to the limit SR 3.3.14.2 Combined License Nos. NPF-91 and NPF-92, respectively, Vogtle Electric
  • Bases references to allocated response times, are revised to include the modifier REFERENCES of where approved consistent with the existing statement in TS Bases for Generating Plant Units 3 and 4, Docket Nos.52-025 and 52-026, SR 3.3.4.1 and the requirement that such allocations must be previously dated November 21, 2019 approved.

[ML19297C988 (Proprietary) and These changes are made for consistency and to improve reader understanding.

ML19297D159 (non-proprietary)]

(VEGP Unit 3 TS Bases Revision 70 made these changes based on Safety

  • References to response times being Evaluation by the Office of Nuclear Reactor Regulation related to Amendment Nos.

measured are revised to verified. 168 and 166 to the Combined License Nos. NPF-91 and NPF-92, respectively,

  • References to summation of response Vogtle Electric Generating Plant Units 3 and 4, Docket Nos.52-025 and 52-026, times is removed. dated November 21, 2019 [ML19297C988 (Proprietary) and ML19297D159 (non-
  • References to allocated response proprietary)].)

times are revised to include the modifier where approved.

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 9 of 22 Item Comment Justification B 3.3.1 (p. 35) SR 3.3.1.8 Insert paragraph prior to paragraph The change is consistent with UFSAR Subsection 15.1.6.1 and the definition of beginning Each division response...: RTS RESPONSE TIME in the TS. (VEGP Unit 3 Bases Revision 43 made this change)

The Passive Residual Heat Removal (PRHR) Actuation Function RTS RESPONSE TIME is the time interval between input of a PRHR discharge valve not-fully-closed position feedback signal and the loss of gripper coil voltage. The RTS RESPONSE TIME for the PRHR actuation does not include testing actuation of the discharge valves by ESFAS instrumentation signals because it cannot be tested if an ESFAS function (e.g., CMT Actuation) has already caused a reactor trip.

B 3.3.6 (p. 2) ACTIONS In C.1, remove the duplicated phrase nor Edit to avoid duplication will it cause the protective function B 3.3.7 (p. 1) APPLICABLE For Function 1 revise Figure 7.1-7 The circuit breaker arrangement is shown in DCD (i.e., FSAR) Figure 7.2-1.

SAFETY ANALYSES reference to Figure 7.2-1 There is no Figure 7.1-7.

B 3.3.8 (p. 53) ASA, LCO, Last paragraph of Function 24, second Editorial change to correct grammar.

and APPLICABILITY sentence, add verb are between Additionally, these channels and required B 3.3.8 (p. 14) ASA, LCO, First paragraph after the bullets, add or Editorial change to correct grammar. This change will restore wording to match and APPLICABILITY to read to energize or de-energize or NUREG-2194 Revision 0 and VEGP Unit 3 Bases open or close contacts.

B 3.3.8 (p. 17) ASA, LCO, First paragraph after the bullets, add and Editorial change to correct grammar.

and APPLICABILITY between Low - 2 and Feedwater isolation signals.

B 3.3.8 (p. 40) ASA, LCO, Last paragraph for Function 7, RCS Change to match TS Function 7 Mode 5 Applicability and APPLICABILITY VENTED should be RCS not VENTED

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 10 of 22 Item Comment Justification B 3.3.8 (p. 62) SR 3.3.8.2 Second sentence, add and the IPC after This phrase is appropriate and was consistently applied for all ESFAS CHANNEL including the sensor CALIBRATION SRs in NUREG-2194 Revision 0 (i.e., what are currently SRs 3.3.10.1, 3.3.11.1, 3.3.13.1, and 3.3.14.1).

B 3.3.9 (p. 3) APPLICABLE Delete valve[s] in phrase CMT valve[s] CMT Valve Actuation and actuation of the CMT valves is not the name of the SAFETY ANALYSES (3 places) function and is only found in these three locations. CMT Actuation is used throughout TS, TS Bases and DCD. These deletions were made in VEGP Unit 3 TS Bases Revision 43.

B 3.3.9 (p. 8) APPLICABLE Function 13 first sentence delete definition PXS acronym was defined earlier in Function 12 (same page).

SAFETY ANALYSES of acronym PXS.

B 3.3.9 (p. 9) APPLICABLE Function 14 third paragraph second line The TS Applicability for MODE 4 is with the RCS cooling not being provided by the SAFETY ANALYSES insert with the RCS cooling not being RNS. These TS Bases were correct in NUREG-2194, Revision 0, however, draft provided by the RNS after and in MODE Revision 1 omits this phrase leaving a disconnect with the actual requirement.

4. Begin a new sentence with, In MODE 4 with an RCS temperature B 3.3.9 (p. 12) ACTIONS Actions G.1 and G.2 first sentence replace VEGP Unit 3 Amendment 118 (ML18075A094 - Cover Letter) revised the Applicability for Function 2 MODE 5, which is shown in NUREG-2194 draft Revision or for one or both of Functions 2 and 9
1. TS Bases changes are required to align with the TS requirement.

in MODE 5 with the RCS pressure boundary intact The change from Mode 4 to MODE 4 to present the defined term MODE in all capital letters.

with

..., Function 2 in MODE 5 with the RCS not VENTED, or and Function 9 in MODE 5 with the RCS pressure boundary intact Also, in the same sentence, change Mode 4 to MODE 4.

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 11 of 22 Item Comment Justification B 3.3.9 (p. 12) APPLICABLE Actions H.1 and H.2 first sentence replace VEGP Unit 3 Amendment 118 (ML18075A094 - Cover Letter) revised the SAFETY ANALYSES Applicability for Function 6 MODE 5, which is shown in NUREG-2194 draft Revision Function 6 in MODE 5 with RCS
1. TS Bases changes are required to align with the TS requirement.

pressure boundary intact and with pressurizer level 20%

with Function 6 in MODE 5 with the RCS not VENTED B 3.3.9 (p. 13) APPLICABLE Actions J.1, J.2, and J.3 first sentence The TS for Functions 12 and 13 also apply Action J for MODE 5. This is not SAFETY ANALYSES replace Function 1 in MODE 5 with discussed in the Bases. TS Bases changes are required to align with the TS Functions 1, 12, and 13 in MODE 5 requirement.

B 3.3.9 (p. 13) ACTIONS Actions J.1, J.3, and J.3: Revise 6.0 This change aligns with TS changes made in VEGP Unit 3 Amendment 126 MWt to 7.0 MWt (ML18100A069), which is also shown in NUREG-2194 draft Revision 1. TS Bases changes are required to align with the TS requirement.

B 3.3.9 (p. 14) ACTIONS Action K.1 and K.2: Revise 6.0 MWt to This change aligns with TS changes made in VEGP Unit 3 Amendment 126 7.0 MWt (ML18100A069), which is also shown in NUREG-2194 draft Revision 1. TS Bases changes are required to align with the TS requirement.

B 3.3.12, (p. 3) ACTIONS EDIT - Second paragraph is odd font, and Editorial suggestions B.1, B.2 and B.3 fourth sentence separate B.1 from is.

B 3.3.13 (p. 3) ACTIONS Second paragraph revise first TS 3.3.13 Required Action B.2 requires controls to be verified functional. Bases B.1 and B.2 OPERABLE to functional revised to align with the TS. (VEGP Unit 3 TS Bases Revision 70 made this change)

B 3.3.13 (p. 6) SR 3.3.13.1 Second sentence, add and the IPC after This phrase is appropriate and was consistently applied for all ESFAS CHANNEL including the sensor CALIBRATION SRs in NUREG-2194 Revision 0 (i.e., what are currently SRs 3.3.10.1, 3.3.11.1, 3.3.13.1, and3.3.14.1).

B 3.3.16 (p. 2) Revise LCO 3.3.13 title in last paragraph Change aligns the title with that in TS LCO 3.3.13. This title was revised in VEGP ASA LCO and of item a and last paragraph of item b Unit 3 Amendment No. 123 [ML18085A620].

APPLICABILITY to Engineered Safety Feature Actuation System (ESFAS) Main Control Room Isolation, Air Supply Initiation, and Electrical Load De-energization

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 12 of 22 Item Comment Justification B 3.3.16 (p. 5) SR 3.3.16.2 In last sentence, delete above the P-12 This criterion is not consistent with the described TS Note for MODE 6.

(Pressurizer Level) interlock B 3.3.17 (p. 1) Add at the end of third paragraph: The lead-in The two OPERABLE channels must be from PMS Divisions B and C, BACKGROUND is clarifying design information. This change was made in VEGP Unit 3 TS Bases The two OPERABLE channels must be Revision 3.

from PMS Divisions B and C, except for valves and electrical breakers powered The remainder of the addition further clarifies the design. This change was made in from the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> battery supplies of the VEGP Unit 3 TS Bases Revision 33.

Class 1E dc and uninterruptible power supply system. Once the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> battery supply associated with the actuation signal for these valves and electrical breakers has been exhausted, remote capability for changing the position of these components is lost, and there is no need for further position monitoring B 3.3.17 (p. 3) LCO For Function 5 combine and edit first two These changes clarify the design. These changes were made in VEGP Unit 3 TS sentences to read: Bases Revision 33.

RCS Subcooling is calculated from core exit temperature and RCS wide range pressure. from pressurizer pressure and RCS hot leg temperature. The RCS Subcooling is provided for verification of core cooling Function 5 also delete last sentence:

Inputs to the RCS Subcooling are pressurizer pressure and RCS hot leg temperature.

B 3.3.17 (p. 4) LCO For Function 10 add last sentence: This change clarifies the design. This change was made in VEGP Unit 3 TS Bases Revision 33.

The pressurizer instruments for RCS wide range pressure and pressurizer pressure also provide input to compensate the level signal.

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 13 of 22 Item Comment Justification B 3.3.17 (p. 4) LCO For Function 11 add and downspouts to This change was approved in association with VEGP Unit 3 Amendment No. 72 the end of the first paragraph.

B 3.3.17 (p. 5) LCO For Function 12 second paragraph is The position indicators on the PRHR HX inlet isolation valve and the PRHR control replaced with: valves are used as diverse variables to determine whether there is flow through the PRHR HX. This change was approved in VEGP Unit 3 Amendment No. 162 Alternatively, two channels of not closed

[ML19133A167]. (VEGP Unit 3 made this change in Bases Revision 52) position indication for the PRHR HX control valves are also provided to monitor primary system heat removal during accident conditions when the steam generators are not available.

These two channels, along with the confirmation that the PRHR HX inlet isolation valve is open per SR 3.5.4.2, are sufficient to verify that PRHR heat removal is fulfilled.

The PRHR HX control valves are redundant to each other; they are located in parallel flow paths and only one valve is required to open to satisfy the heat sink function.

Note also that the flow channels and valve position channels cannot be mixed..

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 14 of 22 Item Comment Justification B 3.3.17 (p. 6) LCO For Function 17 third and fourth sentences These changes clarify the design. These changes were made in VEGP Unit 3 TS revised to read: Bases Revision 33.

The PCS flow instrument on the lowest standpipe, which is also an input to the summation representing total PCS flow, provides a diverse indication of the PCS heat removal capability. The lowest standpipe indication can be used to satisfy one of the two required channels when the PCS level channel in the same electrical division is inoperable.

For Function 17 add last sentence:

When available, the flow from the other three standpipes is combined with the lowest standpipe to provide a total flow measurement.

B 3.3.17 (p. 7) LCO For Function 19 revised to read: Additional clarity and design detail changes to indicate the use of the external stem mounted limit switch (position indicator) on the valve located inside containment, The position of the two motor-operated and the internal limit switch on the valve located outside containment, to satisfy the valves in the line from the IRWST to the 2-channel requirement. Additionally, clarify that the position of the motor-operated RNS pump suction header is monitored valves is monitored to verify that the flow path is isolated following postulated to verify that the valve is closed flow events. (This clarification was made in VEGP Unit 3 Bases Revision 52) path is isolated following postulated events. The valve must be closed flow path must be isolated to prevent loss of IRWST inventory into the RNS. Valve position indication is provided from the external stem-mounted limit switch on the motor-operated valve in the line from the IRWST to the RNS pump suction header located inside reactor containment. Valve position indication is provided from the internal limit switch on the motor-operated valve in the line from the IRWST to the RNS pump suction header located outside reactor containment.

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 15 of 22 Item Comment Justification B 3.3.17 (p. 10) SR 3.3.17.2 Replace LCO 3.3.1, Reactor Trip System TS Function 1 is for the Intermediate Range function, which is addressed in (RTS) Instrumentation with LCO 3.3.3, LCO 3.3.3 (and not LCO 3.3.1). This correction was made in VEGP Unit 3 TS "Reactor Trip System (RTS) Intermediate Bases Revision 33.

Range B 3.3.19 (p. 1,4) Remove Background first sentence Reference 1 is FSAR Chapter 19. Note that the AP1000 PRA and FSAR Chapter BACKGROUND, citation (Ref. 1) 19 are not the same document. FSAR Chapter 19 only provides a description and REFERENCES summary of results. It is not the same level of detail as the PRA documentation, Delete Reference 1 which is the focus of the Background first sentence.

Renumber remaining References B 3.4.4 (p. 2) APPLICABLE Delete sentence in second paragraph: The Power Range High Neutron Flux - High Setpoint trip being discussed in this SAFETY ANALYSIS sentence does not provide adequate reactor protection so that the acceptance limit The value for the accident analysis of 118% RTP is not exceeded, as discussed in the NRC Safety Evaluation for setpoint of the nuclear overpower (high flux) trip is 118% and is based on an VEGP Unit 3 License Amendment No. 144. (VEGP Unit 3 TS Bases Revision 36 analysis assumption that bounds reflected this deletion) possible instrumentation errors.

B 3.4.4 (p. 2) APPLICABLE MODES 3, 4, and 5 second sentence VEGP Unit 3 License Amendment No. 13 revised the Applicability for both SAFETY ANALYSIS delete ending with the breakers closed or TS 3.4.4 and TS 3.4.8 to remove a distinction between reactor trip breakers being open open or closed. The deleted phrase in the Bases for 3.4.4 was inadvertently not deleted when implementing that Amendment. (VEGP Unit 3 Bases were later updated with this change in Revision 3)

B 3.4.7 (p. 5) SR 3.4.7.1 Delete last two paragraphs on page 5: The first paragraph reflects the Applicability details in another TS, i.e., TS 3.4.9 Applicability Note 2, and is therefore removed from TS 3.4.7 Bases.

The containment atmosphere F18 particulate radioactivity LEAKAGE The second paragraph is not consistent with the Applicability of TS 3.4.9 (governing measurement is valid only for plant the operability of the containment sump level instruments). Furthermore, analyses power > 20% RTP. have shown that frost is not expected to form on the inside of the containment vessel. Therefore, this statement is irrelevant and removed.

The containment sump level change method of detecting leaks during MODES 1, 2, 3, and 4 is not valid during extremely cold outside ambient conditions when frost is forming in the interior of the containment vessel.

B 3.4.7 (p. 6) References Revise Regulatory Guide 1.45 from AP1000 design is per Revision 0, and May 1973 is the date for Revision 0.

Revision 1 to Revision 0

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 16 of 22 Item Comment Justification B 3.4.9 (p. 7) References Revise Regulatory Guide 1.45 from AP1000 design is per Revision 0.

Revision 1, May 2008 to Revision 0, May 1973 B 3.4.11 (p. 2) In 4th paragraph, revise 40 and 100 to 48 This reflects design changes consistent with VEGP Unit 3 Amendment No. 176 BACKGROUND and 120 [ML20049A655].

B 3.4.11 (p. 5) SR 3.4.11.2 Delete (Ref. 4) The SR 3.4.11.2 referenced Inservice Testing Program is not the same document as the description of testing in UFSAR Section 3.9.6 (i.e., Ref. 4). Furthermore, the sentence is describing the TS Frequency, which does not contain a Reference.

B 3.4.11 (p. 5) SR 3.4.11.3 Revise second paragraph to replace ISTC The correct ASME Code reference is provided. (VEGP Unit 3 made this change in 4.6, Inservice Tests for Category D Bases Revision 59)

Explosively Actuated Valves with ITSC-5260 and delete third sentence.

B 3.4.11 (p. 6) SR 3.4.11.4 Delete from second sentence ESFAS VEGP Unit 3 Amendment No. 168 [ML19297C791] removed ESFAS Actuation ACTUATION LOGIC OUTPUT TEST and Logic Output Testing requirements. (VEGP Unit 3 made these changes in Bases Revision 56)

B 3.4.11 (p. 6) SR 3.4.11.5 Insert following first sentence VEGP Unit 3 Amendment No. 168 [ML19297C791] removed ESFAS Actuation Logic Output Testing requirements. (VEGP Unit 3 made these changes in Bases The actual or simulated signal is Revision 56) processed through the component interface module to verify the continuity between the output of the component interface module and the valves. The ADS and IRWST injection blocking device ACTUATION LOGIC TEST provides overlap with this Surveillance.

B 3.4.11 (p. 7) Revise Reference 3 to AP1000 The Background (p. 2) cites Reference 3 for The PRA Note that the AP1000 REFERENCES Probabilistic Risk Assessment. PRA and FSAR Chapter 19 are not the same document. FSAR Chapter 19 only provides a description and summary of results. It is not the same level of detail as the PRA documentation.

B 3.4.12 (p. 3) ACTIONS Add required prior to flow path(s) in The modifier required is needed to align with the TS requirements presented in each of RA B.1, RA C.1 and RA D.1. Conditions B, C, and D. Not all ADS valves are required under all APPLICABILITY situations. This is consistent with changes approved in VEGP Unit 3 Amendment No. 118 (ML18075A094 - Cover Letter).

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 17 of 22 Item Comment Justification B3.4.12 (p. 3) ACTIONS Move the first paragraph of D.1 to be the Since Action C could involve three or more inoperable flow paths, the clarification is last paragraph of C.1. appropriate for the C.1 Bases. This is consistent with the changes shown in the request approved in VEGP Unit 3 Amendment No. 118 (ML18075A094 - Cover Letter). (VEGP Unit 3 made these changes in Bases Revision 23)

B 3.4.14 (p. 3) APPLICABLE Add the following in the ASA under the Omitted text makes the statement incorrect, now indicating that the smaller RNS SAFETY ANALYSES RNS Suction Relief Valve Performance, suction relief valve will remain closed when in fact, it would lift and the larger valve next to last sentence: will lift at its lift will remain closed.

setting and the larger RNS suction relief valve B 3.4.14 (p. 4) APPLICABLE Revise The required vent area may be Reference to opening Stage 4 squib valve is not a practical option. (VEGP SAFETY ANALYSES obtained by opening one ADS Stage 2, 3, removed reference to ADS Stage 4 in Bases Revision 39).

or 4 flow path to reference one ADS Stage 1, 2, or 3 flow path. (i.e., delete reference to Stage 4)

B 3.4.14 (p. 5) LCO Add OPERABLE to b header prior to The change provides consistency with the heading for a matching the TS RCS vent requirement to be operable.

B 3.4.14 (p. 9) SR 3.4.14.5 Delete This Surveillance is only required Duplicates final sentence of the paragraph to be performed if the RNS suction relief valves are being used to meet this LCO.

B 3.4.15 (p. 2) Revise four to Five in first line of the Revision to include a fifth CVS high pressure/low pressure connection with the RCS BACKGROUND fourth paragraph by adding the zinc supply line to the list of CVS lines that penetrate containment is consistent with changes approved in VEGP Unit 3 Amendment No. 12 Add the zinc supply line, in the fourth

[ML13172A18], which separated the zinc and hydrogen injection lines. (This paragraph, third sentence after hydrogen change was made in VEGP Unit 3 Bases Revision 1) supply line B 3.4.15 (p. 3) LCO Revise last two sentences to read: Change is consistent with the ASME Operations and Maintenance (OM) Code and applicable addenda regarding the need to adjust the measured valve leak rate In such cases, the observed leakage rate based on the ratio of the maximum operating differential pressure to the test at lower differential pressures shall be differential pressure. (This change was made in VEGP Unit 3 in Bases Revision adjusted to the maximum pressure 54) differential assuming leakage is directly proportional to the pressure differential to the one-half power.

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 18 of 22 Item Comment Justification B 3.4.17 (p. 5) ACTIONS For A.1 and A.2 second line, add repair The change aligns with the TS requirement. The AP1000 GTS Bases included between tube and criteria repair. The apparent inadvertent omission occurred in NUREG-2194 Revision 0.

B 3.5.1 (p. 7) References Revise Reference 4 to AP1000 Background (p. 2) cites Reference 4 for The probabilistic risk assessment (PRA).

Probabilistic Risk Assessment. Note that the AP1000 PRA and FSAR Chapter 19 are not the same document.

FSAR Chapter 19 only provides a description and summary of results. It is not the same level of detail as the PRA documentation.

B 3.5.2 (p. 2) APPLICABLE Revise reference to CVS being The use of inoperable is not appropriate for non-TS systems. Since CVS is a SAFETY ANALYSES inoperable to unavailable or insufficient non-TS system the term is revised to unavailable or insufficient. (VEGP Unit 3 TS Bases Revision 70 made this change)

B 3.5.2 (p. 8) References Revise Reference 3 to AP1000 Background (p. 1) cites Reference 3 for The probabilistic risk assessment (PRA).

Probabilistic Risk Assessment. Note that the AP1000 PRA and FSAR Chapter 19 are not the same document.

FSAR Chapter 19 only provides a description and summary of results. It is not the same level of detail as the PRA documentation.

B 3.5.3 (p. 4) SR 3.5.3.1 Revise reference to SR 3.5.2.8 to There is no SR 3.5.2.8. This change is consistent with revisions made in VEGP SR 3.5.2.7 Unit 3 Amendment No. 176 [ML20049A655].

B 3.5.3 (p. 4) References Revise Reference 2 to AP1000 Action D.1 (p. 3) cites Reference 2 for The probabilistic risk assessment (PRA).

Probabilistic Risk Assessment. Note that the AP1000 PRA and FSAR Chapter 19 are not the same document.

FSAR Chapter 19 only provides a description and summary of results. It is not the same level of detail as the PRA documentation.

B 3.5.4 (p. 1) Second paragraph change principle to Grammar appropriately corrected. (VEGP Unit 3 TS Bases Revision 70 made this BACKGROUND principal change)

B 3.5.4 (p. 3) Revise first paragraph MODES 1, 2, 3, Editorial correction APPLICABILITY and in 4 to MODES 1, 2, and 3, and in MODE 4 B 3.5.4 (p. 5) ACTIONS Add missing pumps in first paragraph to Editorial - missing word read Possible means include two main feedwater pumps (with two condensate

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 19 of 22 Item Comment Justification B 3.5.4 (p. 8) References Revise Reference 3 to AP1000 Background (p. 1) cites Reference 3 for The probabilistic risk assessment (PRA).

Probabilistic Risk Assessment. Note that the AP1000 PRA and FSAR Chapter 19 are not the same document.

FSAR Chapter 19 only provides a description and summary of results. It is not the same level of detail as the PRA documentation.

B 3.5.5 (p. 2) Revise third paragraph MODES 1, 2, 3, Editorial correction APPLICABILITY and in 4 to MODES 1, 2, and 3, and in MODE 4 B 3.5.6 (p. 9) References Revise Reference 3 to AP1000 Action D.1 (p. 5) cites Reference 3 for probabilistic risk assessment (PRA) success Probabilistic Risk Assessment criteria. Note that the AP1000 PRA and FSAR Chapter 19 are not the same document. Ch 19 only provides a description and summary of results. It is not the same level of detail as the PRA documentation.

B 3.6.7 (p. 1) First paragraph second sentence move Grammatical clarification and additional design clarification. (VEGP Unit 3 TS BACKGROUND phrase within containment to the end of Bases Revision 70 made these changes) the sentence.

Note that Reference 1 is intended to cite FSAR Chapter 19 (Shutdown Evaluation);

First paragraph add after 3rd sentence and therefore, the NUREG-2194 Reference 1 is an appropriate reference.

move current last sentence to begin second paragraph:

Since there are no unique MODES 5 and 6 containment pressurization response analyses, containment pressurization is assumed to be bounded by the design basis accident containment response. Therefore, containment closure must be capable of maintaining containment isolation at the containment design pressure of 59 psig (Ref. 1) to prevent gross failure of containment opening barriers that would challenge maintaining long-term core cooling water inventory.

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 20 of 22 Item Comment Justification B 3.6.7 (p. 2,7) Revise the Tables 54-1 and 54-4 Tables 54-1 and 54-4 do not exist in Reference 1 (i.e., FSAR Chapter 19). Tables BACKGROUND reference to Reference 1 (in first full 54-1 and 54-4 are in reference to the Generic AP1000 PRA.

REFERENCES paragraph and next to last paragraph) to Reference 2. Add new Reference 2 citing AP1000 PRA and renumber current Reference 2 to Reference 3. Revise Background page 2 second full paragraph (Ref. 2) to (Ref. 3)

B 3.7.3 APPLICABILITY Add APPLICABILITY section APPLICABILITY section (as presented in NUREG-2194, Revision 0) is missing.

B SR 3.7.3.1 (p. 5) Add the following as new second sentence This sentence was added in VEGP Bases Revision 56 during implementation of in the first paragraph: Unit 3 License Amendment No. 168 [ML19297C791] for additional clarification, which is based on the same change acknowledged in the Amendment Safety The actual or simulated signal is Evaluation for TS SRs 3.1.9.3 and 3.6.3.5.

processed through the component interface module to verify the continuity between the output of the component interface module and the valves.

B SR 3.7.3.1 (p. 5) SR 3.7.3.1 Bases last paragraph replaced Paragraph revised to more accurately describe the associated TS SR Note, which with: allows the option to defer testing until entering the TS Applicability and achieving MODE 3 or 4 (i.e., prior to entering Mode 2). Sentence describing consistency with The SR is modified by a note which ASME OM quarterly stroke requirements is misleading since these valves are not states that the SR is only required to be tested quarterly and ASME OM does not directly provide the exception, but allows performed prior to entry into MODE 2.

a utility to justify a cold shutdown exception.

This allows the option to perform testing in MODES 3 or 4. VEGP Unit 3 Bases Revision 59 made these changes.

Also delete last sentence of SR 3.7.3.1 Bases first paragraph ("This is consistent with the ASME OM Code (Ref. 2) quarterly stroke requirements during operation in MODES 1 and 2)

B 3.7.6 (p. 7) Add APPLICABILITY section divider and APPLICABILITY section divider and header is missing for what is now last two APPLICABILITY header paragraphs of LCO Bases.

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 21 of 22 Item Comment Justification B SR 3.7.6.3 (p. 13) Remove , which each require quarterly The NUREG-2194 Revision 1 draft changes mimic changes made by VEGP Unit 3 testing (per UFSAR Table 3.9-16 and Note in Revision 61. However, the text , which each require quarterly testing (per
38) UFSAR Table 3.9-16 and Note 38) is not found in VEGP TS Bases. This UFSAR table has been removed since its purpose was to present a operational information that now resides in the Inservice Testing Program and controlled under 10 CFR 50.55a.

B SR 3.7.6.10 (p. 15) After in accordance with add the FSAR The AP1000 testing has exceptions to this RG as identified in DCD Appendix 1A.

Appendix 1A position for in reference to This clarification was adopted by VEGP Unit 3 in Revision 67.

conformance with Regulatory Guide 1.52.

B 3.7.7 (p. 1) APPLICABLE First paragraph replace ending for a large NUREG-2194 Revision 0 provided an appropriate first paragraph, which matches SAFETY ANALYSES FLB with inside containment. It is also the content of VEGP Unit 3. The draft Revision 1 paragraph is incomplete.

based on the analysis for a large FLB and a steam generator tube rupture.

B 3.7.7 (p. 2) APPLICABLE Delete and control in first and second The control valves are not containment isolation valves. Note that they are not SAFETY ANALYSES paragraph listed in DCD Tier 2 (or VEGP UFSAR) Table 6.2.3-1.

B SR 3.7.7.2 (p. 4) Add the following as new second sentence This sentence was added in VEGP Bases Revision 56 during implementation of in the first paragraph: Unit 3 License Amendment No. 168 [ML19297C791] for additional clarification, which is based on the same change acknowledged in the Amendment Safety The actual or simulated signal is Evaluation for TS SRs 3.1.9.3 and 3.6.3.5.

processed through the component interface module to verify the continuity between the output of the component interface module and the valves.

B 3.7.9 (p. 2) APPLICABLE Next to last paragraph title of LCO 3.6.6 as Inclusion of - Operating does not match TS 3.6.6 title.

SAFETY ANALYSES Passive Containment Cooling System -

Operating delete - Operating B 3.7.10 (p. 1) SGS-PLV233A & B should be Editorial correction of missing hyphen after PL BACKGROUND SGS-PL-V233A & B B 3.7.13 (p. 1) Revise title of LCO in reference to Correct Title BACKGROUND LCO 3.3.14 to ESFAS IRWST and Spent Fuel Pool Level Refueling Cavity and Spent Fuel Pool Cooling System (SFS)

Isolation Instrumentation..

NUREG-2194 Volume 2, Technical Specification Bases (TSB) Comments Page 22 of 22 Item Comment Justification B 3.8.1 (p. 2) Revise last paragraph 2nd sentence as Voltage limits revised consistent with licensing basis and vendor recommendation BACKGROUND follows: for minimum established float voltage. (VEGP Unit 3 TS Bases Revision 68 made these changes)

The battery terminal minimum established float voltage limit is 2.20 2.13 V per cell, which corresponds to a total minimum voltage output of 264 2.56 V per battery B 3.8.3 (p. 2) LCO Revise the paragraph beginning An This change is recommended as the sentence may not contain EVERYTHING it inverter is OPERABLE when to begin takes for the inverter to considered OPERABLE.

OPERABLE inverters require B 3.8.4 (p. 2) LCO The sentence beginning OPERABILITY of This change is not recommended as the sentence may not contain EVERYTHING the inverters requires has been revised it takes for the inverter to considered OPERABLE.

to begin An inverter is OPERABLE when B 3.8.7 (p. 3,4) ACTIONS Move header for Required Actions Last paragraph on page B 3.8.7-3 begins the discussion of Required Actions C.1, C.1, C.2 and C.3 up one paragraph C.2, and C.3. The C.1, C.2 and C.3 header belongs prior to this paragraph.

B 3.9.3 (p. 3) Swap References 1 and 2 Initial fuel loading is addressed in Chapter 14 which is cited as Ref. 1 in the REFERENCES Applicable Safety Analyses (ASA) subsection, and the boron dilution accident is addressed in Chapter 15 which is cited as Ref 2 ASA subsection.

B 3.9.3 (p. 3) SR 3.9.3.1 Add Bases for SR 3.9.3.1 Channel Check Channel Check SR Bases is missing. Refer to Comment on NUREG-2194 Volume 1, Technical Specification, to add SR to TS B 3.9.5 (p. 1) Delete (Ref. 3) in final sentence. There is no Ref. 3 provided in these Bases Reference subsection.

BACKGROUND Alternatively, add new Reference 3 to REFERENCES.

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