Text

License Amendment Request to Adopt TSTF-513-A, Rev. 3, Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation
	ML111220091
Person / Time
Site:	Vogtle, Farley
Issue date:	04/29/2011
From:	Ajluni M; Southern Nuclear Operating Co
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	NL-11-0675
	Download: ML111220091 (62)
	v • d • e

Mark J. Ajluni, P.E.

Southern Nuclear Nuclear Licensing Director Operating Company. Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham. Alabama 35201 Tel 205.992.7673 Fax 205.992.7885 April 29, 2011 SOUTHERN'\\'

COMPANY Docket Nos.: 50-348 50-424 NL-11-0675 50-364 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Vogtle Electric Generating Plant License Amendment Request to Adopt TSTF-513-A Revision 3 Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation Ladies and Gentlemen:

In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Southern Nuclear Operating Company (SNC) is submittillg a request for an amendment to the Technical Specifications (TS) for the Joseph M. Farley Nuclear Plant (FNP) and Vogtle Electric Generating Plant (VEGP).

In accordance with Technical Specification Task Force Traveler TSTF-513-A Revision 3 titled "Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation," the proposed amendment would revise the TS to define a new time limit for restoring inoperable Reactor Coolant System (RCS) leakage detection instrumentation to operable status; establish alternate methods of monitoring RCS leakage when one or more required monitors are inoperable; and make TS Bases changes which reflect the proposed changes and more accurately reflect the contents of the facility design basis related to operability of the RCS leakage detection instrumentation. The availability of this TS improvement was announced in the Federal Register on January 3,2011 (76 FR 189) as part of the consolidated line item improvement process (CUIP). provides the basis for the proposed change to the FNP TS. provides the FNP TS and Bases markup pages showing the proposed changes. Enclosure 3 provides FNP TS and Bases clean typed pages showing the proposed changes. provides the basis for the proposed change to the VEGP TS. provides the VEGP TS and Bases markup pages showing the proposed changes. Enclosure 6 provides VEGP TS and Bases clean typed pages showing the proposed changes.

(Affirmation and signature are provided on the following page)

U. S. Nuclear Regulatory Commission NL-11-0675 Page 2 SNC requests approval of the proposed license amendments by May 3,2012.

The proposed changes would be implemented within 60 days of issuance of the amendments.

In accordance with 10 CFR 50.91 (b)(1), "State Consultation," a copy of this application and its reasoned analysis about no significant hazards considerations is being provided to the designated Alabama and Georgia officials.

Mr. M. J. Ajluni states he is Nuclear Licensing Director of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.

This letter contains no NRC commitments. If you have any questions, please contact Jack Stringfellow at (205) 992-7037.

Respectfully submitted,

~~1-.

M. J. Ajluni Nuclear Licensing Director 1<.j't;!>-

A 0D, Sworn to and subscribed before me this ~ day of f*1 tu l...-

,2011.

.-J~~~~

GLf Notary Public My commission expires: 1[- () 2 -J.t>l~

MJAlCLT/lac

Enclosures:

1. FNP Basis for Proposed Change

2. FNP Technical Specifications and Bases Markup Pages

3. FNP Technical Specifications and Bases Clean Typed Pages

4. VEGP Basis for Proposed Change

5. VEGP Technical Specifications and Bases Markup Pages

6. VEGP Technical Specifications and Bases Clean Typed Pages

U. S. Nuclear Regulatory Commission NL-11-0675 Page 3 cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. M. L. Stinson, Vice President - Farley Mr. T. E. Tynan, Vice President - Vogtle Ms. P. M. Marino, Vice President - Engineering RType: CFA04.054; CVC7000 U. S. Nuclear Regulatory Commission Mr. V.M. McCree, Regional Administrator Mr. R. E. Martin, NRR Project Manager - Farley, Hatch and Vogtle Mr. P. G. Boyle, NRR Project Manager Mr. E. L. Crowe, Senior Resident Inspector - Farley Mr. M. Cain, Senior Resident Inspector - Vogtle Alabama Department of Public Health Dr. D. E. Williamson, State Health Officer State of Georgia Mr. Allen Barnes, Environmental Director Protection Division

Joseph M. Farley Nuclear Plant License Amendment Request to Adopt TSTF-513-A, Revision 3 Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation Basis for Proposed Change to NL-11-0675 April 29, 2011 Basis for Proposed Change Table of Contents 1.0 Description 2.0 Proposed Changes 2.1 Variations from TSTF-513-A

3.0 Background

4.0 Technical Analysis 5.0 Regulatory Safety Analysis 5.1 No Significant Hazards Consideration Determination 5.2 Applicable Regulatory Requirements/Criteria 6.0 Environmental Consideration 7.0 References E1-2 to NL-11-0675 April 29, 2011 Basis for Proposed Change 1.0 Description This evaluation supports a request to amend Appendix A of Operating Licenses NPF-2 and NPF-8 for Joseph M. Farley Nuclear Plant (FNP) Unit 1 and Unit 2, respectively.

The proposed amendment would revise the Technical Specifications (TS) to define a new time limit for restoring inoperable Reactor Coolant System (RCS) leakage detection instrumentation to operable status; establish alternate methods of monitoring RCS leakage when one or more required monitors are inoperable; and make conforming TS Bases changes. These changes are consistent with NRC approved Technical Specification Task Force Traveler TSTF-513-A Revision 3, "Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation." The availability of this TS improvement was announced in the Federal Register on January 3, 2011 (76 FR 189) as part of the consolidated line item improvement process (CUIP).

Southern Nuclear Operating Company (SNC) requests approval of the proposed license amendments by May 3, 2012. The proposed changes would be implemented within 60 days of issuance of the amendments.

2.0 Proposed Changes The proposed changes revise and add a new Condition C for FNP to TS 3.4.15, "RCS Leakage Detection Instrumentation," and revise the associated bases. The proposed new Condition C is applicable when the containment atmosphere gaseous radioactivity monitor is the only operable TS-required monitor (Le., all other monitors are inoperable).

The proposed new Condition C Required Actions require analyzing grab samples of the containment atmosphere every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and restoring another monitor within 7 days.

Additionally, the TS Bases, which summarize the reasons for the specifications, are revised to clarify the specified safety function for each required instrument in the limiting condition for operation (LCO) Bases, delete discussion from the Bases that could be construed to alter the meaning of TS operability requirements, and reflect the changes made to TS 3.4.15.

2.1 Variations from TSTF-513-A SNC is proposing variations from the TS changes described in TSTF-513-A, Revision 3. The proposed variations are necessary to accommodate plant specific design configurations or plant specific TS differences. The proposed variations remain consistent with the intent of TSTF-513-A and do not impact the conclusions in the referenced NRC staff's model SE.

The following variations from the TS changes described in TSTF-513-A, Revision 3, are proposed:

1. The proposed new Condition D being added by TSTF-513-A to TS 3.4.15 was revised to new Condition C for FNP. This variation from TSTF-513-A is due to the plant specific Conditions in FNP TS 3.4.15 which reflect the FNP specific RCS leakage detection instrumentation. The different placement of this new Condition in the FNP TS 3.4.15 is consistent with the intent of TSTF 513-A and minimizes the re-Iettering of subsequent Conditions.

E1-3 to NL-11-0675 April 29, 2011 Basis for Proposed Change

2. The new Condition D proposed by TSTF-513-A for TS 3.4.15 contains a Note to clarify the Condition is only applicable when a containment atmosphere gaseous radiation monitor is the only operable monitor. The proposed corresponding new Condition C for FNP TS 3.4.15 does not include the Note.

This variation from TSTF-513-A is due to the plant specific number of monitors required to be operable in FNP TS 3.4.15. With the two monitors inoperable as identified in the proposed FNP new Condition C, the only other TS required monitor that would be operable is the containment atmosphere gaseous radioactivity monitor. Therefore, no additional clarification (as provided by the TSTF-513-A Note) is necessary for FNP. This approach is consistent with the intent of TSTF-513-A and avoids inclusion of a potentially confusing Note in the FNP TS.

3. As stated in TSTF-513-A, "In several locations in all three NUREGs, the specifications incorrectly refer to a "required" containment sump monitor or "required" containment air cooler flow rate monitor when the LCD does not provide for more than one monitor. The term "required" is reserved for situations in which there are multiple ways to meet the LCD, such as the requirement for either a gaseous or particulate radiation monitor. The incorrect use of the term "required" is removed." In TSTF-513-A the word "required" is deleted from TS 3.4.15 Condition C for an inoperable containment air cooler condensate flow rate monitor. The corresponding FNP TS 3.4.15 Condition B addresses an inoperable containment air cooler condensate level monitor. However, the word "required" is appropriate in the FNP Condition B, as there are multiple ways to meet the FNP LCD requirement. The FNP TS 3.4.15 LCD requirement for the containment air cooler condensate level monitor includes the alternative to use "... one containment atmosphere gaseous radioactivity monitor." Therefore, the word "required" is not deleted from the FNP Condition B and this approach is consistent with the intent of TSTF-513-A.

4. Finally in TSTF-513-A the TS Bases, which summarize the reasons for the specifications, are revised to clarify the specified safety function for each required instrument in the limiting condition for operation (LCD) Bases, delete discussion from the Bases that could be construed to alter the meaning of TS operability requirements, and reflect the changes made to TS 3.4.15. In the corresponding changes to the FNP TS Bases some variations from TSTF-513-A were necessary to reflect the above listed FNP specific TS considerations, the FNP specific ReS leakage detection instrumentation configuration and design bases, and to specifically reflect the FNP specific RCS leakage detection instrumentation sensitivities as documented in the updated FNP Final Safety Analysis Report (FSAR) section 5.2.7. This approach remains consistent with the intent of TSTF-513-A.

E1-4 to NL-11-0675 April 29, 2011 Basis for Proposed Change

3.0 Background

NRC Information Notice (IN) 2005-24, "Nonconservatism in Leakage Detection Sensitivity," dated August 3,2005, informed addressees that the reactor coolant activity assumptions for primary containment atmosphere gaseous radioactivity monitors may be non-conservative. This means the monitors may not be able to detect a one gallon per minute increase within one hour. Some licensees have taken action in response to IN 2005-24 to remove the gaseous radioactivity monitor from the TS list of required monitors. However, industry experience has shown that the primary containment atmosphere gaseous radiation monitor is often the first monitor to indicate an increase in RCS leak rate. As a result, the TSTF and the NRC staff met on April 29, 2008, and April 14, 2009, to develop an alternative approach to address the issue identified in IN 2005-24. The agreed solution is to retain the primary containment atmosphere gaseous radiation monitor in the LCO list of required equipment, revise the specified safety function of the gas monitor to specify the required instrument sensitivity level, revise the Actions to require additional monitoring, and provide less time before a plant shutdown is required when the primary containment atmosphere gaseous radiation monitor is the only operable monitor.

4.0 Technical Analysis SNC has reviewed TSTF-513-A, Revision 3, and the model SE published on January 3, 2011 (76 FR 189) as part of the CLlIP Notice of Availability. SNC has concluded that the technical bases presented in TSTF Traveler-513, Revision 3, and the model SE prepared by the NRC staff are applicable to FNP.

The proposed amendment revises the language in the TS Bases that describes when the gaseous and particulate containment atmosphere radioactivity monitor is operable.

The proposed amendment requires additional containment atmosphere grab samples or manual RCS leakage monitoring to be performed when the primary containment atmosphere gaseous radiation monitor is the only operable continuous or automatic monitor. These alternative methods provide an RCS leakage detection capability similar to the TS-required methods. The containment atmosphere grab sample has an RCS leakage detection capability that is comparable to that of the containment atmosphere particulate radiation monitor. The proposed Actions and Completion Times for grab samples are adequate because the use of frequent grab samples provides additional assurance that any significant RCS leakage will be detected prior to significant reactor coolant pressure boundary (RCPB) degradation.

Compliance with General Design Criterion (GDC) 30, "Quality of Reactor Coolant Pressure Boundary."

FNP compliance with GDC 30 is discussed in FSAR section 3.1.26, "Criterion 30 Quality of Reactor Coolant Pressure Boundary." With respect to RCS leakage detection, FSAR section 3.1.26 states the following:

"Leakage is detected by an increase in the amount of makeup water required to maintain a normal level in the pressurizer. The reactor vessel closure joint is provided with a temperature monitored leak off between double gaskets. Leakage inside the containment is drained to the containment sump.

E1-5 to NL-11-0675 April 29, 2011 Basis for Proposed Change Leakage is also detected by measuring the airborne activity and the rate of condensate drained from the containment air recirculation units. Monitoring the inventory of reactor coolant in the system at the pressurizer, volume control tank, and coolant drain collection tanks makes available an accurate indication of integrated leakage.

The reactor coolant pressure boundary leakage detection system is discussed in subsection 5.2.7."

FNP FSAR section 5.2.7, "Reactor Coolant Pressure Boundary (RCPB)

Leakage Detection Systems," contains a detailed discussion of the leakage detection systems.

5.0 Regulatory Safety Analysis 5.1 No Significant Hazards Consideration Determination SNC has evaluated the proposed changes to the FNP TS using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration. An analysis of the issue of no significant hazards consideration is presented below:

The proposed amendment would revise FNP TS 3.4.15 "RCS Leakage Detection Instrumentation" Conditions and Required Actions to define a new time limit for restoring inoperable RCS leakage detection instrumentation to operable status; establish alternate methods of monitoring RCS leakage when one or more required monitors are inoperable; and make conforming TS Bases changes.

As required by 10 CFR 50.91 (a), the SNC analysis of the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is presented below:

1:

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change clarifies the operability requirements for the RCS leakage detection instrumentation and reduces the time allowed for the plant to operate when the only TS-required operable RCS leakage detection instrumentation monitor is the containment atmosphere gaseous radiation monitor. The monitoring of RCS leakage is not a precursor to any accident previously evaluated. The monitoring of RCS leakage is not used to mitigate the consequences of any accident previously evaluated. Therefore, it is concluded that the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2:

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

E1-6 to NL-11-0675 April 29, 2011 Basis for Proposed Change Response: No The proposed change clarifies the operability requirements for the RCS leakage detection instrumentation and reduces the time allowed for the plant to operate when the only TS-required operable RCS leakage detection instrumentation monitor is the containment atmosphere gaseous radiation monitor. The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The proposed change maintains sufficient continuity and diversity of leak detection capability that the probability of piping evaluated and approved for Leak-Before-Break progressing to pipe rupture remains extremely low. Therefore, it is concluded that the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3:

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

Response: No The proposed change clarifies the operability requirements for the RCS leakage detection instrumentation and reduces the time allowed for the plant to operate when the only TS-required operable RCS leakage detection instrumentation monitor is the containment atmosphere gaseous radiation monitor. Reducing the amount of time the plant is allowed to operate with only the containment atmosphere gaseous radiation monitor operable increases the margin of safety by increasing the likelihood that an increase in RCS leakage will be detected before it potentially results in gross failure. Therefore, it is concluded that the proposed change does not involve a significant reduction in a margin of safety.

Based upon the above analysis, SNC concludes that the requested change does not involve a significant hazards consideration, as set forth in 10 CFR 50.92(c),

"Issuance of Amendment."

5.2 Applicable Regulatory Requirements/Criteria A description of the proposed TS change and its relationship to applicable regulatory requirements were published in the Federal Register Notice of Availability on January 3, 2011 (76 FR 189). SNC has reviewed the NRC staff's model SE referenced in the CLlIP Notice of Availability and concluded that the regulatory evaluation section is applicable to FNP.

6.0 Environmental Consideration The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, and would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, Oi) a significant change in the E1-7 to NL-11-0675 April 29, 2011 Basis for Proposed Change types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

7.0 References

1. General Design Criterion (GDC) 30, "Quality of Reactor Coolant Pressure Boundary."

2. Regulatory Guide 1.45, Revision 0, "Reactor Coolant Pressure Boundary Leakage Detection System," May 1973.

3. FNP FSAR section 3.1.26, "Criterion 30 - Quality of Reactor Coolant Pressure Boundary."

4. FNP FSAR section 5.2.7, "Reactor Coolant Pressure Boundary (RCPB) Leakage Detection Systems."

5. FNP FSAR Appendix 3A, "Conformance with NRC Regulatory Guides."

E1-8

Joseph M. Farley Nuclear Plant License Amendment Request to Adopt TSTF-513-A, Revision 3 Revise PWR Operability Requirements and Actions for ReS Leakage Instrumentation Technical Specifications and Bases Markup Pages

3.4.15 ACTIONS CONDITION B.

Required containment atmosphere gaseous radioactivity monitor inoperable.

Required containment air cooler condensate level monitor inoperable.

Insert 1 Required Action and associated Completion Time not met.

All required monitors inoperable.

RCS Leakage Detection Instrumentation REQUIRED ACTION OMPLETION TIME B.1.1 Analyze grab samples of Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months the containment atmosphere.

OR B.1.2 Perform SR 3.4.13.1.

Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AND B.2 Restore at least one 30 days required monitor to OPERABLE status.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months D

Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Enter LCO 3.0.3.

Immediately Farley Units 1 and 2 3.4.15-2 Amendment No. ~ (Unit 1)

Amendment No. ~ (Unit 2)

Insert 1:

C.

Containment atmosphere particulate radioactivity monitor inoperable.

C.1 AND Required containment air cooler condensate level monitor inoperable.

C.2.1 OR C.2.2 Analyze grab samples of the containment atmosphere.

Restore containment atmosphere particulate radioactivity monitor to OPERABLE status.

Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 7 days Restore required containment air cooler condensate level monitor to OPERABLE status.

7 days

RCS Leakage Detection Instrumentation B 3.4.15 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.15 RCS Leakage Detection Instrumentation

,Revision 0 BASES BACKGROUND GDC 30 of Appendix A to 10 CFR 50 (Ref. 1) requi es means for detecting and, to the extent practical, identifying t location of the source of RCS LEAKAGE. Regulatory Guide 1.4 (Ref. 2) describes acceptable methods for selecting leakage detection systems.

Leakage detection systems must have the capability to detect significant reactor coolant pressure boundary (RCPB) degradation as soon after occurrence as practical to minimize the potential for propagation to a gross failure. Thus, an early indication or warning signal is necessary to permit proper evaluation of all unidentified In addition to meeting the 1--'-.I:::.'l,p.JJI't:::1t~

OPERABILITY requirements, the monitors are typically set to provide the most The containment air cooler condensate level monitor is instrumented sensitive response to alarm for abnormal increases in the level flow rates.

without causing an excessive number of

~~~~. The condensate flow rate is measured by monitoring the spurious alarms.

water level in a vertical standpipe. As flow rate increases, the water level in the standpipe rises.

olant contains radioactivity that, when released to the instrumentation. Reactor coolant radioactivity levels INill be low during initial reactor startup and fer a fe....' woeks thereafter, until activated Other indications may corrosion products have been formed and fission products appear be used to detect an from fuel olement cladding contamination or cladding defects.

increase in

.JlIlEitrulfREmt--s&RSf*W*~'w'~ef.-:w..g J;lCi/GG radioactivity for partioulato

-9 unidentified LEAKAGE; however,

. Radioactivity detection they are not required re included for monitoring both particulate and gaseous to be OPERABLE by activities cause of their sensitivities and rapid responses to RCS LEAKAGE.

this LCO.

An increase in humidity of the containment atmosphere would indicate release of water vapor to the containment. Dew point temperature measurements can thus be used to monitor humidity (continued)

Farley Units 1 and 2 B 3.4.15-1 IRevision 01

BASES BACKGROUND (continued) is APPLICABLE SAFETY ANALYSES The above-mentioned LEAKAGE detection systems differ in sensitivity and response time. Some of these systems could serve as early alarm systems identifying to the operators that closer examination of other detection systems is necessary to determine the extent of any corrective action that may be required.

Farley Units 1 and 2 RCS Leakage Detection Instrumentation B 3.4.15 levels of the containment atmos here as an indicator of LEAKAGE.

Since the humidity level is influenced by several factors, a quantitative evaluation of an indicated leakage rate by this means may be questionable and should be compared to observed increases in liquid flow from the containment condensate air coolers. Humidity level monitoring is considered most useful as an indirect alarm or indication to alert the operator to a potential problem. Humidity monitors are not required by this LCO.

Air te erature and pressure monitoring methods may also be used to infer u' ntified LEAKAGE to the containment. Containment temperature pressure fluctuate slightly during plant operation, but a rise above the n ally indicated range of values may indicate RCS leakage into the cont' ent. The relevance of temperature and pressure measurements affected by containment free volume and, for temperature, detector location. Alarm signals from these instruments can be valuable in recognizing rapid and sizable leakage to the containment. Temperature and pressure monitors are not required by this LCO.

The safety significance of RCS LEAKAGE varies widely depending on its source, rate, and duration. Therefore, detecting and monitoring RCS LEAKAGE into the containment area is necessary. Quickly separating the identified LEAKAGE from the unidentified LEAKAGE provides quantitative information to the operators, allowing them to take corrective action should a leakage occur detrimental to the safety of the unit and the public.

RCS leakage detection instrumentation satisfies Criterion 1 of 10 CFR 50.36(c)(2)(ii).

B 3.4.15-2 IRevision 01

RCS Leakage Detection Instrumentation B 3.4.15 BASES LCO One method of protecting against large RCS leakage derives frorn the ability of instrurnents to rapidly detect e*.trernely small leaks. This LCO requires instrurnents of diverse monitoring principles to be OPERABLE to provide a high degree of confidence that extrernely srnall leaks are detected in time to allow actions to plaoe the plant in a safe oondition, I....hen RCS LEAKAGE indioates possible RCPB 1L...-__I_n_se_rt_2__""--""f"...degradation.

L

~~~~-----------------------~

The LCO is satisfied when monitors of diverse measurement means are available. Thus, the containment atmosphere particulate radioactivity monitor (R-11) in combination with a gaseous radioactivity monitor (R-12) or a containment air cooler condensate level monitor provides an acceptable minimum.

APPLICABILITY Because of elevated RCS temperature and pressure in MODES 1, 2, 3, and 4, RCS leakage detection instrumentation is required to be OPERABLE.

In MODE 5 or 6, the temperature is to be ~ 200°F and pressure is maintained low or at atmospheric pressure. Since the temperatures and pressures are far lower than those for MODES 1, 2, 3, and 4, the likelihood of leakage and crack propagation are much smaller.

Therefore, the requirements of this LCO are not applicable in MODES 5 and 6.

ACTIONS A.1.1. A.1.2. and A.2 With the required containment atmosphere particulate radioactivity monitor inoperable, no other form of sampling can provide the (continued)

Farley Units 1 and 2 B 3.4.15-3 IRevision 331

BASES ACTIONS containment containment air cooler 1.-_______--1 ~

Insert 3 RCS Leakage Detection Instrumentation B 3.4.15 radioactivity A.1.1. A.1.2. and A.2 (continued) t information; however, the containment at osphere gaseous ra tivity monitor or the containment a' cooler condensate level m

. r will provide indications changes in leakage. Together with t atmosphere gaseous monitor or the condensate level monitor, the periodic surveillance for RCS water inventory balance, SR 3.4.13.1, must be performed at an increased frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or grab samples of the containment atmosphere must be taken and analyzed once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to provide information that is adequate to detect leakage.

Restoration of the required Particulate radioactivity monitor to OPERABLE status within a Completion Time of 30 days is required to regain the function after the monitor's failure. This time is acceptable, considering the Frequency and adequacy of the RCS water inventory balance or containment grab sample analyses required by Required Action A.1.1 or A.1.2.

B.1.1. B.1.2. and B.2 With both the required gaseous containment atmosphere radioactivity monitoring instrumentation channel and the required containment air cooler condensate level monitoring instrumentation channel inoperable, alternative action is required. Either grab samples of the containment atmosphere must be taken and analyzed or water inventory balances, in accordance with SR 3.4.13.1, must be performed to provide alternate periodic information.

With a sample obtained and analyzed or water inventory balance performed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the reactor may be operated for up to 30 days to allow restoration of at least one of the required containment monitors.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months interval provides periodic information that is adequate to etect leakage. The 30 day Completion Time recognizes at least one er form of leakage detection is available.

. 2

,B,orC a Required Action of Condition A cannot be met, the plant must be brought to a MODE in which the requirement does not apply.

To Farley Units 1 and 2 B 3.4.15-4 IRevision 01

RCS Leakage Detection Instrumentation B 3.4.15 BASES ACTIONS L:;:;,I!..!...:::.!..!.:::...~.=2 (continued) achieve this status. the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable. based on operating experience, to reach the required plant conditions from full power conditions in an

,--_E__~, orderly manner and without challenging plant systems.

ru With all required monitors inoperable, no automatic means of monitoring leakage are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required.

SURVEILLANCE SR 3.4.15.1 REQUIREMENTS SR 3.4.15.1 requires the performance of a CHANNEL CHECK of the required containment atmosphere radioactivity monitor. The check gives reasonable confidence that the channel is operating properly.

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is based on instrument reliability and is reasonable for detecting off normal conditions.

SR 3.4.15.2 SR 3.4.15.2 requires the performance of a COT on the required containment atmosphere radioactivity monitor. The test ensures that the monitor can perform its function in the desired manner. The test verifies the alarm setpoint and relative accuracy of the instrument string. The Frequency of 92 days considers instrument reliability, and operating experience has shown that it is proper for detecting degradation.

SR 3.4.15.3 and SR 3.4.15.4 These SRs require the performance of a CHANNEL CALIBRATION for each of the RCS leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string. including the instruments located inside containment. The Frequency of 18 months is a typical refueling cycle and considers channel reliability. Again.

operating experience has proven that this Frequency is acceptable.

Farley Units 1 and 2 B 3.4.15-5 IRe'/isien 01

RCS Leakage Detection Instrumentation f

r-------------------~

Regulatory Guide 1.45, B 3.4.15 Revision 0, "Reactor Coolant Pressure Boundary Leakage

_B_A_S_E_S________H Detection Systems," May 1973.

REFERENCES

1. 10 CFR 50, Appendix A, Section IV, GDC 30.

2.

3. FSAR, Section 5.2.7.

Farley Units 1 and 2 B 3.4.15-6 IRevision 01

Insert 2:

This LCO requires instruments of diverse monitoring principles to be OPERABLE to provide confidence that small amounts of unidentified LEAKAGE are detected in time to allow actions to place the plant in a safe condition, when RCS LEAKAGE indicates possible RCPB degradation.

The LCO requires two instruments to be OPERABLE.

The reactor coolant contains radioactivity that, when released to the containment, may be detected by the gaseous or particulate containment atmosphere radioactivity monitor.

Radioactivity detection systems are included for monitoring both particulate and gaseous activities because of their sensitivities and rapid responses to RCS LEAKAGE, but have recognized limitations. Reactor coolant radioactivity levels will be low during the initial reactor startup following a refueling outage and for a few weeks thereafter, until activated corrosion products have been formed and fission products appear from fuel assembly cladding contamination or cladding defects. If there are few fuel assembly cladding defects and low levels of activation products, it may not be possible for the gaseous or particulate containment atmosphere radioactivity monitors to detect a 1 gpm increase within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months during normal operation. However, the gaseous or particulate containment atmosphere radioactivity monitor is OPERABLE when it is capable of detecting approximately a 1 gpm increase in unidentified LEAKAGE within approximately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months given an RCS activity equivalent to that assumed in the design calculations for the monitors as described in Reference 3.

An increase in humidity of the containment atmosphere could indicate the release of water vapor to the containment. The containment air cooler condensate level monitor detects condensate flow from air coolers by monitoring a standpipe level increase versus time. The time required to detect approximately a 1 gpm increase above the normal value varies based on environmental and system conditions and may take longer than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . This sensitivity is acceptable for containment air cooler condensate level monitor OPERABILITY.

Insert 3:

C.1! C.2.1, and C.2.2 With the required containment atmosphere particulate radioactivity monitor inoperable and the required containment air cooler condensate level monitor inoperable, the only means of detecting LEAKAGE is the required containment atmosphere gaseous radioactivity monitor. This Condition is applicable when the only OPERABLE monitor is the containment atmosphere gaseous radioactivity monitor. The containment atmosphere gaseous radioactivity monitor typically cannot detect a 1 gpm leak within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months when the RCS activity is low. In addition, this configuration does not provide the required diverse means of leakage detection. Indirect methods of monitoring RCS leakage must be implemented. Grab samples of the containment atmosphere must be taken to provide alternate periodic information. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval is sufficient to detect increasing ReS leakage. The Required Action provides 7 days to restore another RCS leakage monitor to OPERABLE status to restore the intended leakage detection diversity. The 7 day Completion Time ensures that the plant will not be operated in a degraded configuration for a lengthy time period.

Joseph M. Farley Nuclear Plant License Amendment Request to Adopt TSTF-513-A, Revision 3 Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation Technical Specifications and Bases Clean Typed Pages

3.4.15 ACTIONS CONDITION B.

Required containment atmosphere gaseous radioactivity monitor inoperable.

AND Required containment air cooler condensate level monitor inoperable.

C.

Containment atmosphere particulate radioactivity monitor inoperable.

AND Required containment air cooler condensate level monitor inoperable.

D.

Required Action and associated Completion Time not met.

E.

All required monitors inoperable.

Farley Units 1 and 2 RCS Leakage Detection Instrumentation REQUIRED ACTION COMPLETION TIME B.1.1 Analyze grab samples of Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months the containment atmosphere.

OR B.1.2 Perform SR 3.4.13.1.

Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AND B.2 Restore at least one 30 days required monitor to OPERABLE status.

C.1 Analyze grab samples of Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months the containment atmosphere.

AND C.2.1 Restore containment 7 days atmosphere particulate radioactivity monitor to OPERABLE status.

OR C.2.2 Restore required 7 days containment air cooler condensate level monitor to OPERABLE status.

D.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND D.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months E.1 Enter LCO 3.0.3.

Immediately 3.4.15-2 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

RCS Leakage Detection Instrumentation B 3.4.15 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.15 RCS Leakage Detection Instrumentation BASES BACKGROUND GDC 30 of Appendix A to 10 CFR 50 (Ref. 1) requires means for detecting and, to the extent practical, identifying the location of the source of RCS LEAKAGE. Regulatory Guide 1.45, Revision 0 (Ref. 2) describes acceptable methods for selecting leakage detection systems.

Leakage detection systems must have the capability to detect significant reactor coolant pressure boundary (RCPB) degradation as soon after occurrence as practical to minimize the potential for propagation to a gross failure. Thus, an early indication or warning signal is necessary to permit proper evaluation of all unidentified LEAKAGE. In addition to meeting the OPERABILITY requirements, the monitors are typically set to provide the most sensitive response without causing an excessive number of spurious alarms.

The containment air cooler condensate level monitor is instrumented to alarm for abnormal increases in the level (flow rates). The condensate flow rate is measured by monitoring the water level in a vertical standpipe. As flow rate increases, the water level in the standpipe rises.

The reactor coolant contains radioactivity that, when released to the containment, may be detected by radiation monitoring instrumentation. Radioactivity detection systems are included for monitoring both particulate and gaseous activities because of their sensitivities and rapid responses to RCS LEAKAGE.

Other indications may be used to detect an increase in undentified LEAKAGE; however, they are not required to be OPERABLE by this LCO.

An increase in humidity of the containment atmosphere would indicate release of water vapor to the containment. Dew point temperature measurements can thus be used to monitor humidity levels of the containment atmosphere as an indicator of potential RCS LEAKAGE Since the humidity level is influenced by several factors, a quantitative Farley Units 1 and 2 B 3.4.15-1

RCS Leakage Detection Instrumentation B 3.4.15 BASES BACKGROUND

( continued)

APPLICABLE SAFETY ANALYSES evaluation of an indicated leakage rate by this means may be questionable and should be compared to observed increases in liquid flow from the containment condensate air coolers. Humidity level monitoring is considered most useful as an indirect alarm or indication to alert the operator to a potential problem. Humidity monitors are not required by this LCO.

Air temperature and pressure monitoring methods may also be used to infer unidentified LEAKAGE to the containment. Containment temperature and pressure fluctuate slightly during plant operation, but a rise above the normally indicated range of values may indicate RCS leakage into the containment. The relevance of temperature and pressure measurements is affected by containment free volume and, for temperature, detector location. Alarm signals from these instruments can be valuable in recognizing rapid and sizable leakage to the containment. Temperature and pressure monitors are not required by this LCO.

The above-mentioned LEAKAGE detection systems differ in sensitivity and response time. Some of these systems could serve as early alarm systems identifying to the operators that closer examination of other detection systems is necessary to determine the extent of any corrective action that may be required.

The need to evaluate the severity of an alarm or an indication is important to the operators, and the ability to compare and verify with indications from other systems is necessary.

The safety significance of RCS LEAKAGE varies widely depending on its source, rate, and duration. Therefore, detecting and monitoring RCS LEAKAGE into the containment area is necessary. Quickly separating the identified LEAKAGE from the unidentified LEAKAGE provides quantitative information to the operators, allowing them to take corrective action should a leakage occur detrimental to the safety of the unit and the public.

RCS leakage detection instrumentation satisfies Criterion 1 of 10 CFR 50.36(c)(2)(ii).

(continued)

Farley Units 1 and 2 B 3.4.15-2

BASES Leo Farley Units 1 and 2 Res Leakage Detection Instrumentation B3.4.15 This Leo requires instruments of diverse monitoring principles to be OPERABLE to provide confidence that small amounts of unidentified LEAKAGE are detected in time to allow actions to place the plant in a safe condition, when ReS LEAKAGE indicates possible RePB degradation.

The LeO requires two instruments to be OPERABLE.

The reactor coolant contains radioactivity that, when released to the containment, may be detected by the gaseous or particulate containment atmosphere radioactivity monitor. Radioactivity detection systems are included for monitoring both particulate and gaseous activities because of their sensitivities and rapid responses to ReS LEAKAGE, but have recognized limitations. Reactor coolant radioactivity levels will be low during the initial reactor startup following a refueling outage and for a few weeks thereafter, until activated corrosion products have been formed and fission products appear from fuel assembly cladding contamination or cladding defects. If there are few fuel assembly cladding defects and low levels of activation products, it may not be possible for the gaseous or particulate containment atmosphere radioactivity monitors to detect a 1 gpm increase within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months during normal operation. However, the gaseous or particulate containment atmosphere radioactivity monitor is OPERABLE when it is capable of detecting approximately a 1 gpm increase in unidentified LEAKAGE within approximately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months given an ReS activity equivalent to that assumed in the design calculations for the monitors as described in Reference 3.

An increase in humidity of the containment atmosphere could indicate the release of water vapor to the containment. The containment air cooler condensate level monitor detects condensate flow from air coolers by monitoring a standpipe level increase versus time. The time required to detect approximately a 1 gpm increase above the normal value varies based on environmental and system conditions and may take longer than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . This sensitivity is acceptable for containment air cooler condensate level monitor OPERABILITY.

The LeO is satisfied when monitors of diverse measurement means are available. Thus, the containment atmosphere particulate radioactivity monitor (R-11) in combination with a gaseous radioactivity monitor (R-12) or a containment air cooler condensate level monitor provides an acceptable minimum.

(continued)

B 3.4.15-3

BASES APPLICABILITY ACTIONS Farley Units 1 and 2 RCS Leakage Detection Instrumentation B 3.4.15 Because of elevated RCS temperature and pressure in MODES 1, 2, 3, and 4, RCS leakage detection instrumentation is required to be OPERABLE.

In MODE 5 or 6, the temperature is to be :$ 200°F and pressure is maintained low or at atmospheric pressure. Since the temperatures and pressures are far lower than those for MODES 1, 2, 3, and 4, the likelihood of leakage and crack propagation are much smaller.

Therefore, the requirements of this LCO are not applicable in MODES 5 and 6.

A.1.1, A.1.2, and A.2 With the required containment atmosphere particulate radioactivity monitor inoperable, no other form of sampling can provide the equivalent information; however, the containment atmosphere gaseous radioactivity monitor or the containment air cooler containment air cooler condensate level monitor will provide indications of changes in leakage. Together with the containment atmosphere gaseous radioactivity monitor or the containment air cooler condensate level monitor, the periodic surveillance for RCS water inventory balance, SR 3.4.13.1, must be performed at an increased frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or grab samples of the containment atmosphere must be taken and analyzed once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to provide information that is adequate to detect leakage.

Restoration of the required Particulate radioactivity monitor to OPERABLE status within a Completion Time of 30 days is required to regain the function after the monitor's failure. This time is acceptable, considering the Frequency and adequacy of the RCS water inventory balance or containment grab sample analyses required by Required Action A.1.1 or A.1.2.

B.1.1, 8.1.2, and B.2 With both the required gaseous containment atmosphere radioactivity monitoring instrumentation channel and the required containment air cooler condensate level monitoring instrumentation channel inoperable, alternative action is required. Either grab samples of the containment atmosphere must be taken and analyzed or water B 3.4.15-4

BASES ACTIONS Farley Units 1 and 2 RCS Leakage Detection Instrumentation B3.4.15 B.1.1. 8.1.2. and B.2 (continued) inventory balances, in accordance with SR 3.4.13.1, must be performed to provide alternate periodic information.

With a sample obtained and analyzed or water inventory balance performed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the reactor may be operated for up to 30 days to allow restoration of at least one of the required containment monitors.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months interval provides periodic information that is adequate to detect leakage. The 30 day Completion Time recognizes at least one other form of leakage detection is available.

C.1. C.2.1. and C.2.2 With the required containment atmosphere particulate radioactivity monitor inoperable and the required containment air cooler condensate level monitor inoperable, the only means of detecting LEAKAGE is the required containment atmosphere gaseous radioactivity monitor. This Condition is applicable when the only OPERABLE monitor is the containment atmosphere gaseous radioactivity monitor.

The containment atmosphere gaseous radioactivity monitor typically cannot detect a 1 gpm leak within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months when the RCS activity is low.

In addition, this configuration does not provide the required diverse means of leakage detection. Indirect methods of monitoring RCS leakage must be implemented. Grab samples of the containment atmosphere must be taken to provide alternate periodic information.

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval is sufficient to detect increasing RCS leakage.

The Required Action provides 7 days to restore another RCS leakage monitor to OPERABLE status to restore the intended leakage detection diversity_ The 7 day Completion Time ensures that the plant will not be operated in a degraded configuration for a lengthy time period.

D.1 and D.2 If a Required Action of Condition A, B, or C cannot be met, the plant must be brought to a MODE in which the requirement does not apply.

To achieve this status. the plant must be brought to at least MODE 3 B 3.4.15-5

BASES ACTIONS SURVEILLANCE REQUIREIVIENTS RCS Leakage Detection Instrumentation B 3.4.15 D.1 and D.2 (continued) within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

With all required monitors inoperable, no automatic means of monitoring leakage are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required.

SR 3.4.15.1 SR 3.4.15.1 requires the performance of a CHANNEL CHECK of the required containment atmosphere radioactivity monitor. The check gives reasonable confidence that the channel is operating properly_

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is based on instrument reliability and is reasonable for detecting off normal conditions.

SR 3.4.15.2 SR 3.4.15.2 requires the performance of a COT on the required containment atmosphere radioactivity monitor. The test ensures that the monitor can perform its function in the desired manner. The test verifies the alarm setpoint and relative accuracy of the instrument string. The Frequency of 92 days considers instrument reliability, and operating experience has shown that it is proper for detecting degradation.

SR 3.4.15.3 and SR 3.4.15.4 These SRs require the performance of a CHANNEL CALIBRATION for each of the RCS leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Frequency of 18 months is a typical refueling cycle and considers channel reliability. Again, operating experience has proven that this Frequency is acceptable.

Farley Units 1 and 2 B 3.4.15-6

RCS Leakage Detection Instrumentation B 3.4.15 BASES REFERENCES

1. 10 CFR 50, Appendix A, Section IV, GDC 30.

2. Regulatory Guide 1.45, Revision 0, "Reactor Coolant Pressure Boundary Leakage Detection Systems," May 1973.

3. FSAR, Section 5.2.7.

Farley Units 1 and 2 B 3.4.15-7

Vogtle Electric Generating Plant License Amendment Request to Adopt TSTF-513-A, Revision 3 Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation Basis for Proposed Change to NL-11-0675 April 29, 2011 Basis for Proposed Change Table of Contents 1.0 Description 2.0 Proposed Changes 2.1 Variations from TSTF-513-A

3.0 Background

4.0 Technical Analysis 5.0 Regulatory Safety Analysis 5.1 No Significant Hazards Consideration Determination 5.2 Applicable Regulatory Requirements/Criteria 6.0 Environmental Consideration 7.0 References E4-2 to NL-11-0675 April 29, 2011 Basis for Proposed Change 1.0 Description This evaluation supports a request to amend Appendix A of Operating Licenses NPF-68 and NPF-81 for Vogtle Electric Generating Plant (VEGP) Unit 1 and Unit 2, respectively.

The proposed amendment would revise the Technical Specifications (TS) to define a new time limit for restoring inoperable Reactor Coolant System (RCS) leakage detection instrumentation to operable status; establish alternate methods of monitoring RCS leakage when one or more required monitors are inoperable; and make conforming TS Bases changes. These changes are consistent with NRC approved Technical Specification Task Force Traveler TSTF-513-A Revision 3, "Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation." The availability of this TS improvement was announced in the Federal Register on January 3, 2011 (76 FR 189) as part of the consolidated line item improvement process (CLlIP).

Southern Nuclear Operating Company (SNC) requests approval of the proposed license amendments by May 3, 2012. The proposed changes would be implemented within 60 days of issuance of the amendments.

2.0 Proposed Changes The proposed changes revise and add a new Condition F for VEGP to TS 3.4.15, "RCS Leakage Detection Instrumentation," and revise the associated bases. The proposed new Condition F is applicable when the containment atmosphere gaseous radioactivity monitor is the only operable TS-required monitor (Le., all other monitors are inoperable).

The proposed new Condition F Required Actions require analyzing grab samples of the containment atmosphere every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and restoring another monitor within 7 days.

Additionally, the TS Bases, which summarize the reasons for the specifications, are revised to clarify the specified safety function for each required instrument in the limiting condition for operation (LCO) Bases, delete discussion from the Bases that could be construed to alter the meaning of TS operability requirements, and reflect the changes made to TS 3.4.15.

2.1 Variations from TSTF-513-A SNC is proposing variations from the TS changes described in TSTF-513-A, Revision 3. The proposed variations are necessary to accommodate plant specific design configurations or plant specific TS differences. The proposed variations remain consistent with the intent of TSTF-513-A and do not impact the conclusions in the referenced NRC staff's model SE.

The following variations from the TS changes described in TSTF-513-A, Revision 3, are proposed:

1. The proposed new Condition D being added by TSTF-513-A to TS 3.4.15 was revised to new Condition F for VEGP. This variation from TSTF-513-A is due to the plant specific Conditions in VEGP TS 3.4.15 which reflect the VEG P specific RCS leakage detection instrumentation. The different placement of this new Condition in the VEGP TS 3.4.15 is consistent with the E4-3 to NL-11-0675 April 29, 2011 Basis for Proposed Change intent of TSTF-513-A and minimizes the re-Iettering of subsequent Conditions.

2. As stated in TSTF-513, "In several locations in all three NUREGs, the specifications incorrectly refer to a "required" containment sump monitor or "required" containment air cooler flow rate monitor when the LCD does not provide for more than one monitor. The term "required" is reserved for situations in which there are multiple ways to meet the LCD, such as the requirement for either a gaseous or particulate radiation monitor. The incorrect use of the term "required" is removed." In TSTF-513-A the word "required" is deleted from TS 3.4.15 Condition C for an inoperable containment air cooler condensate flow rate monitor. The corresponding VEGP TS 3.4.15 Condition D addresses an inoperable containment air cooler condensate flow rate monitor. However, the word "required" is appropriate in the VEGP Condition D, as there are multiple ways to meet the VEGP LCD requirement. The VEGP TS 3.4.15 LCD requirement for the containment air cooler condensate flow rate monitor includes the alternative to use "... a containment atmosphere gaseous or particulate radioactivity monitoring system not taken credit for in item b." Therefore, the word "required" is not deleted from the VEGP Condition D and this approach is consistent with the intent of TSTF-513-A.

3. The revisions to the VEGP TS 3.4.15 Bases are more extensive than the TS Bases revisions in TSTF-513-A. This variation from TSTF-513-A is due to the additional information included in the Background section of the VEGP Bases. As previously stated in section 2.0, "... the TS Bases, which summarize the reasons for the specifications, are revised to clarify the specified safety function for each required instrument in the limiting condition for operation (LCD) Bases, delete discussion from the Bases that could be construed to alter the meaning of TS operability requirements.... " The VEGP specific Bases include more information in the Background section that could be construed to alter the meaning of TS operability requirements than the model TS Bases in TSTF-513-A. Therefore, the VEGP TS Bases were revised to delete the additional information from the Background section, and move some of that information to the LCD section of the TS Bases. The additional revisions to the VEGP TS Bases make the level of detail in the Background and LCD sections more consistent with the TS Bases in TSTF 513-A. Finally, the VEGP TS Bases LCD section specifically reflects the VEGP specific RCS leakage detection instrumentation sensitivities as documented in the updated VEGP Final Safety Analysis Report (FSAR) section 5.2.5. This approach remains consistent with the intent of TSTF-513.

3.0 Background

NRC Information Notice (IN) 2005-24, "Nonconservatism in Leakage Detection Sensitivity," dated August 3,2005, informed addressees that the reactor coolant activity assumptions for primary containment atmosphere gaseous radioactivity monitors may be non-conservative. This means the monitors may not be able to detect a one gallon per minute increase within one hour. Some licensees have taken action in response to IN 2005-24 to remove the gaseous radioactivity monitor from the TS list of required E4-4 to NL-11-0675 April 29, 2011 Basis for Proposed Change monitors. However, industry experience has shown that the primary containment atmosphere gaseous radiation monitor is often the first monitor to indicate an increase in RCS leak rate. As a result, the TSTF and the NRC staff met on April 29, 2008, and April 14, 2009, to develop an alternative approach to address the issue identified in IN 2005-24. The agreed solution is to retain the primary containment atmosphere gaseous radiation monitor in the LCD list of required equipment, revise the specified safety function of the gas monitor to specify the required instrument sensitivity level, revise the Actions to require additional monitoring, and provide less time before a plant shutdown is required when the primary containment atmosphere gaseous radiation monitor is the only operable monitor.

4.0 Technical Analysis SNC has reviewed TSTF-513-A, Revision 3, and the model SE published on January 3, 2011 (76 FR 189) as part of the CUIP Notice of Availability. SNC has concluded that the technical bases presented in TSTF Traveler-513, Revision 3, and the model SE prepared by the NRC staff are applicable to VEGP.

The proposed amendment revises the language in the TS Bases that describes when the gaseous and particulate containment atmosphere radioactivity monitor is operable.

The proposed amendment requires additional containment atmosphere grab samples or manual RCS leakage monitoring to be performed when the primary containment atmosphere gaseous radiation monitor is the only operable continuous or automatic monitor. These alternative methods provide an RCS leakage detection capability similar to the TS-required methods. The containment atmosphere grab sample has an RCS leakage detection capability that is comparable to that of the containment atmosphere particulate radiation monitor. The proposed Actions and Completion Times for grab samples are adequate because the use of frequent grab samples provides additional assurance, in addition to the mass balances required by VEGP TS 3.4.15 Conditions A and B when the containment sump monitors are inoperable, that any significant RCS leakage will be detected prior to significant reactor coolant pressure boundary (RCPB) degradation.

Compliance with General DeSign Criterion (GDC) 30, "Quality of Reactor Coolant Pressure Boundary."

VEGP compliance with GDC 30 is discussed in FSAR section 3.1.4, "Fluid Systems."

With respect to RCS leakage detection, FSAR section 3.1.4 states the following:

"A number of methods are available for detecting reactor coolant leakage. The reactor vessel closure joint is provided with a temperature monitored leak off between double gaskets. Leakage inside the reactor containment is drained to the containment building and reactor cavity sumps, where the level is monitored. Leakage is also detected by measuring the airborne activity and humidity of the containment. Monitoring the inventory of reactor coolant in the system at the pressurizer, volume control tank, and reactor coolant drain tank provides an accurate indication of integrated leakage.

Refer to chapter 5 for complete description of the RCPB leakage detection system."

E4-5 to NL-11-0675 April 29, 2011 Basis for Proposed Change UFSAR Section 5.2.5, "Detection of Leakage through Reactor Coolant Pressure Boundary," contains a detailed discussion of the leakage detection systems.

5.0 Regulatory Safety Analysis 5.1 No Significant Hazards Consideration Determination SNC has evaluated the proposed changes to the VEGP TS using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration. An analysis of the issue of no significant hazards consideration is presented below:

The proposed amendment would revise VEGP TS 3.4.15 "RCS Leakage Detection Instrumentation" Conditions and Required Actions to define a new time limit for restoring inoperable RCS leakage detection instrumentation to operable status; establish alternate methods of monitoring RCS leakage when one or more required monitors are inoperable; and make conforming TS Bases changes.

As required by 10 CFR 50.91 (a), the SNC analysis of the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is presented below:

1:

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change clarifies the operability requirements for the RCS leakage detection instrumentation and reduces the time allowed for the plant to operate when the only TS-required operable RCS leakage detection instrumentation monitor is the containment atmosphere gaseous radiation monitor. The monitoring of RCS leakage is not a precursor to any accident previously evaluated. The monitoring of RCS leakage is not used to mitigate the consequences of any accident previously evaluated. Therefore, it is concluded that the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2:

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

Response: No The proposed change clarifies the operability requirements for the RCS leakage detection instrumentation and reduces the time allowed for the plant to operate when the only TS-required operable RCS leakage detection instrumentation monitor is the containment atmosphere gaseous radiation monitor. The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The proposed change maintains sufficient continuity and E4-6 to NL-11-0675 April 29, 2011 Basis for Proposed Change diversity of leak detection capability that the probability of piping evaluated and approved for Leak-Before-Break progressing to pipe rupture remains extremely low. Therefore, it is concluded that the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3:

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

Response: No The proposed change clarifies the operability requirements for the RCS leakage detection instrumentation and reduces the time allowed for the plant to operate when the only TS-required operable RCS leakage detection instrumentation monitor is the containment atmosphere gaseous radiation monitor. Reducing the amount of time the plant is allowed to operate with only the containment atmosphere gaseous radiation monitor operable increases the margin of safety by increasing the likelihood that an increase in RCS leakage will be detected before it potentially results in gross failure. Therefore, it is concluded that the proposed change does not involve a significant reduction in a margin of safety.

Based upon the above analysis, SNC concludes that the requested change does not involve a significant hazards consideration, as set forth in 10 CFR 50.92(c),

"Issuance of Amendment."

5.2 Applicable Regulatory Requirements/Criteria A description of the proposed TS change and its relationship to applicable regulatory requirements were published in the Federal Register Notice of Availability on January 3, 2011 (76 FR 189). SNC has reviewed the NRC staff's model SE referenced in the CLlIP Notice of Availability and concluded that the regulatory evaluation section is applicable to VEGP.

6.0 Environmental Consideration The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, and would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

E4-7 to NL-11-0675 April 29, 2011 Basis for Proposed Change 7.0 References

1. General Design Criterion (GDC) 30, "Quality of Reactor Coolant Pressure Boundary."

2. Regulatory Guide 1.45, Revision 0, "Reactor Coolant Pressure Boundary Leakage Detection System," May 1973.

3. VEG P FSAR section 3.1.4, "Fluid Systems."

4. VEGP FSAR section 5.2.5, "Detection of Leakage through Reactor Coolant Pressure Boundary,"

5. VEGP FSAR section 1.9, "Conformance to NRC Regulatory Guides."

E4-8

Vogtle Electric Generating Plant license Amendment Request to Adopt TSTF-513-A, Revision 3 Revise PWR Operability Requirements and Actions for ReS Leakage Instrumentation Technical Specifications and Bases Markup Pages

3.4.15 RCS Leakage Detection Instrumentation CONDITION E.

Required containment E.1 atmosphere radioactivity monitor inoperable.

AND OR Required containment air cooler condensate E.2 flow rate monitor inoperable.

Insert 1 Required Action and

~.

associated Completion Time not met.

All required leakage detection systems inoperable.

REQUIRED ACTION Restore required containment atmosphere radioactivity monitor to OPERABLE status.

Restore required containment air cooler condensate flow rate monitor to OPERABLE status.

Be in MODE 5.

COMPLETION TIME 30 days 30 days 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 Perform CHANNEL CHECK of containment normal sumps level and reactor cavity sump level monitors.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (continued)

VogUe Units 1 and 2 3.4.15-3 Amendment No. ~ (Unit 1)

Amendment No. !HI (Unit 2)

Insert 1:

N 0 TE--------------

F. 1 Analyze grab samples of Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Only applicable when a the containment containment atmosphere atmosphere.

gaseous radiation monitor is the only OPERABLE monitor.

AND F.2.1 Restore required 7 days F.

Required containment containment sump sump monitors monitors to OPERABLE inoperable.

status.

OR Required. containment F.2.2 Restore required 7 days air cooler condensate containment air cooler flow rate monitor condensate flow rate inoperable.

monitor to OPERABLE status.

RCS Leakage Detection Instrumentation B 3.4.15 B 3.4 REACTOR COOLANT SYSTEM (RCS)

Revision 0 B 3.4.15 RCS Leakage Detection Instrumentation BASES BACKGROUND In addition to meeting the OPERABILITY requirements, the monitors are typically set to provide the most sensitive response without causing an excessive number of spurious alarms.

GDC 30 of Appendix A to 10 CFR 50 (Ref. 1) requi s means for detecting and, to the extent practical, identifying th location of the source of RCS LEAKAGE. Regulatory Guide 1.45 (Ref. 2) describes acceptable methods for selecting leakage detection systems.

Le age detection systems must have the capability to detect sign!

ant reactor coolant pressure boundary (RCPB) degradation as soon a er occurrence as practical to minimize the potential for propaga n to a gross failure. Thus, an early indication or warning signal is n essa to ermit ro er evaluation of all unidentified LEAKAGE.

equh1alent. of 1 gpm can be detected in approximately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

Systems employed for detecting leakage to the containment from unidentified sources are:

Containment atmosphere airborne particulate radioactivity monitor; Containment atmosphere gaseous radioactivity monitor;

Containment air cooler condensate flow monitor; and Containment sump level monitor.

The containment airborne particulate radioactivity monitor draws an air sample from containment via a sample pump. The ~t is I=S:==;;~=blel Particulate activity can be correlated with the coolant fission and corrosion £roduct activities. ~~~~!t e~~~~!

!Standard ~'Iiations above t t rd Culdl Vogtle Units 1 and 2 B 3.4.15-1 IRe'/ision No. 01

BASES BACKGROUND (continued)

RCS Leakage Detection Instrumentation B 3.4.15 indicate a pessible leak. Fer example, '.*lith 0.01 persent failed fuel, containment background airborne particulate radioacti'/ity equivalent to 10-6 persentlday, and a partition factor equal to 0.001, a 1 gpm leak '....ould be detected in approximately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Larger leaks The containment atmosphere gaseous radioactivity monitor draws air continuously from the containment atmosphere through a gas monitor.

This sample stream flows continuousl throu h a fix shielded volume where its activit is monitored.'

-te-W

-sifsrn and a minimum detestable concentration of 5 x 10 -siIsm.

Gaseous radioactivit can be correlated with the aseous activi of the reactor coolant.

0.01 percent failed fuel, containment background airborne gaseous activity equivalent to 1 persentlday, and a partition factor equal to 1, a 1 gpm leak would be detested in approximately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Larger leaks

..*.{euld be detected in proportionately shorter times.

The containment air cooler condensate monitoring system permits measurement of the liquid runoff from the containment cooler units. It consists of a drain collection header, a vertical standpipe, valving, and standpipe level instrumentation for the coolers. The condensation from the containment coolers flows via the collection header to the vertical standpipe, and a differential pressure transmitter provides standpipe level signals. The system provides measurements of low leakages by monitoring standpipe level increase versus time.

Drainage flow rate from the cooling units due to normal condensation is calculated for the ambient (background) atmospheric conditions present within the containment With the initiation of an additional or abnormal leak, the containment atmosphere humidity and condensation runoff rate both begin to increase, the water level rises in the vertical pipe, and the high condensate flow alarm is actuated.

The condensate flow rate is a function of containment humidity, nuclear service coolin water NSCW tem erature, and containment ur e rate.

~lnsert2 Vogtle Units 1 and 2 B 3.4.15-2 IRevision No. 01

RCS Leakage Detection Instrumentation B 3.4.15 BASES BACKGROUND (continued)

APPLICABLE SAFETY ANALYSES Air brought in from the outside is heated to 60°F before it enters the containment. After entering containment, the air mixes with the containment atmesphere and is heated to bet\\veen 100°F and 120°F while the relative,humidity drops. The most important factor in condensing the '",ater vapor is the NSCVV temperature supplied to the coolers. This water is assumed to vary in temperature between 35°F and 95°F. With cold NSCIJV and the initial background leakage, a sensitivity of 1 gpm in appreximately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months can be achieved.

Since a leak in the primary system would result in reactor coolant flowing into the containment normal or reactor cavity sumps, leakage would be indicated by a level increase in the sump. Indication of incroasi ng sump level is transmittod from the sump to the control room level indicator by means of a sump lovel transmitter. The system provides measurements of low leakages by monitoring level increase versus time.

The detection capabilities of the containment normal sump and reactor cavity sump are shown in FSAR figure 5.2.5 1, assuming that the wator from tho loak is collectod in the sump. The actual reactor coolant leakage rate can be established from the increase above the normal rate of change of sump level. A check of other instrumentation

'Nould bo required to oliminato possible loakage from nonradioactjl,<e systems as a cause of an increase in sump lovol. Tho leakago rato can also be determined from the froquency of sump pump operation.

Under normal conditions, the containment normal and reactor cal/ity sump pumps operate '<'ery infrequently, Gross leakage can be surmised from unusual froquoncy ef pump operation. Sump lo',<el and pump running indication are provided in the control room to alort tho oporators.

The need to evaluate the severity of an alarm or an indication is important to the operators, and the ability to com are and veri with indications from other s stems is necessa.

instrument locations are utilized, if needed, to ensure that the transport delay time of the leakage from its source to an instrument location yields an acceptable overall response time.

(continued)

Vogtle Units 1 and 2 B 3.4.15-3 IRevision No. OJ

BASES APPLICABLE SAFETY ANALYSES (continued)

LCO amounts of unidentified LEAKAGE Insert 3 APPLICABILITY RCS Leakage Detection Instrumentation B 3.4.15 The safety significance of RCS LEAKAGE varies widely depending on its source, rate, and duration. Therefore, detecting and monitoring RCS LEAKAGE into the containment area is necessary. Quickly separating the identified LEAKAGE from the unidentified LEAKAGE provides quantitative information to the operators, allowing them to take corrective action should a leak occur detrimental to the safety of the unit and the public.

RCS leakage detection instrumentation satisfies Criterion 1 of 10 CFR 50.36 (c)(2)(ii).

tu:::t:=::;:=tt::r:xtif~4~~,tt:.r~: thg LCO requires instruments of diverse monitoring principles to be ERABLE to provide 18 high degree ofl confidence that lextreRlelV!

sma ~ are detected in time to allow actions to place the plant in a safe condition, when RCS LEAKAGE indicates possible RCPB degradation.

The LCO is satisfied when monitors of diverse measurement means are available. Thus, the containment sump monitors, in combination with a gaseous or particulate radioactivity monitor and/or a containment air cooler condensate flow rate monitor, provides an acceptable minimum.

Because of elevated RCS temperature and pressure in MODES 1, 2, 3, and 4, RCS leakage detection instrumentation is required to be OPERABLE.

In MODE 5 or 6, the temperature is to be ~ 200°F and pressure is maintained low or at atmospheric pressure. Since the temperatures and pressures are far lower than those for MODES 1, 2, 3, and 4, the likelihood of leakage and crack propagation are much smaller.

Therefore, the requirements of this LCO are not applicable in MODES 5 and 6.

Vogtle Units 1 and 2 B 3.4.15-4 IRe'!. 1 10lD11

RCS Leakage Detection Instrumentation B 3.4.15 BASES ACTIONS Insert 4 D.1 and D.2 (continued)

Provided a CHANNEL CHECK is performed every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or a water inventory balance is performed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , reactor operation may continue while awaiting restoration of the containment air cooler condensate flow rate monitor to OPERABLE status.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months interval provides periodic information that is adequate to detect RCS LEAKAGE.

With both required containment atmosphere gaseous and particulate radioactivity monitors and the required containment air cooler condensate flow rate monitor inoperable, the only means of detecting leakage is the containment sump monitor. This Condition does not provide the required diverse means of leakage detection. The Required Action is to restore either of the inoperable required monitors to OPERABLE status within 30 days to regain the intended leakage detection diversity. The 30 day Completion Time ensures that the plant will not be operated in a reduced configuration for a

,--_G---,r<~::dt~ G If a Required Action of Condition A, B, C, D, r annot be met, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an

,--_H_--,~. orderly manner and without challenging plant systems.

'l2u With all required leakage detection systems inoperable, no automatic means of monitoring leakage are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required. For the purpose of this Condition, the leakage (continued)

Vogtle Units 1 and 2 B 3.4.15-7 IRevision (!>lo. 01

BASES ACTIONS SURVEILLANCE REQUIREMENTS RCS Leakage Detection Instrumentation B 3.4.15

.1 (continued) detection systems consist of the three systems described below in items a, b, and c, respectively:

a.

The containment normal sumps level and reactor cavity sump monitors;

b.

One containment atmosphere radioactivity monitor (gaseous or particulate); and

c.

Either the containment air cooler condensate flow rate or a containment atmosphere gaseous or particulate radioactivity monitoring system not taken credit for in item b.

SR 3.4.15.1 and SR 3.4.15.2 These SRs require the performance of a CHANNEL CHECK of the required containment atmosphere radioactivity monitor and containment sump monitors. The check gives reasonable confidence that the channels are operating properly. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is based on instrument reliability and is reasonable for detecting off normal conditions.

SR 3.4.15.3 SR 3.4.15.3 requires the performance of a COT on the required containment atmosphere radioactivity monitor. The test ensures that the monitor can perform its function in the desired manner. The test verifies the alarm setpoint and relative accuracy of the instrument string. The Frequency of 92 days considers instrument reliability, and operating experience has shown that it is proper for detecting degradation.

SR 3.4.15.4, SR 3.4.15.5, and SR 3.4.15.6 These SRs require the performance of a CHANNEL CALIBRATION for each of the RCS leakage detection instrumentation channels. The calibration verifies the accuracy of the (continued)

Vogtle Units 1 and 2 B 3.4.15-8 IRevision No. 01

BASES SURVEILLANCE REQUIREMENTS REFERENCES RCS Leakage Detection Instrumentation B 3.4.15 SR 3.4.15.4. SR 3.4.15.5, and SR 3.4.15.6 (continued) instrument string, including the instruments located inside containment. The Frequency of 18 months is a typical refueling cycle and considers channel reliability. Again, operating experience has proven that this Frequency is acceptable.

1.

10 CFR 50, Appendix A, Section IV, GDC 30.

3.

FSAR, Subsection 5.2.5:-.----1 Regulatory Guide 1.45, Revision 0, "Reactor Coolant Pressure Boundary Leakage Detection Systems," May 1973.

Vogtle Units 1 and 2 B 3.4.15-9

Insert 2:

The containment normal or reactor cavity sumps can also be used to detect ReS leakage. Since a leak in the ReS would result in reactor coolant flowing into the containment normal or reactor cavity sumps, leakage would be indicated by a level increase in the sump. The actual reactor coolant leakage rate can be established from the increase above the normal rate of change of sump level. Indication of an increasing sump level is transmitted from the sump to the control room level indicator by means of a sump level transmitter. The system provides measurements of low leakages by monitoring level increase versus time. A check of other instrumentation would be required to eliminate possible leakage from nonradioactive systems as a cause of an increase in sump level.

The above-mentioned LEAKAGE detection systems differ in sensitivity and response time. Some of these systems could serve as early alarm systems signaling the operators that closer examination of other detection systems is necessary to determine the extent of any corrective action that may be required.

Insert 3:

The LeO requires three instruments to be OPERABLE.

The containment normal or reactor cavity sumps are used to collect unidentified LEAKAGE. The LeO requirements apply to the total amount of unidentified LEAKAGE collected in the containment normal and reactor cavity sumps. Since a leak in the primary system would result in reactor coolant flowing into the containment normal or reactor cavity sumps, leakage would be indicated by a level increase in the sumps.

Indication of an increasing sump level is transmitted from the sump to the control room level indicator by means of a sump level transmitter. The system provides measurements of low leakages by monitoring level increase versus time. The leakage rate can also be determined from the frequency of sump pump operation. Under normal conditions, the containment normal and reactor cavity sump pumps operate very infrequently. Gross leakage can be surmised from more frequent pump operation.

Sump level and pump running indications are provided in the control room to alert the operators.

The detection capabilities of the containment normal sump and reactor cavity sump are described in Reference 3. The identification of an increase in unidentified LEAKAGE will be delayed by the time required for the unidentified LEAKAGE to travel to the containment normal and reactor cavity sumps and it may take longer than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to detect a 1 gpm increase in unidentified LEAKAGE, depending on the origin and magnitude of the LEAKAGE. This sensitivity is acceptable for containment sump monitor OPERABILITY.

The reactor coolant contains radioactivity that, when ~eleased to the containment, may be detected by the gaseous or particulate containment atmosphere radioactivity monitor.

Only one of the two detectors is required to be OPERABLE. Radioactivity detection systems are included for monitoring both particulate and gaseous activities because of their sensitivities and rapid responses to ReS LEAKAGE, but have recognized limitations. Reactor coolant radioactivity levels will be low during initial reactor startup, following a refueling outage, and for a few weeks thereafter, until activated corrosion

products have been formed and fission products appear from fuel assembly cladding contamination or cladding defects. If there are few fuel assembly cladding defects and low levels of activation products, it may not be possible for the gaseous or particulate containment atmosphere radioactivity monitors to detect a 1 gpm increase within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months during normal operation. However, the gaseous or particulate containment atmosphere radioactivity monitor is OPERABLE when it is capable of detecting a 1 gpm increase in unidentified LEAKAGE within approximately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months given an RCS activity equivalent to that assumed in the design calculations for the monitors, as described in Reference 3.

An increase in humidity of the containment atmosphere could indicate the release of water vapor to the containment. The containment air cooler condensate flow rate system provides measurements of low leakages by monitoring a standpipe level increase versus time. Condensate flow from the containment air coolers is instrumented to detect when there is an increase above the normal value by 1 gpm. The time required to detect a 1 gpm increase above the normal value varies based on environmental and system conditions and may take longer than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . This sensitivity is acceptable for containment air cooler condensate flow rate monitor OPERABILITY.

Insert 4:

F.1, F.2.1, and F.2.2, With the required containment sump monitors and the required containment air cooler condensate flow rate monitor inoperable, the only means of detecting LEAKAGE is the required containment atmosphere radiation monitor. A Note clarifies that this Condition is applicable when the only OPERABLE monitor is the containment atmosphere gaseous radiation monitor. The containment atmosphere gaseous radioactivity monitor typically cannot detect a 1 gpm leak within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months when the RCS activity is low. In addition, this configuration does not provide the required diverse means of leakage detection. Indirect methods of monitoring RCS leakage must be implemented. Grab samples of the containment atmosphere must be taken to provide alternate periodic information. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval is sufficient to detect increasing RCS leakage. The Required Action provides 7 days to restore another RCS leakage monitor to OPERABLE status to regain the intended leakage detection diversity. The 7 day Completion Time ensures that the plant will not be operated in a degraded configuration for a lengthy time period.

Vogtle Electric Generating Plant License Amendment Request to Adopt TSTF-513-A, Revision 3 Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation Technical Specifications and Bases Clean Typed Pages

RCS Leakqge Detection Instrumentation 3.4.15 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E.

Required containment E.1 Restore required 30 days atmosphere radioactivity containment atmosphere monitor inoperable.

radioactivity monitor to OPERABLE status.

AND OR Required containment air cooler condensate E.2 Restore required 30 days flow rate monitor containment air cooler inoperable.

condensate flow rate monitor to OPERABLE status.

NOT E -------------

F.1 Analyze grab samples of Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Only applicable when a the containment containment atmosphere atmosphere.

gaseous radiation monitor is the only OPERABLE monitor.

AND F.2.1 Restore required 7 days F.

Required containment containment sump sump monitors monitors to OPERABLE inoperable.

status.

AND OR Required containment F.2.2 Restore required 7 days air cooler condensate containment air cooler flow rate monitor condensate flow rate inoperable.

monitor to OPERABLE status.

G.

Required Action and G.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

AND G.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

Vogtle Units 1 and 2 3.4.15-3 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

3.4.15 RCS Leakage Detection Instrumentation ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H.

All required leakage H.1 Enter LCO 3.0.3.

Immediately detection systems inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 Perform CHANNEL CHECK of containment 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months normal sumps level and reactor cavity sump level monitors.

SR 3.4.15.2 Perform CHANNEL CHECK of the required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months containment atmosphere radioactivity monitor.

SR 3.4.15.3 Perform COT of the required containment 92 days atmosphere radioactivity monitor.

SR 3.4.15.4 Perform CHANNEL CALIBRATION of the 18 months containment sump monitors.

SR 3.4.15.5 Perform CHANNEL CALIBRATION of the 18 months required containment atmosphere radioactivity monitor.

SR 3.4.15.6 Perform CHAN NEL CALIBRATION of the 18 months required containment air cooler condensate flow rate monitor.

Vogtle Units 1 and 2 3.4.15-4 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

RCS Leakage Detection Instrumentation B 3.4.15 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.15 RCS Leakage Detection Instrumentation BASES BACKGROUND GDC 30 of Appendix A to 10 CFR 50 (Ref. 1) requires means for detecting and, to the extent practical, identifying the location of the source of RCS LEAKAGE. Regulatory Guide 1.45, Revision 0 (Ref. 2) describes acceptable methods for selecting leakage detection systems.

Leakage detection systems must have the capability to detect significant reactor coolant pressure boundary (RCPB) degradation as soon after occurrence as practical to minimize the potential for propagation to a gross failure. Thus, an early indication or warning signal is necessary to permit proper evaluation of all unidentified LEAKAGE. In addition to meeting the OPERABILITY requirements, the monitors are typically set to provide the most sensitive response without causing an excessive number of spurious alarms.

Systems employed for detecting leakage to the containment from unidentified sources are:

Containment atmosphere airborne particulate radioactivity monitor;

Containment atmosphere gaseous radioactivity monitor;

Containment air cooler condensate flow monitor; and

Containment sump level monitor.

The containment airborne particulate radioactivity monitor draws an air sample from containment via a sample pump. The sample is then passed through a particulate filter with detectors. Particulate activity can be correlated with the coolant fission and corrosion product activities.

( continued)

Vogtle Units 1 and 2 B 3.4.15-1

BASES BACKGROUND (continued)

RCS Leakage Detection Instrumentation B 3.4.15 The containment atmosphere gaseous radioactivity monitor draws air continuously from the containment atmosphere through a gas monitor.

This sample stream Hows continuously through a fix shielded volume where its activity is monitored. Gaseous radioactivity can be correlated with the gaseous activity of the reactor coolant.

The containment air cooler condensate monitoring system permits measurement of the liquid runoff from the containment cooler units. It consists of a drain collection header, a vertical standpipe, valving, and standpipe level instrumentation for the coolers. The condensation from the containment coolers flows via the collection header to the vertical standpipe, and a differential pressure transmitter provides standpipe level signals. The system provides measurements of low leakages by monitoring standpipe level increase versus time.

Drainage flow rate from the cooling units due to normal condensation is calculated for the ambient (background) atmospheric conditions present within the containment. With the initiation of an additional or abnormal leak, the containment atmosphere humidity and condensation runoff rate both begin to increase, the water level rises in the vertical pipe, and the high condensate flow alarm is actuated.

The condensate flow rate is a function of containment humidity, nuclear service cooling water (NSCW) temperature, and containment purge rate.

The containment normal or reactor cavity sumps can also be used to detect RCS leakage. Since a leak in the RCS would result in reactor coolant flowing into the containment normal or reactor cavity sumps, leakage would be indicated by a level increase in the sump. The actual reactor coolant leakage rate can be established from the increase above the normal rate of change of sump level. Indication of an increasing sump level is transmitted from the sump to the control room level indicator by means of a sump level transmitter. The system provides measurements of low leakages by monitoring level increase versus time. A check of other instrumentation would be required to eliminate possible leakage from nonradioactive systems as a cause of an increase in sump level.

The above-mentioned LEAKAGE detection systems differ in sensitivity and response time. Some of these systems could serve as early alarm systems signaling the operators that closer examination of other detection systems is necessary to determine the extent of any corrective action that may be required.

Vogtle Units 1 and 2 B 3.4.15-2

BASES APPLICABLE SAFETY ANALYSES LCO RCS Leakage Detection Instrumentation B 3.4.15 The need to evaluate the severity of an alarm or an indication is important to the operators, and the ability to compare and verify with indications from other systems is necessary.

The safety significance of RCS LEAKAGE varies widely depending on its source, rate, and duration. Therefore, detecting and monitoring RCS LEAKAGE into the containment area is necessary. Quickly separating the identified LEAKAGE from the unidentified LEAKAGE provides quantitative information to the operators, allowing them to take corrective action should a leak occur detrimental to the safety of the unit and the public.

RCS leakage detection instrumentation satisfies Criterion 1 of 10 CFR 50.36 (c)(2)(ii).

This LCO requires instruments of diverse monitoring principles to be OPERABLE to provide confidence that small amounts of unidentified LEAKAGE are detected in time to allow actions to place the plant in a safe condition, when RCS LEAKAGE indicates possible RCPB degradation.

The LCO requires three instruments to be OPERABLE.

The containment normal or reactor cavity sumps are used to collect unidentified LEAKAGE. The LCO requirements apply to the total amount of unidentified LEAKAGE collected in the containment normal and reactor cavity sumps. Since a leak in the primary system would result in reactor coolant flowing into the containment normal or reactor cavity sumps, leakage would be indicated by a level increase in the sumps. Indication of an increasing sump level is transmitted from the sump to the control room level indicator by means of a sump level transmitter. The system provides measurements of low leakages by monitoring level increase versus time. The leakage rate can also be determined from the frequency of sump pump operation. Under normal conditions, the containment normal and reactor cavity sump pumps operate very infrequently. Gross leakage can be surmised from more frequent pump operation. Sump level and pump running indications are provided in the control room to alert the operators.

The detection capabilities of the containment normal sump and reactor cavity sump are described in Reference 3. The identification of an increase in unidentified LEAKAGE will be delayed by the time required for the unidentified LEAKAGE to travel to the containment normal and reactor cavity sumps and it may take longer than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to (continued)

Vogtle Units 1 and 2 B 3.4.15-3

RCS Leakage Detection Instrumentation B3.4.15 BASES LCO (continued) detect a 1 gpm increase in unidentified LEAKAGE, depending on the origin and magnitude of the LEAKAGE. This sensitivity is acceptable for containment sump monitor OPERABILITY.

The reactor coolant contains radioactivity that, when released to the containment, may be detected by the gaseous or particulate containment atmosphere radioactivity monitor. Only one of the two detectors is required to be OPERABLE. Radioactivity detection systems are included for monitoring both particulate and gaseous activities because of their sensitivities and rapid responses to RCS LEAKAGE, but have recognized limitations. Reactor coolant radioactivity levels will be low during initial reactor startup, following a refueling outage, and for a few weeks thereafter, until activated corrosion products have been formed and fission products appear from fuel assembly cladding contamination or cladding defects. If there are few fuel assembly cladding defects and low levels of activation products, it may not be possible for the gaseous or particulate containment atmosphere radioactivity monitors to detect a 1 gpm increase within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months during normal operation. However, the gaseous or particulate containment atmosphere radioactivity monitor is OPERABLE when it is capable of detecting a 1 gpm increase in unidentified LEAKAGE within approximately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months given an RCS activity equivalent to that assumed in the design calculations for the monitors, as described in Reference 3.

An increase in humidity of the containment atmosphere could indicate the release of water vapor to the containment. The containment air cooler condensate flow rate system provides measurements of low leakages by monitoring a standpipe level increase versus time.

Condensate flow from the containment air coolers is instrumented to detect when there is an increase above the normal value by 1 gpm.

The time required to detect a 1 gpm increase above the normal value varies based on environmental and system conditions and may take longer than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . This sensitivity is acceptable for containment air cooler condensate flow rate monitor OPERABILITY.

The LeO is satisfied when monitors of diverse measurement means are available. Thus, the containment sump monitors, in combination with a gaseous or particulate radioactivity monitor and/or a containment air cooler condensate flow rate monitor, provides an acceptable minimum.

( continued)

Vogtle Units 1 and 2 B 3.4.15-4

BASES (continued)

APPLICABILITY ACTIONS RCS Leakage Detection Instrumentation B 3.4.15 Because of elevated RCS temperature and pressure in MODES 1, 2, 3, and 4, RCS leakage detection instrumentation is required to be OPERABLE.

In MODE 5 or 6, the temperature is to be ~ 200°F and pressure is maintained low or at atmospheric pressure. Since the temperatures and pressures are far lower than those for MODES 1, 2, 3, and 4, the likelihood of leakage and crack propagation are much smaller.

Therefore, the requirements of this LCO are not applicable in MODES 5 and 6.

With one containment sump monitor inoperable, the remaining containment sump monitors, the containment atmosphere radioactivity monitor, and/or the containment air cooler condensate flow rate monitor will provide indications of changes in leakage. Together with these monitors, the periodic surveillance for RCS water inventory balance, SR 3.4.13.1, must be performed at an increased frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to provide information that is adequate to detect leakage.

B.1 and B.2 With two or more containment sump monitors inoperable, no other form of sampling or monitors can provide the equivalent information; however, the containment atmosphere radioactivity and/or containment air cooler condensate flow rate monitors will provide indications of changes in leakage. Together with these remaining monitors, the periodic surveillance for RCS water inventory balance, SR 3.4.13.1, must be performed at an increased frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to provide information that is adequate to detect leakage.

Restoration of at least two sump monitors to OPERABLE status within a Completion Time of 30 days is required to regain most of this function and allow operation to continue under the provisions of Condition A. This Completion Time is acceptable, considering the remaining OPERABLE atmosphere radioactivity and/or condensate flow rate monitors and the Frequency and adequacy of the RCS water inventory balance required by Action B.1.

(continued)

Vogtle Units 1 and 2 B 3.4.15-5

BASES ACTIONS (continued)

RCS Leakage Detection Instrumentation B3.4.15 C.1.1. C.1.2, C.2.1. and C.2.2 With both gaseous and particulate containment atmosphere radioactivity monitoring instrumentation channels inoperable, alternative action is required. Either grab samples of the containment atmosphere must be taken and analyzed or water inventory balances, in accordance with SR 3.4.13.1, must be performed to provide alternate periodic information.

With a sample obtained and analyzed or water inventory balance performed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the reactor may be operated for up to 30 days to allow restoration of the required containment atmosphere radioactivity monitors. Alternatively, continued operation is allowed if the air cooler condensate flow rate monitoring system is OPERABLE, provided grab samples are taken every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months interval provides periodic information that is adequate to detect leakage. The 30 day Completion Time recognizes at least one other form of leakage detection is available.

0.1 and 0.2 With the required containment air cooler condensate flow rate monitor inoperable, alternative action is again required. Either SR 3.4.15.2 must be performed or water inventory balances, in accordance with SR 3.4.13.1, must be performed to provide alternate periodic information.

Provided a CHANNEL CHECK is performed every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or a water inventory balance is performed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , reactor operation may continue while awaiting restoration of the containment air cooler condensate flow rate monitor to OPERABLE status.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months interval provides periodic information that is adequate to detect RCS LEAKAGE.

E.1 and E.2 With both required containment atmosphere gaseous and particulate radioactivity monitors and the required containment air cooler condensate flow rate monitor inoperable, the only means of detecting leakage is the containment sump monitor. This Condition does not provide the required diverse means of leakage detection. The Required Action is to restore either of the inoperable required (continued)

Vogtle Units 1 and 2 B 3.4.15-6

BASES ACTIONS RCS Leakage Detection Instrumentation B 3.4.15

[,1 and E.2 (continued) monitors to OPERABLE status within 30 days to regain the intended leakage detection diversity. The 30 day Completion Time ensures that the plant will not be operated in a reduced configuration for a lengthy time period.

F.1. F.2.1. and F.2.2 With the required containment sump monitors and the required containment air cooler condensate flow rate monitor inoperable, the only means of detecting LEAKAGE is the required containment atmosphere radiation monitor. A Note clarifies that this Condition is applicable when the only OPERABLE monitor is the containment atmosphere gaseous radiation monitor. The containment atmosphere gaseous radioactivity monitor typically cannot detect a 1 gpm leak within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months when the RCS activity is low. In addition, this configuration does not provide the required diverse means of leakage detection. Indirect methods of monitoring RCS leakage must be implemented. Grab samples of the containment atmosphere must be taken to provide alternate periodic information. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interval is sufficient to detect increasing RCS leakage. The Required Action provides 7 days to restore another RCS leakage monitor to OPERABLE status to regain the intended leakage detection diversity.

The 7 day Completion Time ensures that the plant will not be operated in a degraded configuration for a lengthy time period.

G.1 and G.2 If a Required Action of Condition A, B, C, D, E, or F cannot be met, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

With all required leakage detection systems inoperable, no automatic means of monitoring leakage are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required. For the purpose of this Condition, the leakage (continued)

Vogtle Units 1 and 2 B3.4.15-7

BASES ACTIONS SURVEILLANCE REQUIREMENTS RCS Leakage Detection Instrumentation B 3.4.15 H.1 (continued) detection systems consist of the three systems described below in items a, b, and c, respectively:

a.

The containment normal sumps level and reactor cavity sump monitors;

b.

One containment atmosphere radioactivity monitor (gaseous or particulate); and

c.

Either the containment air cooler condensate flow rate or a containment atmosphere gaseous or particulate radioactivity monitoring system not taken credit for in item b.

SR 3.4.15.1 and SR 3.4.15.2 These SRs require the performance of a CHANNEL CHECK of the required containment atmosphere radioactivity monitor and containment sump monitors. The check gives reasonable confidence that the channels are operating properly. The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is based on instrument reliability and is reasonable for detecting off normal conditions.

SR 3.4.15.3 SR 3.4.15.3 requires the performance of a COT on the required containment atmosphere radioactivity monitor. The test ensures that the monitor can perform its function in the desired manner. The test verifies the alarm setpoint and relative accuracy of the instrument string. The Frequency of 92 days considers instrument reliability, and operating experience has shown that it is proper for detecting degradation.

SR 3.4.15.4, SR 3.4.15.5. and SR 3.4.15.6 These SRs require the performance of a CHANNEL CALIBRATION for each of the RCS leakage detection instrumentation channels. The calibration verifies the accuracy of the

( continued)

Vogtle Units 1 and 2 B 3.4.15-8

BASES SURVEILLANCE REQUIREMENTS REFERENCES RCS Leakage Detection Instrumentation B3.4.15 SR 3.4.15.4, SR 3.4.15.5, and SR 3.4.15.6 (continued) instrument string, including the instruments located inside containment. The Frequency of 18 months is a typical refueling cycle and considers channel reliability. Again, operating experience has proven that this Frequency is acceptable.

1.

10 CFR 50, Appendix A, Section IV, GDC 30.

2.

Regulatory Guide 1.45, Revision 0, "Reactor Coolant Pressure Boundary Leakage Detection Systems," May 1973.

3.

FSAR, Subsection 5.2.5.

Vogtle Units 1 and 2 B 3.4.15-9

v t e Letter Sequence Request
TAC:ME6144, Revise Operability Requirements and Actions for RCS Leakage Instrumentation (Approved, Closed)
Initiation Request Acceptance... Administration Questions Answers Results Approval Other:
MONTHYEAR2011-11-10 [Table View]

NL-11-0675, License Amendment Request to Adopt TSTF-513-A, Rev. 3, Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation

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NL-11-0675, License Amendment Request to Adopt TSTF-513-A, Rev. 3, Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation

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