NL-15-1739, Response to Request for Additional Information Regarding SNC License Amendment Request for TSTF-523, Revision 2

Response to Request for Additional Information Regarding SNC License Amendment Request for TSTF-523, Revision 2

ML15264A738
Person / Time
Site:	Vogtle
Issue date:	09/21/2015
From:	Pierce C Southern Co, Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-15-1739, TAC MF6213, TAC MF6214, TSTF-523, Rev. 2
Download: ML15264A738 (11)

Text

Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7872 SOUTHERN << \

Fax 205 .992.7601 NUCLEAR A SOUTHERN COM PANY SEP 2 1 20f5 Docket Nos.: 50-424 NL-15-1739 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant- Units 1 and 2 Response to Request for Additional Information Regarding SNC License Amendment Request for TSTF-523. Revision 2

References:

1. SNC Letter NL-14-1349, Edwin I. Hatch Nuclear Plant- Units 1 and 2 License Amendm ent Request to Revise Technical Specifications Regarding Generic Letter 2008-01, Managing Gas Accumulation in accordance with TSTF-523, Revision 2, Using the Consolidated Line Item Improvement Process (CLIIP), dated May 12, 2015.

2. NRC Letter, Vogtle Electric Generating Plant, Units 1 and 2- Request for Additiona l Information on License Amendm ent Request(TAC NOS. MF6213 AND MF6214),

dated August 24, 2015.

Ladies and Gentlemen:

On May 12, 2015, in accordance with the provisions of 10 CFR 50.90 Southern Nuclear Operating Company (SNC) submitted a request for an amendment to the technical specifications (TS) for Vogtle Electric Generating Plant (VEGP), Units 1 and 2 (Reference 1).

The proposed amendment would modify TS requirements related to Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray systems," as described in TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation."

Following the submittal of the VEGP License Amendm ent Request, SNC received a request for additional information by the NRC on August 24, 2015 (Reference 2). provides the requested information. Enclosure 2 provides the replacement pages for the affected LAR VEGP Technical Specification Marked Up Pages. Enclosure 3 provides the replacement pages for the affected LAR VEGP Technical Specification Clean Typed Pages.

U.S. Nuclear Regulatory Commission NL-15-1739 Page2 This letter contains no new NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.

Mr. C. R. Pierce states he is Regulatory Affairs 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.

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CRP/GLS/Iac Sworn to and subscribed before me this J-..1 day of '2015.

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Enclosures:

1. Response to Request for Additional Information- TSTF-523

2. VEGP Technical Specification Marked Up Replacement Pages

3. VEGP Technical Specification Clean Typed Replacement Pages cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. B. K. Taber, Vice President- Vogtle 1 & 2 Mr. D. R. Madison, Vice President - Fleet Operations Mr. B. J. Adams, Vice President - Engineering Mr. G. W. Gunn, Regulatory Affairs Manager- Vogtle 1 & 2 RType: CVC7000 U.S. Nuclear Regulatorv Commission Mr. V. M. McCree, Regional Administrator Mr. L. D. Wert, Regional Administrator (Acting)

Mr. R. E. Martin, NRR Senior Project Manager- Vogtle 1 & 2 Mr. L. M. Cain, Senior Resident Inspector- Vogtle 1 & 2 State of Georgia Mr. J. H. Turner, Director- Environmental Protection Division

Vogtle Electric Generating Plant- Units 1 and 2 Response to Request for Additional Information Regarding SNC License Amendment Request for TSTF-523. Revision 2 Enclosure 1 Response to Request for Additional Information - TSTF-523

Enclosure to NL-15-1739 Response to Request for Additional Informatio n- TSTF-523 Page E-1 The NRC staff has reviewed the Vogtle Electric Generating Plant, Units 1 and 2 license amendme nt request and determined that additional information is necessary as noted below.

RAI No.1 SNC stated in its May 12, 2015, application that the proposed amendment was consistent with TSTF-523, Revision 2. In Enclosure 1 of the submittal, Surveillance Requirement 3.9.6.2 uses the phrase "Verify required [residual heat removal] AHA loop locations... " versus the approved TSTF wording, "Verify AHA loop locations .... " The wording in the submittal is inconsistent with TSTF-523 and Limiting Condition for Operation (LCO) 3.9.6, which specifies that two RHR loops shall be OPERABLE.

Revise the submittal to use the wording that is consistent with the approved TSTF-523 and LCO 3.9.6 or provide a technical justification for the deviation.

SNC Response to RA1:

Upon further review of the SNC LARin the original letter, NL-15-0422, SA's 3.4.8.4 and 3.9.6.2 need to be amended to provide consistency with the TSTF-523, Revision 2 traveler.

The new Surveillance Requirements (SA's) 3.4.8.4 and 3.9.6.2 will remove the word "required" to ensure consistency with TSTF-523, Revision 2. The SA's will now use the approved verbiage "Verify AHA loop locations susceptible to gas accumulation are sufficiently filled with water." Enclosure 2 will include the pages to replace in the LAR for VEGP Technical Specification Marked Up Pages sent in the original SNC letter NL-15-0422. will include the pages to replace in the LAR for the VEGP Technical Specification Clean Typed Pages sent in the original SNC letter NL-15-0422. This change ensures that the proposed amendment is now consistent with TSTF-523, Revision 2.

Vogtle Electric Generating Plant- Units 1 and 2 Response to Request for Additional Information Regarding SNC License Amendment Request for TSTF-523. Revision 2 Enclosure 2 VEGP Technical Specification Marked Up Replacement Pages

Enclosure 2 to NL-15-0422 VEGP Technical Specification Ma!Ked Up Pages RCS Loops - fv10DE 5, Loops Not Filled 3.4.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR loop inoperable. A.1 Initiate action to restore Immediately RHR loop to OPERABLE status.

B. Required RHR loops B.1 Suspend all operations Immediately inoperable. involving reduction in RCS boron concentration.

OR AND No RHR loop in operation.

B.2 Initiate action to restore Immediately one RHR loop to OPERABLE status and to operation.

C. One or more valves used C.1 Initiate action to secure Immediately to isolate unborated water valve(s) in closed sources not secured in position.

closed position.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR loop is in operation. In accordance with the Surveillance Frequency Control Program SR 3.4.8.2 Verify correct breaker alignment and indicated povver In accordance with the are available to the required RHR pump that is not Surveillance Frequency Control Program SR 3.4.8.3 Verify each valve that isolates unborated water In accordance with the sources is secured in the closed position. Surveillance Frequency Control Program

~ Insert SR 3.4.8.4 located on next page I Vogtle Units 1 and 2 3.4.8-2 Amendment No. 400 (Unit 1)

Amendment No. 00 Unit 2)

E2-3

Enclosure 2 to NL-15-0422 VEGP Technical Specification Marked Up Pages

/ Insert as SR 3.4.8.4 SR 3.4.8.4 Verify RHR loop locations susceptible to gas In accordance with the accumulation are sufficiently filled with water. Surveillance Frequency Control Program E2-4 to NL-15-0422 VEGP Technical Specification Ma!Ked Up Pages RHR and Coolant Circulation- Low Water Level 3.9.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) 8.2 Initiate action to restore Immediately one RHR loop to operation.

AND 8.3 Close all containment 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> penetrations providing direct access from containment atmosphere to outside atmosphere.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 Verifyone RHR loop is in operation and circulating In accordance with reactor coolant at a flow rate of~ 3000 gpm. the Surveillance Frequency Control t

Program I

SR 3.9.6.2 Verify RHR loop locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.9.6-2 Amendment No. +58 (Unit 1)

Amendment No. +4G (Unit 2)

E2-9

Vogtle Electric Generating Plant- Units 1 and 2 Response to Request for Additional Information Regarding SNC License Amendment Request for TSTF-523, Revision 2 Enclosure 3 VEGP Technical Specification Clean Typed Replacement Pages

RCS Loops - MODE 5, Loops Not Filled 3.4.8 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.8.4 Verify RHR loop locations susceptible to gas In accordance with the accumulation are sufficiently filled with water. Surveillance Frequency Control Program Vogtle Units 1 and 2 3.4.8-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

RHR and Coolant Circulation- Low Water Level 3.9.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) 8.2 Initiate action to restore Immediately one RHR loop to operation.

AND 8.3 Close all containment 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> penetrations providing direct access from containment atmosphere to outside atmosphere.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 Verify one RHR loop is in operation and circulating In accordance with reactor coolant at a flow rate of~ 3000 gpm. the Surveillance Frequency Control Program SR 3.9.6.2 Verify RHR loop locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.9.6-2 Amendment No. (Unit 1)

Amendment No. (Unit 2)