Text

Response to Request for Additional Information Regarding Adoption of TSTF-432-A, Rev. 1, Change in Technical Specifications End States (WCAP-16294), Using the Consolidated Line Item Improvement Process
	ML15281A179
Person / Time
Site:	Vogtle
Issue date:	10/08/2015
From:	Pierce C; Southern Co, Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-15-1882, TSTF-432-A, Rev. 1
	Download: ML15281A179 (27)
	v • d • e

Charles R. Pierce Regulatory Affairs Director Ott ll 8 2015 Docket Nos.: 50-424 50-425 Southern Nuclear Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7872 Fax 205.992.7601 U. S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, D. C. 20555-0001 SOUTHERN*\\

NUCLEAR A SOUTHERN COMPANY NL-15-1882 Vogtle Electric Generating Plant, Units 1 & 2 Response to Request for Additional Information Regarding Adoption of TSTF-432-A, Rev. 1 "Change in Technical Specifications End States (WCAP-16294),

Using the Consolidated Line Item Improvement Process" Ladies and Gentlemen:

By letter dated May 6, 2015 (Agencywide Documents Access and Management System [ADAMS] Accession No. ML15128A239), Southern Nuclear Operating Company (SNC) submitted a license amendment request (LAR) to adopt the Technical Specifications changes identified in Technical Specification Task Force Traveler 432-A, Rev. 1 "Change in Technical Specifications End States, WCAP-16294."

By letter dated September 8, 2015 (ADAMS Accession No. ML15240A232), the Nuclear Regulatory Commission (NRC) sent SNC a request for additional information (RAI). Enclosure 1 provides the SNC response to the NRC RAI.

Additionally, SNC proposes to revise the Technical Specifications and Bases pages submitted as part of the LAR, as provided in Enclosures 2 and 3 of this letter.

This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.

U.S. Nuclear Regulatory Commission NL-15-1882 Page2 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.

Respectfulll'fbmitted, t.t~*

C. R. Pierce Regulatory Affairs Director CRP/EGA Sworn to and subscribed before me this _1!:._ day of_{O=...;c__p=----' 2015.

My commission expires: /0..... Z, lcJ tl Enclosures 1. SNC Response to NRC RAI

2. Mark-up of Technical Specifications and Bases Pages

3. Clean-typed Technical Specifications Pages cc:

Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. D. R. Madison, Vice President-Fleet Operations Mr. M. D. Meier, Vice President-Regulatory Affairs Mr. B. K. Taber, Vice President-Vogtle 1 & 2 Mr. B. J. Adams, Vice President-Engineering Mr. G. W. Gunn, Regulatory Aff~irs Manager-Vogtle 1 & 2 RType: CVC7000 U. S. Nuclear Regulatory 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

Vogtle Electric Generating Plant-Units 1 and 2 Response to Request for Additional Information Regarding Adoption of TSTF-432-A, Rev. 1 "Change in Technical Specifications End States {WCAP-16294),

Using the Consolidated Line Item Improvement Process" SNC Response to NRC RAI to NL-15-1882 SNC Response to NRC RAJ By letter dated May 6, 2015 (Agencywide Documents Access and Management System

[ADAMS] Accession No. ML15128A239), Southern Nuclear Operating Company (SNC) submitted a license amendment request (LAR) to adopt the Technical Specifications changes identified in Technical Specification Task Force (TSTF) Traveler 432-A, Rev. 1, "Change in Technical Specifications End States, WCAP-16294." By letter dated September 8, 2015, the Nuclear Regulatory Commission (NRC) sent SNC a request for additional information (RAJ).

This enclosure provides the SNC response to the NRC RAI.

NRC Request for Additional Information:

Discussion:

The U.S. Nuclear Regulatory Commission (NRC) staff's review of the licensee's application determined that the proposed end state change forTS Limiting Conditions for Operation (LCO) 3.7.10, "Control Room Emergency Filtration System (CREFS)- Both Units Operating," and TS LCO 3. 7.11, "CREFS -One Unit Operating," are not consistent with the approved TSTF-432 changes as explained below:

LCOs 3.7.10, Condition D and LCO 3.7.11 Condition F relate to a loss of both or one or more of CREFS trains due to inoperable control room envelope (CRE) boundary.

Conditions A, Band C in LCO 3.7.10 and Conditions A thru E in LCO 3.7.11 relate to a loss of both or one or more trains for reasons other than Condition D or F, respectively.

Required Action F.3 in LCO 3.7.10 or H.2 in LCO 3.7.11 currently places the unit in MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months or 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , respectively, when Required Action and associated Completion Time (for all Conditions) not met. The licensee's proposed end state change is to be in Mode 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for these Required Actions.

The NRC staff's approved safety evaluation (ADAMS Accession No. ML100770146, dated March 29, 2010) as well as the TSTF-432, Revision 1, dated November 29, 2010 (ADAMS Accession No. ML103360003) justify an end state allowance for a loss of one or two CREFS trains due to inoperable control room envelope boundary in MODE 1. 2. 3. or 4. The proposed end state change to Required Action F.3 or H.2, if approved, would apply to all subject LCOs Conditions including those which are not associated with an inoperable CRE boundary, whereas, the TSTF allows the end state allowance specifically for a Condition associated with an inoperable CRE boundary only. Hence, the proposed change is not consistent with the approved TSTF-432 change.

Furthermore, Standard Technical Specifications (NUREG-1431, Revision 4), LCO 3.7.10, Condition F, Required Action F.1 requires to enter LCO 3.0.3 when two CREFS trains are inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B. (Condition B relates to a loss of one or more CREFS trains due to inoperable CRE boundary in MODE 1, 2, 3, or 4.)

Request for Additional Information:

The NRC staff requests the licensee to revise its proposed end state change to be consistent with the approved TSTF-432, or provide technical basis for the subject change as currently proposed in the application.

E1-1 to NL-15-1882 SNC Response to NRC RAI SNC Response to the Request for Addltlonallnfonnatlon:

The changes in TSTF-432-A, Rev. 1 for Revision 3.0 of the Improved Standard Technical Specification (ISTS) 3.7.10, Control Room Emergency Filtration System (CREFS), provides a revised end state for ISTS 3.7.10, Condition C when the Required Action and Completion Time of Condition A orB are not met. ISTS 3.7.10, Condition A involves situations where one CREFS train is inoperable, and ISTS 3. 7.1 0, Condition B involves situations where two (both)

CREFS trains are inoperable due to an inoperable control room boundary. The revised end state condition would allow the unit to be placed in a MODE where overall plant risk is reduced (MODE 4) instead of requiring that the unit be placed in a MODE where the where the Limiting Condition for Operability (LCO) is no longer applicable (MODE 5).

The changes identified in TSTF-432 for ISTS 3.7.10 are applicable to Vogtle Technical Specifications (TS) 3. 7.1 0 and 3. 7.11, and are proposed with the following variances and differences.

The CREFS design that is assumed in ISTS 3.7.10 and TSTF-432 consists of two independent, redundant trains, each of which is capable of pressurizing the control room and maintaining habitability within the control room envelope (CRE). The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. Requirements for operability of the CRE are included in the CREFS operability requirements of ISTS 3. 7.1 0. The two train CREFS design and shared CRE that is assumed in ISTS 3.7.10 and TSTF-432 is typical for dual unit Westinghouse plants.

The Vogtle CREFS design has a total of four redundant, completely independent, full capacity CREFS trains that recirculate and filter the air in the common Unit 1 and 2 CRE. The CREFS trains for Unit 1 are powered from Unit 1 safety buses A and B, and the CREFS trains for Unit 2 are powered from Unit 2 safety buses A and B. Operability of the CRE is included in the CREFS operability requirements of Vogtle TS 3.7.10, "Control Room Emergency Filtration System (CREFS)- Both Units Operating," and 3. 7.11, "Control Room Emergency Filtration System (CREFS)- One Unit Operating." The increased redundancy provided by the four train Vogtle CREFS design is reflected in the Conditions and Required Actions of Vogtle TS 3. 7.10 and 3.7.11.

ISTS 3.7.10, Condition A applies in situations where one CREFS train is inoperable in MODES 1, 2, 3, or 4. In this Condition, the remaining OPERABLE CREFS train is adequate to perform the control room protection function. However, overall reliability is reduced because a single failure in the OPERABLE CREFS train could result in loss of the CREFS function.

ISTS 3.7.10, Condition A applies to CREFS train inoperability due to: 1) an inoperable CRE boundary, or 2) causes other than an inoperable CRE boundary. The Required Action and Completion Time for ISTS 3.7.10, Condition A is to restore the inoperable CREFS train within 7 days.

Vogtle TS 3.7.10, Condition A, and Vogtle TS 3.7.11, Conditions A and B, apply when one CREFS train is inoperable for reasons other than an inoperable CRE boundary. With a single CREFS train inoperable for reasons other than an inoperable CRE boundary, one train of CREFS in the unaffected unit must be placed in the emergency mode of operation within 7 days. In this condition, the remaining operable CREFS train for the affected unit is adequate to perform the CRE occupant protection function. However, overall reliability is reduced because a failure in the operable CREFS train could result in a loss of the CREFS function for the affected

. E1-2 to NL-15-1882 SNC Response to NRC RAI unit. Placing one CREFS train in the unaffected unit in the emergency mode of operation ensures the CRE occupants remain protected for postulated accidents and single failure conditions.

Vogtle TS 3. 7.1 0, Condition B, and Vogtle TS 3. 7.11, Condition C, apply when one CREFS train is inoperable in each.unit for reasons other than an inoperable CRE boundary. With one CREFS train inoperable in each unit for reasons other than an inoperable CRE boundary, the two remaining operable CREFS trains must be placed in the emergency mode of operation within 7 days. In this condition, the remaining operable CREFS trains are adequate to perform the CRE occupant protection function for each unit. However, overall reliability is reduced because a failure in one of the operable CREFS trains could result in a loss of the CREFS function for the affected unit. Placing one CREFS train in the emergency mode of operation in each unit ensures the CRE occupants remain protected for postulated accidents and single failure conditions.

For conditions involving inoperability of a single CREFS train for reasons other than an inoperable CRE boundary, or inoperability of one CREFS train in each unit for reasons other than an inoperable CRE boundary, the Required Actions and Completion Times of Vogtle TS 3.7.10, Conditions A and B, and Vogtle TS 3.7.11, Conditions A, B, and C, are equivalent to the Required Action and Completion Time of ISTS 3.7.10, Condition A. ISTS 3.7.10, Condition A requires restoration of an inoperable CREFS train within 7 days, and Vogtle TS

3. 7.1 0, Conditions A and B, and Vogtle TS 3. 7.11, Conditions A, B, and C, require that the CREFS train in the unaffected unit be placed in the emergency mode of operation within 7 days.

These Required Actions and Completion Times are equivalent because in each case the Required Action ensures the CRE occupants remain protected for postulated accidents and eliminates single failure vulnerability of the CREFS safety function within the same time frame.

The differences in the Required Actions between ISTS 3.7.10, Condition A and Vogtle TS 3.7.10, Conditions A and B, and Vogtle TS 3.7.11, Conditions A, B, and C, reflect plant-specific differences in the Vogtle Unit 1 and 2 CREFS design that do not adversely affect applicability of the end state changes identified in TSTF-432 forVogtle TS 3.7.10 and 3.7.11.

With respect to inoperability of a CREFS train due to an inoperable CRE boundary, inoperability of a single CREFS train due to an inoperable CRE boundary is addressed in ISTS 3.7.10, Condition A, and inoperability of two (both) CREFS trains due to an inoperable CRE boundary is addressed in ISTS 3.7.10, Condition B. The revised end state conditions ofTSTF-432 are applicable to ISTS 3.7.10, Conditions A and B.

lnoperability of one or more CREFS trains due to an inoperable CRE boundary is collectively addressed in Vogtle TS 3.7.10, Condition D, and Vogtle TS 3.7.11, Condition F. The combined presentation of Required Actions and Completion Times in Vogtle TS 3.7.10, Condition D, and Vogtle TS 3.7.11, Condition F, reflects changes that were made with the adoption of TSTF-448 in license amendments 154 and 135 for Vogtle Units 1 and 2 (NRC ADAMS Accession No. ML082480712). The changes in TSTF-448 also included adoption of a Control Room Envelope Habitability Program. Adoption of the end state changes from TSTF-432 for Vogtle TS 3.7.10, Condition D, and Vogtle TS 3. 7.11, Condition F is consistent with the intent of TSTF-432, which is to place the unit in a MODE where overall plant risk is reduced if the CRE boundary is inoperable and cannot be restored within the required Completion Time. Remaining within the Applicability of the LCO is acceptable to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5.

E1-3 to NL-15-1882 SNC Response to NRC RAI Additionally, Completion Times of 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months and 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months are proposed for the Required Actions of Vogtle TS 3.7.10, Condition F to place the affected unit(s) in MODE 3 and MODE 4, respectively. The 7 hour8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months Completion Time to place the affected unit(s) in MODE 3 is consistent with the Completion Time that is currently reflected in the plant Technical Specifications for Required Action F.2, and the 13 hour1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months Completion Time that is proposed for Required Action F.3 (i.e., 6 additional hours) is reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems. This difference does not adversely affect the applicability or intent of the end state changes identified in TSTF-432 for Vogtle TS 3.7.10, Condition F.

The proposed Technical Specification and Bases changes for Vogtle TS 3.7.10 are revised to separate Condition F into two separate conditions and create a new Condition G. The revised Condition F will apply to situations involving the "Required Action and Associated Completion Time of Condition A, B, or D not met." Conditions A, B, and D apply to situations involving inoperability of a single CREFS train in one or both units for reasons other than an inoperable CRE boundary, and to situations involving inoperability of one or more CREFS trains due to an inoperable CRE boundary. These conditions are equivalent to those identified in ISTS 3.7.10, Conditions A and B, and the end state changes of TSTF-432-A are applied to the revised Condition F. Conforming changes to the Note for Required Action F.1 are made to reflect the applicable Conditions under which Condition F applies.

For those Conditions in Vogtle TS 3. 7.10 that the revised end states changes of TSTF-432 are not applicable, the existing requirements of Vogtle TS 3. 7.1 0, Condition F are provided in a new Condition G. Condition G will apply to situations involving the "Required Action and Associated Completion Time of Condition CorE not met." Vogtle TS 3.7.10, Condition Cis applicable to situations where two CREFS trains are inoperable for a single unit for reasons other than an inoperable CRE boundary, and ConditionE pertains to control room air temperature not within limits. Neither of these Conditions is included within the scope of TSTF-432. The Required Actions and Completion Times in new Condition G are unchanged from the existing Condition F.

Conforming changes to the Note for Required Action G.1 are made to reflect the applicable Conditions under which Condition G applies.

The proposed Technical Specification and Bases changes for Vogtle TS 3.7.11 are revised to separate Condition H into two separate conditions and create a new Condition I. The revised Condition H will apply to situations involving the "Required Action and Associated Completion Time of Condition A, B, C, or F not met." Conditions A, B, C, or F apply to situations involving inoperability of a single CREFS train in one or both units for reasons other than an inoperable CRE boundary, and to situations involving inoperability of one or more CREFS trains due to an inoperable CRE boundary. These conditions are equivalent to those identified in ISTS 3.7.10, Conditions A and B, and the end state changes of TSTF-432-A are applied to the revised Condition H.

For those Conditions in Vogtle TS 3. 7.11 that the revised end states changes of TSTF-432 are not applicable, the existing requirements of Vogtle TS 3.7.11, Condition H are provided as a new Condition I. Condition I will apply to situations involving the "Required Action and Associated Completion Time of Condition D, E or G not met." Vogtle TS 3.7.10, Conditions D and E are applicable to situations where two CREFS trains are inoperable for a single unit for reasons other than an inoperable CRE boundary, and Condition G pertains to control room air temperature not within limits. None of these Conditions are included within the scope of TSTF-432. The Required Actions and Completion Times in new Condition I are unchanged from the existing Condition H.

E1-4

Vogtle Electric Generating Plant-Units 1 and 2 Response to Request for Additional Information Regarding Adoption of TSTF-432-A, Rev. 1 "Change in Technical Specifications End States (WCAP-16294),

Using the Consolidated Line Item Improvement Procesl)"

Mark-up of Technical Specifications and Bases Pages

ACTIONS (continued)

CONDITION F.

Required Action and associated Completion Time not met.

of Condition A, 8, or D INSERT - TS 3.7.10 Condition G Vogtle Units 1 and 2 F.1 CREFS - Both Units Operating 3.7.10 REQUIRED ACTION

NOTE-------

Required Action F.1 is not applicable when entering this Condition from Condition Br:::J+=Af=l=l or D COMPLETION TIME Lock closed the outside 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months air (OSA) intake dampers of the affected unit and lock open the OSA intake dampers of the unaffected unit.

F.2 Place the affected units(s) 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months in MODE 3.

AND F.3 Place the affected unit(s)

nM~

NOTE--------------

LCO 3.0.4.a is not

--iapplicable when entering MODE 4.

3.7.10-3 Amendment No. 154 (Unit 1)

Amendment No. 135 (Unit 2)

CONDITION G. Required Action and associated Completion Time of Condition C or E not met.

TS 3. 7.1 0 - Condition G Insert REQUIRED ACTION G.1 NOTE------

Required Action G.1 is not applicable when entering this Condition from Condition E.

COMPLETION TIME Lock closed the outside air 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (OSA) intake dampers of the affected unit and lock open the OSA intake dampers of the unaffected unit.

G.2 Place the affected units(s) in MODE3.

G.3 Place the affected unit(s) in MODES.

7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months 37 hours

BASES ACTIONS Vogtle Units 1 and 2 D.1 (continued)

CREFS -

Both Units Operating B 3.7.10 that CRE occupants are protected from hazardous chemicals and smoke. These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions.

The 90 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

With the CRE air temperature outside its limit, action must be taken to restore the air temperature to within the limit within 7 days. If the CRE air temperature exceeds its limit, the ability of a single train of CREFS to maintain CRE temperature after a CRI may be affected. The completion time of 7 days is reasonable considering the number of CREFS trains available to perform the required temperature control function and the low probability of an event occurring that would require the CREFS operation during that time.

F.1. F.2. and F.3 If the Required Actions an Conditions A, B, are not met action must be taken to place the unit in a condition ~~~~~~~~~~~~~

pre no longer required!. Locking closed the outside air (OSA) dampers in the affected unit and locking open the OSA dampers in the unaffected unit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , ensure that all CRE air intake is monitored by redundant radiogas monitors that actuate OPERABLE CREFS trains. The affected unit(s) must also be placed in MODE 3 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and M~ithin (continued)

B 3.7.10-7 Rev. 3-11/08

BASES ACTIONS overall plant risk is reduced INSERT BASES 3.7.10 Condition F, Change 1 INSERT BASES 3.7.10 Condition F, Change 2 SURVEILLANCE REQUIREMENTS Vogtle Units 1 and 2 CREFS -

Both Units Operating B3.7.10 F.1. F.2. and F.~ (conti~

, ~hG~~~~~~~i;r~~Jt:r~

tr~ ':::td':ilft:f. '

These actions ensure that if the CRE occupants cannot be protected from all postulated accident and single failure conditions, the unit or units are placed in a MODE where the The allowed Completion Times are reasonable, based on oper: mg experience, to perform the Required Actions and to rea the required unit conditions from full power conditions in an rderly manner without challenging unit systems.

B and D B and D Required Action F.1 is edified by a Note that e epts Conditions,,

. Conditions,,

ffect both units, and Required Action F.1 is based on a single affected unit.

Therefore, upon entry into Condition F from Condition~

only Required Actions F.2 and F.3 apply.

B or D

~==:::::::::JINSERT BASES SR 3_ 7 _1 o.1lCond1t1on G The CREFS is required to maintain the CRE temperature s 85°F in the event of a CRI. The maintenance of the CRE below this temperature ensures the operational requirements of equipment located in the CRE will not be exceeded. To accomplish this function, the CREFS air flow is directed through cooling coils which are supplied by the Essential Chilled Water System. The design cooling capacity of the CREFS and the limitation of the normal CRE ambient temperature (before CRI) ensure the capability of the CREFS to maintain the CRE temperature within limit after a CRI. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.10.2 Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not too severe, testing each train once every month provides an adequate check of this system.

Monthly operations with the heater control circuit energized allows the heaters to operate as necessary to reduce the humidity in the (continued)

B 3.7.10-8 REVISION 14

INSERT - Bases 3. 7.10 Condition F, Change 1 Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 8). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 8, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

INSERT-Bases 3.7.10 Condition F, Change 2 Required Action F.3 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

INSERT-Bases 3.7.10 Condition G G.1. G.2. and G.3 If the Required Actions and associated Completion Times of Conditions C or E are not met, action must be taken to place the unit in a condition where the inoperable CREFS train(s) are no longer required. Locking closed the outside air (OSA) dampers in the affected unit and locking open the OSA dampers in the unaffected unit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , ensures that all CRE air intake is monitored by redundant radiogas monitors that actuate OPERABLE CREFS trains. The affected unit(s) must also be placed in MODE 3 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within the following 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , which removes the requirement for CRE occupant protection in the event of

an Sl in the affected unit(s). These actions ensure that if the CRE occupants cannot be protected from all postulated accident and single failure conditions, the unit or units are placed in a MODE where the protection is no longer required. The allowed Completion Times are reasonable, based on operating experience, to perform the Required Actions and to reach the required unit conditions from full power conditions in an orderly manner without challenging unit systems.

Required Action G.1 is modified by a Note that excepts Condition E. Condition E affects both units, and Required Action G.1 is based on a single affected unit. Therefore, upon entry into Condition G from Condition E, only Required Actions G.2 and G.3 apply.

BASES SURVEILLANCE REQUIREMENTS REFERENCES SR 3. 7.1 0.5 (continued)

CREFS -

Both Units Operating B3.7.10 basis analyses of DBA consequences. When unfiltered air in leakage is greater than the assumed flow rate, Condition D must be entered. Required Action D.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref. 5) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 6). These compensatory measures may also be used as mitigating actions as required by Required Action D.2. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref.

7). Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions.

Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

1.

FSAR, Section 6.4.

2.

FSAR, Chapter 15.

3.

VEGP Calculation No. X6CNA.09.01, Control Room HVAC Technical Specifications, October 21, 1988.

4.

Regulatory Guide 1.52, Rev. 2.

5.

Regulatory Guide 1.196.

6.

NEI 99-03, "Control Room Habitability Assessment," June 2001.

7.

Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, "NEI Draft White Paper, Use of

Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability." (ADAMS Accession No. ML040300694).

~

8. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of

-===~-----==----=~~~

"'--. Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

Vogtle Units 1 and 2 B 3.7.10-10 REVISION 14

Place the unit in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months of~ C~o-n=d7 it~io~n~A~*~B~*~C~*~o~r ~F~l==F.....,._H_.....

2

=/=ft

=IP=Ia==1c~-~~:-~~:~~N:~:--~--- o~u=rs=--====-

'"'-. INSERT-TS 3.7.11 LCO 3.0.4.a is not Condition 1 L----1applicable when entering MODE4.

SURVEILLANCE REQUIREMENTS SR 3.7.11.1 SURVEILLANCE The Surveillance Requirements of Specification 3.7.10 are applicable.

Vogtle Units 1 and 2 3.7.11-3 FREQUENCY In accordance with applicable SRs.

Amendment No. 154 (Unit 1)

Amendment No. 135 (Unit 2)

TS 3.7.11-Condition I Insert CONDITION REQUIRED ACTION COMPLETION TIME I.

Required Action and 1.1 Place the unit in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition D, E, AND or G not met for operating unit.

1.2 Place the unit in MODE 5.

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

BASES ACTIONS INSERT BASES Condition H Vogtle Units 1 and 2 F.1 (continued)

CREFS -One Unit Operating B3.7.11 During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the ca,lculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. These mitigating actions (i.e.,

actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA In addition, the 90 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

With the CRE air temperature outside its limit, action must be taken to restore the air temperature to within the limit within 7 days. If the CRE air temperature exceeds its limit, the ability of a single train of CREFS to maintain CRE temperature after a CRI may be affected. The completion time of 7 days is reasonable considering the number of CREFS trains available to perform the required temperature control function and the low probability of an event occurring that would require the CREFS operation during that time.

1.1 and 1.2 lot Condition D, E, or G are not met~

If the Required Actions and associated Completion Times for the operating unit 18re not met, action must be taken to place the unit in a condition where the inoperable CREFS train(s) are no longer required. The operating unit must be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , which removes the requirement for CRE occupant protection in the event of an Sl in (continued)

B 3.7.11-5 Rev. 3-11/08

~-------

BASES ACTIONS INSERT BASES Condition H Vogtle Units 1 and 2 F.1 (continued)

CREFS-One Unit Operating B3.7.11 During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. These mitigating actions (i.e.,

actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

With the CRE air temperature outside its limit, action must be taken to restore the air temperature to within the limit within 7 days. If the CRE air temperature exceeds its limit, the ability of a single train of CREFS to maintain CRE temperature after a CRI may be affected. The completion time of 7 days is reasonable considering the number of CREFS trains available to perform the required temperature control function and the low probability of an event occurring that would require the CREFS operation during that time.

rJL 1 and 1.2 I I 1-1.1 and 11.2f

,....lo_f_C_o-nd-i-tio_n_D----. E~.-o-r--:G,.....-ar_e_n_o_t_m_e--.t ~

If the Required Actions and associated Completion Times for the operating unit IBre Rot met action must be taken to place the unit in a condition where the inoperable CREFS train(s) are no longer required. The operating unit must be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , which removes the requirement for CRE occupant protection in the event of an Sl in (continued)

B3.7.11-5 Rev. 3-11/08

INSERT-Bases 3.7.11 Condition H H.1 and.H.2 If the Required Actions and associated Completion Times of Conditions A, B, C or F are not met for the operating unit, action must be taken to place the unit in a condition in which overall plant risk is reduced. The operating unit must be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . These actions ensure that if the CRE occupants cannot be protected from all postulated accident and sihgle failure conditions, the unit is placed in a MODE where overall plant risk is reduced.

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 2). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 2, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action H.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The allowed Completion Times are reasonable, based on operating experience to reach the required unit conditions from full power conditions in an orderly manner without challenging unit systems.

BASES ACTIONS SURVEILLANCE REQUIREMENTS REFERENCES Vogtle Units 1 and 2

jl.1 and 1.2 1 I H.1 end ~.2f<continued)

CREFS-One Unit Operating B3.7.11 the operating unit. These actions ensure that if the CRE occupants cannot be protected from all postulated accident and single failure conditions, the unit is placed in a MODE where the protection is no longer required. The allowed Completion Times are reasonable, based on operating experience to reach the required unit conditions from full power conditions in an orderly manner without challenging unit systems.

SR 3.7.11.1 SR 3.7.11.1 requires that the SRs specified in LCO 3.7.10 be applicable for this LCO as well. The description and Frequencies of those required SRs are included in the Bases for LCO 3. 7.1 0.

1.

VEGP Calculation No. X6CNA.09.01, Control Room HVAC Technical Specifications, October 21, 1988.

\\_ 2. WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

B3.7.11-6 Rev. 2-11/08

Vogtle Electric Generating Plant-Units 1 and 2 Response to Request for Additional Information Regarding Adoption of TSTF-432-A, Rev. 1 "Change in Technical Specifications End States (WCAP-16294),

Using the Consolidated Line Item Improvement Process" Clean-typed Technical Specifications Pages

ACTIONS (continued)

CONDITION F.

Required Action and associated Completion Time of Condition A, 8, or D not met.

Vogtle Units 1 and 2 F.1 CREFS - Both Units Operating 3.7.10 REQUIRED ACTION

NOTE------

Required Action F.1 is not applicable when entering this Condition from Condition 8 or D.

COMPLETION TIME Lock closed the outside 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months air (OSA) intake dampers of the affected unit and lock open the OSA intake dampers of the unaffected unit.

F.2 Place the affected units(s) 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months in MODE 3.

AND F.3

NOTE--------

LCO 3.0.4.a is not applicable when entering MODE 4.

Place the affected unit(s) 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months in MODE4.

(continued) 3.7.10-3 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

ACTIONS (continued)

CONDITION G.

Required Action and associated Completion Time of Condition C or E not met.

Vogtle Units 1 and 2 CREFS - Both Units Operating 3.7.10 REQUIRED ACTION COMPLETION TIME G.1 ----NOTE----

Required Action G.1 is not applicable when entering this Condition from Condition E.

Lock closed the outside air 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (OSA) intake dampers of the affected unit and lock open the OSA intake dampers of the unaffected unit.

G.2 Place the affected units(s) in 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months MODE 3.

G.3 Place the affected unit(s) in MODES.

3.7.10-4 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Amendment No.

(Unit 1)

(Unit 2)

CREFS - Both Units Operating 3.7.10 SURVEILLANCE REQUIREMENTS SR 3.7.10.1 SR 3.7.10.2 SR 3.7.10.3 SR 3.7.10.4 SR 3.7.10.5 SURVEILLANCE Verify control room air temperature~ 85°F.

Operate each CREFS train for ~ 1 0 continuous hours with the heater control circuit energized.

Perform required CREFS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

Verify each CREFS train actuates (switches to emergency mode) on an actual or simulated actuation signal.

Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

Vogtle Units 1 and 2 3.7.10-5 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with theVFTP In accordance with the Surveillance Frequency Control Program In accordance with the Control Room Envelope Habitability Program Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

ACTIONS (continued)

CONDITION F.

One or more CREFS F.1 trains inoperable due to inoperable CRE boundary.

AND F.2 AND F.3 G.

Control room air G.1 temperature not within limit.

H.

Required Action and H.1 associated Completion Time of Condition A, B, AND C, or F not met for operating unit.

H.2 I.

Required Action and 1.1 associated Completion Time of Condition D, E, AND or G not met for operating unit.

1.2 Vogtle Units 1 and 2 CREFS - One Unit Operating 3.7.11 REQUIRED ACTION COMPLETION TIME Initiate action to Immediately implement mitigating actions.

Verify mitigating actions 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.

Restore CRE boundary to 90 days OPERABLE status.

Restore control room air 7days temperature to within limit.

Place the unit in MODE 3.

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

NOTE-------

LCO 3.0.4.a is not applicable when entering MODE 4.

Place the unit in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Place the unit in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Place the unit in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 3.7.11-3 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

SURVEILLANCE REQUIREMENTS SR 3.7.11.1 SURVEILLANCE The Surveillance Requirements of Specification

3. 7.1 0 are applicable.

Vogtle Units 1 and 2 3.7.11-4 CREFS - One Unit Operating 3.7.11 FREQUENCY In accordance with applicable SRs.