Text

Response to Second Request for Additional Information Regarding SNC License Amendment Request for TSTF-52, Revision 2
	ML15329A249
Person / Time
Site:	Vogtle, Farley
Issue date:	11/25/2015
From:	Pierce C; Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-15-2062
	Download: ML15329A249 (60)
	v • d • e

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

.A.

40 Inverness Center Parkway Post Office Box 1295 Birmingham , AL 35242 NOV 2 5 2015 Tel 205.992.7872 SOUTHERN Fax 205.992 7601 NUCLEAR A SOUIHERN COMPANY Docket Nos.: 50-348, 50-364 NL-15-2062 50-424, 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant- Units 1 and 2 Vogtle Electric Generating Plant- Units 1 and 2 Response to Second Request for Additional Information Regarding SNC License Amendment Request for TSTF-523, Revision 2

References:

1. SNC Letter NL-15-0421, Joseph M. Farley Nuclear Plant- Units 1 and 2 License Amendment 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. SNC Letter NL-15-0422, Vogtle Electric Generating Plant- Units 1 and 2 License Amendment 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.

3. NRC Letter, Joseph M. Farley Nuclear Plant, Units 1 and 2- Request for Additional Information (T~C NOS. MF6211 AND MF6212), dated August 20, 2015.

4. NRC Letter, Vogtle Electric Generating Plant, Units 1 and 2- Request for Additional Information on License Amendment Request (TAG NOS. MF6213 AND MF6214), dated August 24, 2015.

5. SNC Letter NL-15-1665, Joseph M. Farley Nuclear Plant- Units 1and 2- Request for Additional Information Regarding SNC License Amendment Request for TSTF-523, Revision 2, dated September 15, 2015, ML15258A535.

6. SNC Letter NL-15-1739, Vogtle Electric Generating Plant- Units 1 and 2- Response to Request for Additional Information Regarding SNC License Amendment Request for TSTF-523, Revision 2, dated September 21, 2015, ML15264A738.

7. NRC Letter, Joseph M. Farley Nuclear Plant, Units 1 and 2 and Vogtle, Units 1 and 2-Request for Additional Information (CAC NOS. MF6211, MF6212, MF6213, AND MF6214),

dated October 29, 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 Joseph M. Farley Nuclear Plant (FNP) , Units 1 and 2 and Vogtle Electric Generating Plant (VEGP), Units 1 and 2 (References 1 and 2).

U.S. Nuclear Regulatory Commission NL-15-2062 Page 2 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 FNP and VEGP License Amendment Requests, SNC received a request for additional information by the NRC on August 20, 2015 (Reference

3) and on August 24, 2015 (Reference 4). The response to this set of RAis was addressed in SNC Letters NL-15-1665 and NL-15-1739 (Reference 5 and 6).

The NRC has issued a follow-up set of RAis asking the same type information for FNP and VEGP (Reference 7). Enclosure 1 provides the requested information. Enclosure 2 provides the replacement pages for the affected LAR FNP and VEGP Technical Specification Marked Up Pages. Enclosure 3 provides the replacement pages for the affected LAR FNP and VEGP Technical Specification Clean Typed Pages. Enclosure 4 of this letter will provide the FNP and VEGP LAR replacement pages for the information only affected marked up Technical Specification Bases pages.

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.

Respectfully submitted, l l C. i £.;- *

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I C. R. Pierce Regulatory Affairs Director \

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CRP/GLS/Iac Sworn to and subscribed before me this ZS~ay of w~bk 12015.

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Notary Public My commission expires: IIz./20 r g' rl

Enclosures:

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

2. FNP and VEGP Technical Specification Marked Up Replacement Pages

3. FNP and VEGP Technical Specification Clean Typed Replacement Pages

4. FNP and VEGP Technical Specification Bases Marked Up Replacement Pages (For Information Only)

U.S. Nuclear Regulatory Commission NL-15-2062 Page 3 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bast, Executive Vice President & Chief Nuclear Officer Mr. M. D. Meier, Vice President- Regulatory Affairs Ms. C. A. Gayheart, Vice President- Farley Mr. B. K. Taber, Vice President- Vogtle 1 & 2 Mr. D. R. Madison, Vice President- Fleet Operations Mr. B. J. Adams, Vice President- Engineering Ms. B. L. Taylor, Regulatory Affairs Manager- Farley Mr. G. W. Gunn, Regulatory Affairs Manager- Vogtle 1 & 2 RTypes: CFA04.054; CVC7000 U.S. Nuclear Regulatory Commission Mr. L. D. Wert, Regional Administrator (Acting)

Mr. S. A. Williams, NRR Project Manager- Farley Mr. R. E. Martin, NRR Senior Project Manager- Vogtle 1 & 2 Mr. P. K. Niebaum, Senior Resident Inspector- Farley Mr. L. M. Cain, Senior Resident Inspector- Vogtle 1 & 2 Alabama Department of Public Health Dr. D. E. Williamson, State Health Officer State of Georgia Mr. J. H. Turner, Director- Environmental Protection Division

Joseph M. Farley Nuclear Plant- Units 1 and 2 Vogtle Electric Generating Plant- Units 1 and 2 Response to Second Request for Additional Information Regarding SNC License Amendment Request for TSTF-523, Revision 2 Enclosure 1 Response to Request for Additional Information - TSTF-523 to NL-15-2062 Response to Request for Additional Information - TSTF-523 Page E1-1 By two letters dated May 12, 2015 (Agency wide Documents Access and Management System (ADAMS) Accession Nos. ML15132A722 and ML15132A662), the Southern Nuclear Operating Company, Inc. (SNC), submitted a request to revise the Joseph M. Farley Nuclear Plant, Unit 1 and Unit 2, and the Vogtle Electric Generating Plant, Unit 1 and Unit 2, Technical Specifications (TS) consistent with the U.S. Nuclear Regulatory Commission (NRC)- approved Technical Specification Task Force (TSTF) Traveler 523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation."

As part of section 50.36 of Title 10 of the Code of Federal Regulations (1 0 CFR), "Technical Specifications," the licensee is required to provide a "summary statement of the bases or reasons for such specifications" as part of the license amendment request (LAR) submittal.

Since the TS bases are part of the LAR submittal, they are utilized as supporting information by the NRC staff during the review of the TS changes. The U.S. Nuclear Regulatory Commission staff has determined that additional information regarding the TS bases is necessary since the application deviated from the approved language in TSTF-523.

RAJ No.1 In multiple sections of the TS bases associated with the Residual Heat Removal (RHR) system (Vogtle 3.4.6, 3.4.7, 3.4.8, 3.9.5, 3.9.6 and Farley 3.4.6, 3.4.7, 3.4.8, 3.9.4, 3.9.5) the TS bases state, "When the RHR System is restored to service, the surveillance is met by virtue of the performance of operating procedures that ensure the RHR Loop is adequately filled and vented.

The performance of these manual actions ensures that the surveillance is met." According to the surveillance requirement (SR) language, the SR is met by ensuring the system is "sufficiently filled with water," but this TS bases description indicates that performance of operating procedures satisfies the SR. Please justify how "by virtue of the performance of operating procedures" ensures that the SR acceptance criteria are met for locations susceptible to gas accumulation or, if necessary, revise the TS bases so that they are in agreement with the approved TSTF-523 language.

SNC Response to RA1:

SNC has included all the wording that is consistent with the U.S. Nuclear Regulatory Commission (NRC)- approved Technical Specification Task Force (TSTF) Traveler 523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation," in the above mentioned RHR system TS bases sections. The differences that we are discussing in the bases sections for these 3 RAis is that more wording is added to the bases for clarification to the operators at Farley and Vogtle to ensure that the actions required to meet the SR bases are properly met.

Performance of the actions to meet the Gas Accumulation surveillance requirements is driven at these plants by the operating procedures (which does include manual actions) -for example filling and venting, pointers to ensure proper ultrasonic tests are performed and evaluated, guidance to ensure proper flows are maintained in the systems, observation of erratic system performance indicative of voids in the system are identified, precautions taken when cycling system boundary valves, the filling and venting and ultrasonic testing of system piping/components that are voided for maintenance, assurance that any voids found are evaluated/removed to ensure system operability - which includes writing condition reports when needed, etc. This is the process by which the SRs for gas accumulation will have implementation managed to ensure the RHR system is "sufficiently filled with water."

to NL-15-2062 Response to Request for Additional Information - TSTF-523 Page E1-2 After further consideration of the NRC RAI, it is justified to amend the affected Technical Specification Bases sections (Vogtle 3.4.6, 3.4.7, 3.4.8, 3.9.5, 3.9.6 and Farley 3.4.6, 3.4.7, 3.4.8, 3.9.4, 3.9.5) to replace the wording "When the RHR System is restored to service, the surveillance is met by virtue of the performance of operating procedures that ensure the RHR Loop is adequately filled and vented. The performance of these manual actions ensures that the surveillance is met. .. " with "Operating procedures direct the implementing actions to meet this SR and ensure the system is sufficiently filled with water ... " of this letter will provide the FNP and VEGP Technical Specification Bases Marked Up Replacement Pages (For Information Only).

RAJ No.2 In multiple sections associated with the RHR system (Vogtle 3.4.6, 3.4.7, 3.4.8, 3.9.5, 3.9.6 and Farley 3.4.6, 3.4.7, 3.4.8, 3.9.4, 3.9.5) the TS bases state, "SR may be met for a RHR Loop by virtue of having a loop in service in-accordance with operating procedures." If the system is running with sufficient flow, monitoring the running parameters is effective. However, if the flow is low, the gas voids may not transport through the system. Additionally, stagnant branch lines in an operating system may be susceptible to gas accumulation. This appears to be an alternative to performing the SR. Please explain how the flowrate of the operating system and the stagnant branch lines are taken into consideration when crediting the in-service loop as meeting the SR.

Explain why is it acceptable to describe this approach in the TS bases rather than the TS surveillance. If necessary, revise the TS bases so that they are in agreement with the approved TSTF-523 language.

SNC Response to RA2:

As stated above, SNC has included all the wording that is consistent with the U.S. Nuclear Regulatory Commission (NRC) - approved Technical Specification Task Force (TSTF) Traveler 523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation," in the above mentioned RHR system TS bases sections. Once the system is placed in service, operating parameters are monitored to ensure the capability of the running system is meeting its system requirements and the presence of gas voids is not detected during running. Erratic pump operation, including suction pressure, discharge pressure, and flow oscillations, as well as unusual vibration levels, can be indicative of air or gas accumulation in the system piping.

Actions will be taken to document, via Condition Report (CR) , and investigate the potential gas intrusion as needed. Monitoring of these parameters continues while the system is running .

The RHR System Operating Procedure provides operating guidance to maintain the RHR system single loop flow at a high enough flow to ensure proper circulation (not allowing low pump flow). Plant operating experience along with improvements in the reduction of voids as captured in the FNP and VEGP responses to GL 2008-01 makes it prudent to allow a RHR system to continue to run instead of performing a system evolution of securing the RHR system to perform ultrasonic testing and venting for the 31 day surveillance. In fact, the RHR operation is unique in that it is a system run continuously during certain low mode plant conditions; instead of just during surveillance requirements or transients. However, if a void exists that is affected by a later change in flow rate or flow path , monitoring of the system parameters will provide feedback of a potential changing void system configuration and require a CR to be written to address the issue to ensure gas accumulation is brought within the acceptance to NL-15-2062 Response to Request for Additional Information - TSTF-523 Page E1-3 criteria limits. Evaluation of the event through the CR process would require further investigation which should determine any void size change and verification accumulated gas is within acceptance criteria.

Per TSTF-523 Revision 2 traveler submitted to the NRC dated February 21, 2013 (ML13053A075), the 31 day surveillance frequency is based on the gradual nature of gas accumulation, the procedural controls governing system operation, and operating experience.

This approach was reviewed and endorsed by the NRC letter Model Safety Evaluation for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-523, Revision 2, "Generic letter 2008-01, Managing Gas Accumulation," using the Consolidated Line Item Improvement Process (CLIIP), dated December 23, 2013 (ML13255A169). Again, gas accumulation is based on a gradual nature and it is not often that the RHR system would be running when its 31 day surveillance is due. Therefore, accepting a running RHR system as meeting its surveillance, as long as no indications of erratic system operation is observed due to voids, is appropriate due to the controls in place for the system operational flow guidance.

After further consideration of the NRC RAI, it seems prudent to amend the Technical Specifications for the SR's (Vogtle 3.4.6, 3.4. 7, 3.4.8, 3.9.5, 3.9.6 and Farley 3.4.6, 3.4. 7, 3.4.8, 3.9.4, 3.9.5) with a note and a clarification of this note in the corresponding Technical Bases sections to ensure the RHR subsystem remains sufficiently filled with water stating:

Technical Specification Note:

"Note:

An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation."

Technical Specification Bases Note:

"This SR is modified by a Note clarifying that the SR may be met for a running RHR Loop by virtue of having the RHR Loop in service in accordance with operating procedures except when the RHR Loop is in a low flow system operation which could allow the potential of gas voids not transporting through the system and the potential accumulation of gas voids in stagnant branch lines." of this letter will provide the FNP and VEGP License Amendment Request (LAR),

Reference 1 and 2, replacement pages for the affected Marked Up Technical Specification pages. Enclosure 3 of this letter will provide the FNP and VEGP LAR replacement pages for the affected Clean Typed Technical Specification Pages. Enclosure 4 of this letter will provide the FNP and VEGP Technical Specification Bases Marked Up Replacement Pages (For Information Only).

to NL-15-2062 Response to Request for Additional Information- TSTF-523 Page E1-4 RAI No.3 In multiple sections associated with the RHR system (i.e., Vogtle- 3.4.6, 3.4.7, 3.4.8, 3.9.5, 3.9.6, and Farley- 3.4.6, 3.4.7, 3.4.8, 3.9.4, 3.9.5), the TS bases state, "The RHR system is assumed to remain sufficiently filled with water and may be restarted following short term duration RHR shutdowns, if no evolutions were performed that can introduce voids into the RHR loop." This language is not contained in TSTF-523, so please explain how short-term duration is determined by the operators along with its basis. Also, if necessary, revise the TS bases so that they are in agreement with the approved TSTF-523 language.

SNC Response to RA3:

As stated above, SNC has included all the wording that is consistent with the U.S. Nuclear Regulatory Commission (NRC)- approved Technical Specification Task Force (TSTF) Traveler 523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation," in the above mentioned RHR system TS bases sections. As is discussed in the LCO notes for the above Technical specification Bases section for RHR there are allowed short term duration times of Jess than or equal to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months allowed per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months periods or Jess than or equal to two hours allowed per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months periods to shut down an RHR pump to perform various tests -which include for example:

to validate various accident analysis such as validation of rod drop times during cold conditions

permit periodic surveillance tests to be performed on the inoperable loop during the only time when such testing is safe and possible

permits core mapping or alterations in the vicinity of the reactor vessel hot leg nozzles and RCS to RHR isolation valve testing

perform the required surveillance testing necessary to verify the RHR System performance in the ECCS injection mode of operation.

The purpose of this clarification note is to provide guidance for the operators during these discussed short duration shutdowns; "The RHR system is assumed to remain sufficiently filled with water and may be restarted following short term duration RHR shutdowns, if no evolutions were performed that can introduce voids into the RHR loop." As per the TSTF-523 Revision 2 traveler, gas accumulation is based on a gradual nature of gas accumulation, the procedural controls governing system operation, and operation experience. With the longest shutdown only being less than or equal 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period it was prudent to provide this clarification to the FNP and VEGP operators. Again, the sentence is only added for implementation process clarification for the operators and does not diminish the bases of the Surveillance Requirement since the TSTF-523, Revision 2, bases traveler wording is completely included.

SNC response to tvpo discovered on the FNP Conly) Technical Specification Bases mark-up page B 3.5.2-11:

A typo was found in the FNP, Reference 1, Technical Specification Bases mark-up page B 3.5.2-11, in which Section SR 3.5.2.6 section number should actually have been SR 3.5.2.8. of this letter will also provide the FNP Technical Specification Bases Marked Up Replacement Page (For Information Only), correcting this typo on page B 3.5.2-11.

Joseph M. Farley Nuclear Plant- Units 1 and 2 Vogtle Electric Generating Plant- Units 1 and 2 Response to Second Request for Additional Information Regarding SNC License Amendment Request for TSTF-523, Revision 2 Enclosure 2 FNP and VEGP Technical Specification Marked Up Replacement Pages to NL-15-0421 FNP Technical Specification Marked Up Pages RCS Loops- MODE 4 3.4.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. One required RHR loop B.1 Be in MODE 5. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months inoperable.

AND Two required RCS loops inoperable.

C. Required RCS or RHR c. 1 Suspend all operations Immediately loops inoperable. involving a reduction of RCS boron concentration.

OR AND No RCS or RHR loop in operation. C.2 Initiate action to restore Immediately one loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify one RHR or RCS loop is in operation. In accordance with the Surveillance Frequency Control Program SR 3.4.6.2 Verify SG secondary side water levels are ~ 75% (wide In accordance range) for required RCS loops. with the Surveillance Frequency Control Program SR 3.4.6.3 Verify correct breaker alignment and indicated power are In accordance available to the required pump that is not in operation. with the

+----i Insert SR 3.4.6.4 located on next page Surveillance Frequency Control Program Farley Units 1 and 2 3.4.6-2 Amendment No. ~ (Unit 1)

Amendment No. 00 (Unit 2)

E2-1 to NL-15-0421 FNP Technical Specification Mar1<ed Up Pages

/

Insert as SR 3.4.6.4 SR 3. 4. 6. 4 -------------------------------NOTES------------------------

1. Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 4.

2. An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation.

Verify required RHR loop locations susceptible to gas In accordance accumulation are sufficiently filled with water. with the Surveillance Frequency Control Program E2-2

Enclosure 2 to NL-15-0421 FNP Technical Specification Marked Up Pages RCS Loops- MODE 5, Loops Filled 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.3 Verify correct breaker alignment and indicated power In accordance with are available to the required RHR pump that is not in the Surveillance operation. Frequency Control Program I SR 3.4.7.4 ------------------------------NOTE------------------------

An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation.

Verify required RHR loop locations susceptible to gas In accordance with the Surveillance accumulation are sufficiently filled with water.

Frequency Control Program Farley Units 1 and 2 3.4.7-3 Amendment No. 48a (Unit 1)

Amendment No. 400 (Unit 2)

E2-3

Enclosure 2 to NL-15-0421 FNP Technical Specification Marked Up Pages RCS Loops- l'vODE 5, Loops Not Filled 3.4.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 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 operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR loop is in operation. In accordance wth the Surveillance Frequency Control Program SR 3.4.8.2 Verify correct breaker alignment and indicated pov.er In accordance wth are available to the required RHR pump that is not in the Surveillance operation. Frequency Control Program

~

I SR 3.4.8.3 --------------------NOTE--------------------

An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation.

Verify RHR loop locations susceptible to gas In accordance with the Surveillance accumulation are sufficiently filled wth water. Frequency Control Program Farley Units 1 and 2 3.4.8-2 Amendment No. ~ (Unit 1)

Amendment No. .t80 (Unit 2)

E2-4 to NL-15-0421 FNP Technical Specification Marked Up Pages RHR and Coolant Circulation- High Water Level 3.9.4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.4 Close equipment hatch 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and secure with four bolts.

AND AS Close one door in each 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months air lock.

A.6.1 Close each penetration 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months providing direct access from the containment atmosphere to the outside atmosphere with a manual or automatic isolation valve, blind flange, or equivalent.

A.6.2 Verify each penetration is 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months capable of being closed by an OPERABLE Containment Purge and exhaust Isolation System.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.4.1 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 Insert SR 3.9.4.2 located on next page Program Farley Units 1 and 2 3.9.4-2 Amendment No. -+Sa (Unit 1)

Amendment No. +8G (Unit 2)

E2-10 to NL-15-0421 FNP Technical Specification Mar1<ed Up Pages

/

Insert as SR 3.9.4.2 SR 3. 9. 4. 2 ----------------------------NOTE---------------------

An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation.

Verify required RHR loop locations susceptible to gas In accordance accumulation are sufficiently filled 'Nith water. with the Surveillance Frequency Control Program E2-1Da to NL-15-0421 FNP Technical Specification Marked Up Pages RHR and Coolant Circulation- Low Water Level 3.9.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 Verify one RHR loop is in operation and circulating In accordance ~th reactor coolant at a flow rate of 2::: 3000 gpm. the Surveillance Frequency Control Program SR 3.9.5.2 Verify correct breaker alignment and indicated power In accordance ~th available to the required RHR pump that is not in the Surveillance t

operation. Frequency Control Program I

SR 3.9.5.3 -----------------------NOTE-------------------

An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation .

Verify RHR loop locations susceptible to gas In accordance ~th accumulation are sufficiently filled ~th water. the Surveillance Frequency Control Program Farley Units 1 and 2 3.9.5-3 Amendment No. ~ (Unit 1)

Amendment No. +80 (Unit 2)

E2-11

Enclosure 2 to NL-15-0422 VEGP Technical Specification Marked Up Pages RCS Loops- MODE 4 3.4.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.6.3 Verfy correct pump breaker alignment and In accordance 'Nith indicated pov.er are available to the required the Surveillance pump that is not in operation. Frequency Control Program

/

SR 3.4.6.4 --------------------NOTES------------------

1. Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 4.

2. An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation.

Verify required 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 3.4.6-3 Amendment No. -+a8 (Unit 1)

Amendment No. 44Q (Unit 2)

E2-1

Enclosure 2 to NL-15-0422 VEGP Technical Specification Marked Up Pages RCS Loops- MODE 5, Loops Filled 3.4.7 SURVEILLANCE REQUIREfv'ENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.7.3 Verify correct breaker alignment and indicated In accordance with power are available to the required RHR pump the Surveillance that is not in operation. Frequency Control I

Program

,/

SR 3.4.7.4 ------------------------------NOTE-----------------------

An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation .

Verify required RHR loop locations susceptible to In accordance \Mth the gas accumulation are sufficiently filled with water. Surveillance Frequency Control Program Vogtle Units 1 and 2 3.4.7-3 Amendment No. 4-aS (Unit 1)

Amendment No. 44Q (Unit 2)

E2-2

Enclosure 2 to NL-15-0422 VEGP Technical Specification Marked Up Pages RCS Loops- IVk)DE 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 wth the Surveillance Frequency Control Program SR 3.4.8.2 Verify correct breaker alignment and indicated powe In accordance wth the are available to the required RHR pump that is not ir Surveillance Frequency operation. Control Program SR 3.4.8.3 Verify each valve that isolates unborated water In accordance wth 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 -------------------------------~()lrE:----------------------------

An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation .

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 Marl<ed Up Pages RHR and Coolant Circulation - High Water Level 3.9.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.4 Close all containment 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months penetrations providing direct access from containment atmosphere to outside atmosphere.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 Ver"ty one RHR loop is in operation and circulating In accordance vvith reactor coolant at a flow rate of ::: 3000 gpm. the Surveillance Frequency Control Program SR 3.9.5.2 -------------------------------NOTE----------------------------

An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation .

Ver"ty required RHR loop locations susceptible to In accordance vvith the Surveillance gas accumulation are sufficiently filled vvith water.

Frequency Control Program Vogtle Units 1 and 2 3.9.5-2 Amendment No. ~ (Unit 1)

Amendment No. +4G- (Unit 2)

E2-B to NL-15-0422 VEGP Technical Specification Marked 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 0.00111 hours 6.613757e-6 weeks 1.522e-6 months penetrations providing direct access from containment atmosphere to outside atmosphere.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 Ver'ffy one RHR loop is in operation and circulating In accordance IMth reactor coolant at a flow rate of ?: 3000 gpm. the Surveillance Frequency Control Program I

SR 3.9.6.2 -------------------------------NOTE----------------------------

An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation.

Ver'ty RHR loop locations susceptible to gas In accordance IMth the Surveillance accumulation are sufficiently filled IMth water. Frequency Control Program Vogtle Units 1 and 2 3.9.6-2 Amendment No. 4a8 (Unit 1)

Amendment No. 440 (Unit 2)

E2-9

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

RCS Loops- MODE 4 3.4.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.4 -----------NOTES

1. Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 4.

2. An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation.

Ver'ty required RHR loop locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Farley Units 1 and 2 3.4.6-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

RCS Loops- MODE 5, Loops Filled 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.3 Verify correct breaker alignment and indicated power In accordance with are available to the required RHR pump that is not in the Surveillance operation. Frequency Control Program SR 3.4.7.4 -----------------------------NOTE--------------------------

An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation.

Verify required RHR loop locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Farley Units 1 and 2 3.4.7-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

RCS Loops- MODE 5, Loops Not Filled 3.4.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required RHR loops 8 .1 Suspend all operations Immediately inoperable. involving reduction in RCS boron concentration.

OR AND No RHR loop in operation. 8 .2 Initiate action to restore Immediately one RHR loop to OPERABLE status and operation.

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 power In accordance with are available to the required RHR pump that is not in the Surveillance operation. Frequency Control Program SR 3.4.8.3 -------------NOTE----------------

An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation.

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

Amendment No. (Unit 2)

RHR and Coolant Circulation-HighWater Level 3.9.4 SURVEILLANCE FREQUENCY SR 3.9.4.2 --NOTE----------------

An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation.

Verify required RHR loop locations susceptible to In accordance with gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Farley Units 1 and 2 3.9.4-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

RHR and Coolant Circulation- Low Water Level 3.9.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 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 3.9.5.2 Verify correct breaker alignment and indicated power In accordance with available to the required RHR pump that is not in the Surveillance operation. Frequency Control Program SR 3.9.5.3 -----------------------------N()TE-----------------------------

An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation.

Verify RHR loop locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Farley Units 1 and 2 3.9.5-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

RCS Loops- MODE 4 3.4.6 FREQUENCY SR 3.4.6.3 Verify correct pump breaker alignment and In accordance with indicated power are available to the required the Surveillance pump that is not in operation. Frequency Control Pr ram SR 3.4.6.4 ---------NOTES

1. Not required to be performed until12 hours after entering MODE 4.

2. An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation .

Verify required RHR loop locations susceptible to In accordance with gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.4.6 Amendment No. (Unit 1)

Amendment No. (Unit 2)

RCS Loops- MODE 5, Loops Filled 3.4.7 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.7.3 Verify correct breaker alignment and indicated In accordance with power are available to the required RHR pump the Surveillance that is not in operation. Frequency Control Program SR 3.4.7.4 -----------------------------NOTE----------------------------

An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation.

Verify required RHR loop locations susceptible to In accordance with gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.4.7 Amendment No. (Unit 1)

Amendment No. (Unit 2)

RCS Loops- MODE 5, Loops Not Filled 3.4.8 SURVEILLANCE FREQUENCY SR 3.4.8.4 -----------------------------NOlrE---------------------------

An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation .

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 - High Water Level 3.9.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.4 Close all containment 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months penetrations providing direct access from containment atmosphere to outside atmosphere.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 Verify one RHR loop is in operation and circulating In accordance with the reactor coolant at a flow rate of;:::: 3000 gpm. Surveillance Frequency Control Program SR 3.9.5.2 --------------------NOTE-------------

An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation.

Verify required RHR loop locations susceptible to In accordance with the gas accumulation are sufficiently filled with water. Surveillance Frequency Control Program Vogtle Units 1 and 2 3.9.5-2 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 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 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 ---------------------NOTE----------------

An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation.

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)

Joseph M. Farley Nuclear Plant- Units 1 and 2 Vogtle Electric Generating Plant- Units 1 and 2 Response to Second Request for Additional Information Regarding SNC License Amendment Request for TSTF-523, Revision 2 Enclosure 4 FNP and VEGP Technical Specification Bases Marked Up Replacement Pages (For Information Only) to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RCS Loops - M:>DE 4 B 3.4.6 BASES SURVEILLANCE SR 3.4.6.2 REQUIREI\JENT S (continued) SR 3.4.6.2 ra:juires wrfiCation ci SG OPERABIUTY. SG OPERABIUTY is wrfied by ensurirg that the seoondary side wde range IIIBter lewl is ;: : : 75%. If the SG secondary side wde range water lewl is< 75%, the tubes may become unca..ered and the associated loop may not be capable ci pro\1ding the heat sink necessaryfor removal r:i decay heat. Tl"e Surwillance Fra:juency is controlled under the Surwillance Fra:j uency Control Prc.g ram.

SR 3.4.6.3 Verification that the ra:jured pump is OPERABLE ensures that an additional RCS or RHR p.Jmp can be placed in o,::eration, f needed, to maintain decay heat removal and reactor coolant circulation.

Verification is performed by writy;ng proper breaker algnment and pov.er available to the required pump. Tl"e Surwillance Fra:juency is controlled under the Surwillance Fra:juency Control Prc.gram.

SR 3.4.6.4 RHR System pipirg and components haw the potential to dewlop

\Oids and pockets ci entrained gases. Prewntirq and mancgirq gas intrusion and accumulation is necessaryf or prope- operation ci the required RHR loop(s) and may also prewnt IIIBter hammer. pump ca'v1tation. and pumpirq ci noncondensiblegas into the reacta- wssel.

Selection d RHR System locations susceptible to gas accumulation is based on a re'v1ewof system desgn information. including pipirg and instrumentation drawngs, isometric drawng s. plan and elevation drawngs, and calculatiors. The design re'v1ewis supplemented by system IIIBik doW1s to validate the system high ponts and to cortirm the location and orientaton ci important compona1ts that can become sources d gas or could otherWse cause gas to be trapped or difficult to rem ow durirq system maintenance a restoration. Susceptible locations depend on plart and system confguration. such as stand-by wrsus operating conditims.

The RHR System is OPERABLE Yilen it is sufficiently filled IMth water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance 1s not met. If it (continued)

Farley Units 1 and 2 B 3.4.6-5 Re\1sion E4-2 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RCS Loops -I'IIODE 4 B 3.4.6 BASES SURVEILLANCE SR 3.4.6.4 (continued)

REQUIREr.JENT S is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e .. the system is sufficiently filled with water). the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits. Operating procedures direct the implementing actions to meet this SR and ensure the system is sufficiently filled with water.

RHR System locations susceptible to gas accumulation are monitored and. if gas is found. the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions. the plant configuration. or personnel safety. For these locations alternative methods (e.g ., operating parameters. remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The RHR system is assumed to remain sufficiently filled with water and may be restarted following short term duration RHR shutdowns. if no evolutions were performed that can introduce voids into the RHR loop.

This SR is modified by a Note 1 that states the SR is not required to be performed until12 hours after entering MODE 4. In a rapid shutdown. there may be insufficient time to verify all susceptible locations prior to entering MODE 4.

This SR is modified by a Note 2 clarifying that the SR may be met for a running RHR Loop by virtue of having the RHR Loop in service in accordance with operating procedures except when the RHR Loop is in a low flow system operation which could allow the potential of gas voids not transporting through the system and the potential accumulation of gas voids in stagnant branch lines.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation.

REFERENCES None.

Farley Units 1 and 2 B 3.4.6-6 Re\1sion I E4-3 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RCS Loops - fltODE 5, Loops Filled B 3.4.7 BASES SURVEILLANCE SR 3.4.7.1 REQUIREI\IENT S Tlis SR ra:tuires verification that the ra:tuired loop is in operation.

Verification includes flow rate, temperature, or pump status monitorirg, Vlhich help ensure that forced flow is prmAding heat removal.

ne Sun.eillance Fra:tuency is controlled under the Sun.eillance Fra:tuency Control Prcgram .

SR 3.4.7.2 Verifying thci at least tiJIO SGs are OPERABLE byensurirg their secondary side IMde range \t\Bter le\els are ~ 75% ensures an alternate decay heat removal method Ya natural circulation in the e\ent that the second RI-R loop is not OPERABLE. If both RHR loops are OPERABLE, this Sun.eillance is not neerled . The Sun.eillance Frequency is controlled under the SUI'\eillance Fra:tuency Control Prcgram.

SR 3.4.7.3 Verfication that a second RHR pump is OPERABLE ensures that an additional pump can be paced in operation, if neerled, to maintain decay heat removal and reactor coolart circulation. Verfication is performed by \erifying proper brea<er algnment and pov.er available to the RHR pump. If seoondary side \t\Bter le\el is ~ 75% (wde range) in at least tiJIO SGs, this Sun.eillance is not needed. The Sun.eillance Frequency is controlled under the SUI'\eillance Fra:tuency Control Prcgram .

SR 3.4.7.4 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing g as intrusion and accumulation is necessary for proper operation of the required RHR loop(s) and may also prevent water hammer, pump cavitation. and pumping of noncondensible gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation drawings, isometric drawings, plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise (continued)

Farley Units 1 and 2 B 3.4.7-5 ReYsion I E4-5 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RCS Loops - MJDE 5, Loops Filled B 3.4.7 BASES SURVEILLANCE SR 3.4.7.4 (continued)

REQUIREfiiENTS cause gas to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration. such as stand-by versus operating conditions.

The RHR System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e .,

the system is sufficiently filled with water). the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. Operating procedures direct the implementing actions to meet this SR and ensure the system is sufficiently filled with water.

RHR System locations susceptible to gas accumulation are monitored and, if gas is found. the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions. the plant configuration. or personnel safety. For these locations alternative methods (e.g., operating parameters. remote monitoring) may be used to monitor the susceptible location.

Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY.

The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The RHR system is assumed to remain sufficiently filled wth water and may be restarted follow;ng short term duration RHR shutdoWls.

if no evolutions \Nere performed that can introduce voids into the RHR loop.

(continued)

Farley Units 1 and 2 B 3.4.7-6 Re\1sion E4-6 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for infonnation only)

RCS Loops -l\tODE 5, LDops Filled B 3.4.7 BASES SURVEILLANCE SR 3.4.7.4 (continued)

REQUIRErvENT S This SR is modified by a Note clarifying that the SR may be met for a running RHR Loop by virtue of having the RHR Loop in service in accordance with operating procedures except when the RHR Loop is in a low flow system operation which could allow the potential of gas voids not transporting through the system and the potential accumulation of gas voids in stagnant branch lines.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program . The Surveillance Frequency may vary by location susceptible to gas accumulation.

REFERENCES 1. NRC lrtormation Notice95-35, "DSJraded Abilityc:t Steam Generators to Remo\e Decay Heat by Natural Circulation. "

Farley Units 1 and 2 B 3.4.7-7 Re\Asion I E4-7

Enclosure 4 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for infonnation only)

RCS Loops, - JI,,DE 5, Loops Not Filled B.3.4.8 BASES ACTIONS B.1 and B.2 (continued)

If no required RHR loops are OPERABLE or in operation, ex::ept during conditions permitted by Note 1, all operatioos imoi\Ang a reduction d RCS boron concentration must be suspended and action must be initiated mmediately to restore an RHR loop to OPERABLE status and qJeration. Boron dilution requires forced circulation for uniform dilution, and the margin to criticality must not be reduced in this twe d operation The immediate Completion Time reflects the importance d maintainillJ operction for heat removal. Tte action to restore must contnue until one loop is restored to OPERABLE status and operation SURVEILLANCE SR 3.4.8.1 REQUIREI\t£NT S This SR requires verification that one loop is in operation. Verification includes flow rate, temperature, or pump status monitoring, which help ensure that forced flow is providing heat removal. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.8.2 Verification that the required number of pumps are OPERABLE ensures that additional pumps can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation.

Verification is performed by verifying proper breaker alignment and power available to the required pumps. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.8.3 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR loops and may also prevent water hammer. pump cavitation. and pumping of noncondensable gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information. including piping and instrumentation drawings. isometric drawings, plan and elevation drawings. and calculations. The design review (continued)

Farley Units 1 and 2 8 3.4.8-3 Re\1sion I E4-9 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RCS Loops,- MODE 5, Loops Not Filled B.3.4.8 BASES SURVEILLANCE SR 3.4.8.3 (continued)

REQUIRErvENT S is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause g as to be trapped or difficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the' Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e .. the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. Operating procedures direct the implementing actions to meet this SR and ensure the system is sufficiently filled with water.

RHR System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions. the plant configuration. or personnel safety. For these locations alternative methods (e.g ., operating parameters. remote monitoring) may be used to monitor the susceptible location.

Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY.

The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILIT Y during the Surveillance interval.

The RHR system is assumed to remain sufficiently filled with water and may be restarted following short term duration RHR shutdowns.

if no evolutions were performed that can introduce voids into the RHR loop.

(continued)

Farley Units 1 and 2 B 3.4.8-4 Re\4sionl E4-10

Enclosure 4to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RCS Loops, - I\ODE 5, Loops Not Filled 8 3.4.8 BASES SURVEILlANCE SR 3.4.8.3 (continued)

REQUIREM:NT S This SR is modified by a Note clarifying that the SR may be met for a running RHR Loop by virtue of having the RHR Loop in service in accordance with operating procedures except when the RHR Loop is in a low flow system operation which could allow the potential of gas voids not transporting through the system and the potential accumulation of gas voids in stagnant branch lines.

The Surveillance Freg uency is controlled under the Surveillance Frequency Control Prooram . The Surveillance Frequency may vary by location susceptible to gas accumulation.

Farley Units 1 and 2 8 3.4.8-5 Re\1sion I E4-11 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

ECCS - OperatirYJ B 3.5.2 BASES SURVEILLANCE SR 3.5.2.8 REQUIREfv'ENT S (continued) locations depend on plant and system configuration. such as stand-by versus operating conditions.

The ECCS is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the ECCS is not rendered inoperable by the accumulated gas (i.e .. the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

ECCS locations susceptible to gas accumulation are monitored and. if gas is found. the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions. the plant configuration. or personnel safety. For these locations alternative methods (e.g. operating parameters. remote monitoring) may be used to monitor the susceptible location .

Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge the system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation.

Farley Units 1 and 2 B 3.5.2-11 Re\4sion I E4-15 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RHR and Coolant Circulation- Hgh Water Le\el 8 3.9.4 BASES ACTIONS A.4, A.S. A.6.1. and A.6.2 (continued)

With RHR loop r9:1uirements not met, the potential e>Osts for the coolant to boil and release radioacti\e gas to the oontainment atmosphere. Performirg the actions described aoo\e ensures that all containment penetrations are either closed or can be closed so that the dose limits are not e>eeeded.

The Completion Time r:i 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months alloVIS fi>Ong r:i most RHR problems and is reasonable, based on the low probability d the coolant boilirg in that time.

SURVEILLANCE SR 3.9.4.1 REQUIREI'IIENT S This Sur\eillance demonstrates that the RHR loop is in operation and circulatirg reactor coolart. The flow rate is detennined by the flow rate necessary to pro~de slificient decay heat removal capability and to pre\ent thermal and ooron stratfication in the cnre. The Sur\eillance Frequency is controlled under the Sur\eillance Frequency Control Program.

SR 3.9.4.2 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR loops and may also prevent water hammer. pump cavitation. and pumping of noncondensible gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information. including piping and instrumentation drawings.

isometric drawings. plan and elevation drawings. and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration . Susceptible locations depend on plant and system configuration. such as stand-by versus operating conditions.

(continued)

Farley Units 1 and 2 8 3.9.4-4 Re~sion I E4-23 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RHR and Coolant Circulation - Hg h Water Lewl B 3.9.4 BASES SURVEILLANCE SR 3.9.4.2 (continued)

REQUI REM: NT S The RHR System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subseguent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. Operating procedures direct the implementing actions to meet this SR and ensure the system is sufficiently filled with water.

RHR System locations susceptible to g as accumulation are monitored and. if gas is found. the gas volume is compared to the acceptance criteria for the location . Susceptible locations in the same system f low path which are subject to the same g as intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

Monitoring may not be practical f or locations that are inaccessible due to radiological or environmental conditions, the plant configuration. or personnel safety. For these locations alternative methods (e.g., operating parameters.

remote monitoring) may be used to monitor the susceptible location . Monitoring is not reguired for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The RHR system is assumed to remain sufficiently filled IMth water and may be restarted follolloling short term duration RHR shutdoiMls, if no evolutions were performed that can introduce voids into the RHR loop.

(continued)

Farley Units 1 and 2 B 3.9.4-5 Re\1sion E4-24

Enclosure 4 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RHR and Coolant Circulation- Hgh Water Le\el 8 3.9.4 BASES SURVEILLANCE SR 3.9.4.2 (continued)

REQUIREI\JENT S This SR is modified by a Note clarifying that the SR may be met for a running RHR Loop by virtue of having the RHR Loop in service in accordance with operating procedures except when the RHR Loop is in a low flow system operation which could allow the potential of gas voids not transporting through the system and the potential accumulation of gas voids in stagnant branch lines.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation .

REFERENCES 1. FSAR, Section 5.5. 7.

Farley Units 1 and 2 8 3.9.4-6 Re~sion I E4-25 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only}

RHR and Coolant Circulation- Low Water Le\el B 3.9.5 BASES SURVEILLANCE SR 3.9.5.2 REQUIREI'vENTS (continued) Verification that the required pump is 0 PERABLE ensures that an additional RCS or RHR p.Jmp can be placed in op3ration, if needed, to maintain decay heat removal and reactor coolant circulation.

Verification is performed by \erity;ng proper breaker algnment and power available to the required pump. The SuMillance Frequency is controlled under the SuMillance Frequency Control Program.

SR 3.9.5.3 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR loops and may also prevent water hammer. pump cavitation. and pumping of noncondensible gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information. including piping and instrumentation drawings. isometric drawings. plan and elevation drawings, and calculations. The design review is supplemented by system walk downs to validate the system high points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or difficult to remove during system maintenance or restoration . Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions.

The RHR System is OPERABLE when it is sufficiently filled with water. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met.

If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water). the Surveillance may be declared met.

Accumulated gas should be eliminated or brought within the acceptance criteria limits. Operating procedures direct the implementing actions to meet this SR and ensure the system is sufficiently filled with water.

(continued)

Farley Units 1 and 2 B 3.9.5-4 Re~sion I E4-27 to NL-15-0421 FNP Technical Specification Bases Marked Up Pages (for information only)

RHR and Coolant Circulation- Low Water Le\.el B 3.9.5 BASES SURVEILLANCE SR 3.9.5.3 (continued)

REQUIREI'v£NT S RHR System locations susceptible to gas accumulation are monitored and. if gas is found. the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions. the plant configuration. or personnel safety. For these locations alternative methods (e.g., operating parameters. remote monitoring) may be used to monitor the susceptible location .

Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY.

The accuracyof the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The RHR system is assumed to remain sufficiently filled with water and may be restarted following short term duration RHR shutdowns.

if no evolutions were performed that can introduce voids into the RHR loop.

This SR is modified by a Note clarifying that the SR may be met for a running RHR Loop by virtue of having the RHR Loop in service in accordance with operating procedures except when the RHR Loop is in a low flow system operation which could allow the potential of gas voids not transporting through the system and the potential accumulation of gas voids in stagnant branch lines.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program . The Surveillance Frequency may vary by location susceptible to gas accumulation.

REFERENCES 1. FSAR, Section 5.5.7.

Farley Units 1 and 2 B 3.9.5-5 Re\4sion I E4-28 1o NL-15-0422 VEGP Technical Specification Bases Marked Up Pages (for infonnation only)

RCS Loops -IVODE 4 B 3.4.6 BASES SURVEILLANCE SR 3.4.6.2 REQUIRENENTS (continued) SR 3.4.6.2 requires verification of SG OPERABILITY. SG OPERABIUTY is verified by ensuring that the secondary side water level (LI-0501, Ll-0502, U-0503, Ll-0504) for the required RCS loops is above the highest point cl the steam generator U-tubes for each required loop. To assure that the steam generator is capable of functioning as a heat sink for the removal of decay heat, the U-tubes must be completely submerged. Plant procedures pro~de the minimum indicated levels for the range of the steam generator operating conditions required to satisfy this SR. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.6.3 Verfication that the required pump is OPERABLE ensures that an additional RCS or RHR pump can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation.

Verfication is performed by verifying proper pump breaker alignment and poiJI.er available to the required pump. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.6.4 RHR System pipirq and components have the potential to develop

\!Qids and pockets cl entrained gases. Preventing and mancging gas intrusion and accumulatbn is necessary for proper operation of the reguired RHR loop(s) and may also prevent mter hammer. pump ca~tation, and pumping cJ noncondensiblegas into the reactor vessel.

Selection of RHR System locations susceptible tog as accumulation is based on a re~ew of system desgn information. including pipirn and instrumentation drawng s. isometric drawng s. plan and elevation drawngs. and calculations. The desgn re~ewis supplemented by system mlk do\M1s to validate the system hgh pants and to confirm the location and orientatbn of important compone1ts that can become sources cJ gas or could cther'Aise cause gas to be trapped or difficult to remove during system maintenance or restoration . Susceptible locations depend on plant and system configuration. such as stand-by versus operating conditions.

(continued)

Vogtle Units 1 and 2 B 3.4.6-5 E4-2 REVISION I to NL-15-0422 VEGP Technical Specification Bases Marked Up Pages (for infonnation only)

RCS Loops -l\tODE 4 B 3.4.6 BASES SURVEILLANCE SR 3.4.6.4 REQUIRErvENTS (continued) The RHR System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits . Operating procedures direct the implementing actions to meet this surveillance requirement and ensure the system is sufficiently filled with water.

RHR System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration . or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY.

The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The RHR system is assumed to remain sufficiently filled with water and may be restarted following short term duration RHR shutdowns, if no evolutions were performed that can introduce voids into the RHR loop.

(continued)

Vogtle Units 1 and 2 B 3.4.6-6 E4-3 REVISION I

Enclosure 4 to NL-15-0422 VEGP Technical Specification Bases Marked Up Pages (for information only)

RCS Loops- rvDDE 4 8 3.4.6 BASES SURVEILLANCE SR 3.4.6.4 REQUIRErvENTS (continued) This SR is modified by Note 1 that states the SR is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 4. In a rapid shutdown. there may be insufficient time to verify all susceptible locations prior to entering MODE 4.

This SR is modified by Note 2 clarifying that the SR may be met for a running RHR Loop by virtue of having the RHR Loop in service in accordance with operating procedures except when the RHR Loop is in a low flow system operation which could allow the potential of gas voids not transporting through the system and the potential accumulation of gas voids in stagnant branch lines .

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program . The Surveillance Frequency may vary by location susceptible to gas accumulation.

REFERENCES None.

Vogtle Units 1 and 2 8 3.4.6-7 E4-4 REVISION I to NL-15-0422 VEGP Technical Specification Bases Marked Up Pages (for information only)

RCS Loops- l'vODE 5, Loops Filled B 3.4.7 BASES SURVEILLANCE SR 3.4.7.3 (continued)

REQUIRENENTS Verfication is perfonned by verifying proper brea<er algnmert and pov.er available to the RHR pump. If secondary side VIBter level is above the highest point cf the SG U-tubes in at least tv.o SGs, this Surveillance is not needed. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.7.4 RHR System pipirq and components have the potential to develop

\Qids and pockets of entrained gases. Preventing and manooirg gas intrusion and accumulatbn is necessary for proper operation cf the required RHR loop(s) and may also prevent VIBter hammer, pump cavitation, and pumpirg of noncondensiblegas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system desgn infonnation, including pipirg and instrumentation drawng s, isometric dra'J'.Ang s, plan and elevation drawng s, and calculations. The desgn review is supplemented by system VIBik do'M'ls to validate the system hg h ponts and to confinn the location and orientatbn of important components that can become sources cf gas or could other\Mse cause gas to be trapped or difficult to remove durirg system maintenance or restoration . Susceptible locations depend on plant and system confguration, such as stand-by versus operating conditions.

The RHR System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the

\Qiume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas \Qiume at the suction or discharge cf a pump), the Surveillance is not met. If~ is detennined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with VIBter), the Surveillance may be declared met. Accumulated gas should be eliminated or brought IMthin tte acceptance criteria limits.

Operating procedures direct the implementing actions to meet this surveillance requirement and ensure the system is sufficiently filled with water.

(continued)

Vogtle Units 1 and 2 B 3.4.7-6 E4-6 REVISION I to NL-15-0422 VEGP Technical Specification Bases Marked Up Pages (for information only)

RCS Loops- tvODE 5, Loops Filled B 3.4.7 BASES SURVEILLANCE SR 3.4.7.4 (continued)

REQUIRErv£NT S RHR System locations susceptible togas accumulation are monitored and. if gas is found. the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path 11\hich are subject to the same gas intrusion mechanisms may be verified by monitoring a representative subset of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions. the plant confguration. or personnel safety. For these locations alternative methods (e.g ..

operating parameters. ranote monitoring) may be used to monitor the susceptible location. l\lbnitoring is not required for susceptible locations 11\here the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABIUTY. The acruracyof the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY durirg the Surveillance interval.

The RHR system is assumed to remain sufficiently filled with water and may be restarted following short term duration RHR shutdowns.

if no evolutions were performed that can introduce voids into the RHR loop.

This SR is modified by a Note clarifying that the SR may be met for a running RHR Loop by virtue of having the RHR Loop in service in accordance with operating procedures except when the RHR Loop is in a low flow system operation which could allow the potential of gas voids not transporting through the system and the potential accumulation of gas voids in stagnant branch lines.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Prooram . The Surveillance Frequency may vary by location susceptible to gas accumulation .

REFERENCES None.

Vogtle Units 1 and 2 B 3.4.7-7 E4-7 REVISION I to NL-15-0422 VEGP Technical Specification Bases Marked Up Pages (for infonnalion only)

RCS Loops-l'vODE 5, Loops Not Filled B 3.4.8 BASES SURVEILLANCE SR 3.4.8.3 REQUIREI\tENTS (continued) Verlication that the required valve(s) are closed (except as provided in Note 3 to the LCO) wll preclude an uncontrolled boron dilution event in l'vODE 5 wth the RCS loops not filled. Since these valves are required to be secured in position, a frequency of 31 days is sufficient to ensure that they remain closed as required.

SR 3.4.8.4 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR loops and may also prevent water hammer. pump cavitation. and pumping of noncondensible gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system desg n information. includirg piping and instrumentation drawings, isometric drawings. plan and elevation drawings. and calculations. The desgn review is supplemented by system v.alk downs to validate the system hg h points and to confirm the location and orientation of important components that can become sources of gas or could otherwise cause gas to be trapped or dfficu~ to remove during system maintenance or restoration. Susceptible locations depend on plant and system confg uration. such as stand-by versus operating conditions.

The RHR System is OPERABLE \/\hen it is sufficiently filled with water. Acceptance criteria are established for the volume cl accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e .. the system is sufficiently filled wth water). the Surveillance may be declared met. Accumulated gas should t:e eliminated or brought within the acceptance criteria limits. Operating procedures direct the implementing actions to meet this surveillance requirement and ensure the system is sufficiently filled with water.

continued Vogtle Units 1 and 2 B 3.4.8-5 E4-9 Revision No. I to NL-15-0422 VEGP Technical Specification Bases Marked Up Pages (for infom1ation only)

RCS Loops- l'vODE 5, Loops Not Filled B 3.4.8 BASES SURVEILLANCE SR 3.4.8.4 REQUIREr£NTS (continued) RHR System locations susceptible to gas accumulation are monitored and. if gas is found. the gas wlume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path 'Ahich are subject to the same gas intrusion mechanisms may be verified by monitorirn a representative sub-set of susceptible locations.

l\lbnitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions. the plant confg uration. or personnel safety. For these locations alternative methods (e.g.,

operatirn parameters. remote monttoring) may be used to monitor the susceptible location. Nbnitoring is not reg uired for susceptible locations 'Ahere the maximum potential accumulated gas void volume has been evaluated and determined to not challerne system OPERABIUTY. The accuracy of the method used for monitori!JI the susceptible locations and trendi!JI of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The RHR system is assumed to remain sufficiently filled with water and may be restarted following short term duration RHR shutdowns.

if no evolutions were performed that can introduce voids into the RHR loop.

This SR is modified by a Note clarifying that the SR may be met for a running RHR Loop by virtue of having the RHR Loop in service in accordance with operating procedures except when the RHR Loop is in a low flow system operation which could allow the potential of gas voids not transporting through the system and the potential accumulation of gas voids in stagnant branch lines.

The Surveillance Freg uency is controlled under the Surveillance Frequency Control Prooram . The Surveillance Frequency may vary

.Qy location susceptible to gas accumulation.

REFERENCES 1. FSAR, Subsection 15.4.6.

Vogtle Units 1 and 2 B 3.4.8-6 E4-10 Revision No. I to NL-15-0422 VEGP Technical Specification Bases Marked Up Pages (for information only)

RHR and Coolant Circulation- HghWater Level 8 3.9.5 BASES ACTIONS A.3 (continued)

VJater level 2:: 23 ft above the top cl the reactor vessel flarg e, corrective actions shall be initiated immediately.

If RHR loop r~uirements are not met, all containment penetrations providing direct access from the containment atmosphere to the outside atmosphere must be closed wthin 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Wlh the RHR loop requirements not met, the potential exists for the coolant to boil and release radioactive gas to the containment atmosphere. Closing containment penetrations that are open to the outside atmosphere ensures dose limits are not exceeded.

The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is reasonable, based on the low probability cl the coolant boiling in that time.

SURVEILLANCE SR 3.9.5.1 REQUIREIVENT S This Surveillance demonstrates that the RHR loop is in operation and circulating reactor coolant. The flow rate (FIC-0618A and FIC-0619A) is determined by the flow rate necessary to provide sufficient decay heat removal capability and to provide m i>dng ri the borated coolant to pre>vent thermal and boron stratlication in the core. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.9.5.2 RHR System pipirn and components ha>ve the potential to de>velop

\/Qids and pockets of entrained gases. Pre>venting and mancgirg gas intrusion and accumulation is necessarvfor proper operation cl the RHR loops and may also pre>vent \t\8ter hammer, pump cavitation, and pumpirn ri noncondensiblegas into the reactor

>vessel.

Selection of RHR System locations susceptible tog as accumulation is based on a review of system des!:m information, including pipirg and instrumentation drawng s, isometric dra\Mng s, plan and elevation dra\Mngs, and calculations. The desgn review is supplemented by system \t\81k doiMls to validate the system hgh ponts and to confirm the location and orientatbn cl important components that can become sources cl gas or could other'A4se cause gas to be trapped or difficult (continued)

Vogtle Units 1 and 2 8 3.9.5-4 E4-20 REVISION I to NL-15-0422 VEGP Technical Specification Bases Marked Up Pages (for information only)

RHR and Coolant Circulation- HghWater Level B 3.9.5 BASES SURVEILLANCE SR 3.9.5.2 (continued)

REQUIRErvENTS to remove durina svstem maintenance or restoration. Susceptible locations depend on plant and svstem configuration. such as stand-by versus operating conditions.

The RHR System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump). the Surveillance is not met. If it is determined by subseauent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e .. the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. Operating procedures direct the implementing actions to meet this surveillance requirement and ensure the system is sufficiently filled with water.

RHR System locations susceptible to gas accumulation are monitored and. if gas is found. the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path Wlich are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

1\fonitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions. the plant confquration. or personnel safety. For these locations alternati\e methods (e.g.,

operatim parameters. remote monttorirg) may be used to monitor the susceptible location. 1\fonitoring is not rea uired for susceptible locations WI ere the maximum potential accumulated gas void volume has been evaluated and determined to not challerge system OPERABILITY. The accuracy of the method used for monitorirg the susceptible locations and trending c:i the results should be sufficient to assure system OPERABILITY during the Sur\eillance interval.

The RHR system is assumed to remain sufficiently filled with water and may be restarted following short term duration RHR shutdowns.

if no evolutions were performed that can introduce voids into the RHR loop.

This SR is modified by a Note clarifying that the SR may be met for a running RHR Loop by virtue of having the RHR Loop in service in accordance with operating procedures except when the RHR Loop is in a low flow system operation which could allow the potential of gas voids not transporting through the system and the potential accumulation of gas voids in stagnant branch lines.

(continued)

Vogtle Units 1 and 2 B 3.9.5-4 E4-21 REVISION I to NL-15-0422 VEGP Technical Specification Bases Marked Up Pages (for information only)

RHR and Coolant Circulation- HighWater Level 8 3.9.5 BASES SURVEILLANCE SR 3.9.5.2 (continued)

REQUREMENTS The Surveillance Froo uency is controlled under the Surveillance FroouencyControl Prooram . The Surveillance Frequency may vary by location susceptible tog as accumulation.

REFERENCES NONE Voqtle Units 1 and 2 8 3.9.5-5 E4-22 REVISION I to NL-15-0422 VEGP Technical Specification Bases Marked Up Pages (for infonnation only)

RHR and Coolant Circulation - Low Water Level B 3.9.6 BASES (continued)

SURVEILLANCE SR 3.9.6.1 REQUIREfvENTS This Surveillance demonstrates that one RHR loop is in operation and circulating reactor coolant. The flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability and to provide mixing r:l the borated coolant to prevent thermal and boron stratfication in the core. In addition , during operation ci the RHR loop

'Nith the V~Ster level in the vicinity of the reactor vessel nozzles, the RHR pump suction requirements must be met. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.9.6.2 RHR System piping and components have the potential to develop wids and pockets r:l entrained gases. Preventing and manc:ging gas intrusion and accumulatbn is necessary for proper operation of the RHR loops and may also prevent V~Ster hammer. pump cavitation, and pumping of noncondensible gas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system desgn information, including piping and instrumentation drawng s, isometric drawng s. plan and elevation drawngs. and calculations. The desgn review is supplemented by system V~Sik do\M1s to validate the system hg h pohts and to confirm the location and orientation of important components that can become sources ci gas or could otheriMse cause gas to be trapped or difficult to remove during system maintenance or restoration . Susceptible locations depend on plant and system confguration, such as stand-by versus operating conditions.

The RHR System is OPERABLE when it is sufficiently filled with water.

Acceptance criteria are established f or the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the wlume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas wlume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsoo uent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with V~Ster), the Surveillance may be declared met. Accumulated gas should be eliminated or brolfJ ht wthin the acceptance criteria limits.

Operating procedures direct the implementing actions to meet this surveillance requirement and ensure the system is sufficiently filled with water.

(continued)

Vogtle Units 1 and 2 B 3.9.6-4 E4-24 REVISION I to NL-15-0422 VEGP Technical Specification Bases Marked Up Pages (for information only)

RHR and Coolant Circulation - Low Water Level B 3.9.6 BASES SURVEILLANCE SR 3.9.6.2 (continued)

REQUIREI\tENTS RHR System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system f low path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical f or locations that are inaccessible due to radiological or environmental conditions. the plant configuration, or personnel safety. For these locations alternative methods (e.g.,

operating parameters. remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The RHR system is assumed to remain sufficiently filled with water and may be restarted following short term duration RHR shutdowns.

if no evolutions were performed that can introduce voids into the RHR loop.

This SR is modified by a Note clarifying that the SR may be met for a running RHR Loop by virtue of having the RHR Loop in service in accordance with operating procedures except when the RHR Loop is in a low flow system operation which could allow the potential of gas voids not transporting through the system and the potential accumulation of gas voids in stagnant branch lines.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The Surveillance Frequency may vary by location susceptible to gas accumulation .

REFERENCES NONE Vogtle Units 1 and 2 B 3.9.6-5 E4-25 REVISION I