NL-17-0783, Supplemental Response to the NRC Request for Additional Information of February 3, 2017, on the Requested TS Change to Adopt the Risk Informed Completion Time Program

Supplemental Response to the NRC Request for Additional Information of February 3, 2017, on the Requested TS Change to Adopt the Risk Informed Completion Time Program

ML17124A679
Person / Time
Site:	Vogtle
Issue date:	05/04/2017
From:	Hutto J Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-17-0783
Download: ML17124A679 (16)

Text

~ Southern Nuclear J.J. Hutto Regulatory Affairs Director 40 hncmes'> Center PJrkway Po~t Office Box 1295 HtrminghJm. AI 3~242 205 992 5ll72 tel 205 992 760 I fax jjhuno@southemco com MAY 0 4 2011 Docket Nos.: 50-424 NL-17-0783 50-425 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant, Units 1 and 2 Supplemental Response to the NRC Request for Additional Information of February 3, 2017, on The Requested TS Change to Adopt the Risk Informed Completion Time Program Ladies and Gentlemen:

By letter dated September 13, 2012, Southern Nuclear Operating Company (SNC) submitted a license request to modify the Vogtle Electric Generating Plant (VEGP), Units 1 and 2, Technical Specifications (TS) to implement risk informed completion times into their TS, per the guidelines of Nuclear Energy Institute (NEI) Report 06-09, Revision 0-A, "Risk Informed Technical Specifications (RMTS) Guidelines". Since then, several requests for additional information (RAI) from the Nuclear Regulatory Commission (NRC) staff and subsequent responses from SNC have been docketed.

The latest of those RAis was received from the NRC on February 3, 2017, and subsequently modified by the NRC via a March 3, 2017 correspondence to SNC. SNC responded to the RAI by two separate letters: one on March 13, 2017 and the second on April14, 2017.

Telephone conferences were held between the NRC and SNC on April 26 and 28, 2017, where the NRC sought clarification on several of those SNC responses. As a result, the NRC requested that additional information be provided on the docket. Enclosures 1 and 2 to this letter provide that information. provides a clarification to the SNC response to RAI #5 from the April 14, 2017 letter. Enclosure 2 provides a proposed marked-up and clean page to VEGP TS Section 5.5.22.

The revised paragraph g. of Section 5.5.22 provides amplification on the subject of common cause failures.

All the TS changed pages were provided to the NRC in the April14, 2017 correspondence. The TS pages for Section 5.5.22 in this letter replace the Section 5.5.22 pages provided in the April 14 letter. All other TS pages in the April 14 letter remain valid.

This letter contains no new NRC commitments.

If you have any questions, please contact Ken McElroy at 205.992.7369

U. S. Nuclear Regulatory Commission NL-17-0783 Page 2 Mr. J.J. Hutto 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,

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J. J. Hutto i I

Regulatory Affairs Director ',

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ribed before me this-!/---- day of_,,_JVIL....J..!<wff=-...,t~r-------12017.

My commission expires: /6 -'t - d-o 11

Enclosures:

1. Response to Request for Additional Information

2. Marked-Up and Clean TS Pages for Section 5.5.22 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Best, Executive Vice President & Chief Nuclear Officer Mr. R. D. Gayheart, Fleet Operations General Manager Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. B. K. Taber, Vice President- Vogtle 1 & 2 Mr. B. J. Adams, Vice President- Engineering Mr. D. D. Sutton, Regulatory Affairs Manager- Vogtle 1 & 2 RType: CVC7000 U.S. Nuclear Regulatory Commission Ms. C. Haney, Regional Administrator Mr. M.D. Orenak, NRR Project Manager- Vogtle 1 & 2 Mr. M. F. Endress, Senior Resident Inspector- Vogtle 1 & 2 State of Georgia Mr. R. E. Dunn, Director- Environmental Protection Division

Vogtle Electric Generating Plant, Units 1 and 2 Supplemental Response to the NRC Request for Additional Information of February 3, 2017, on The Requested TS Change to Adopt the Risk Informed Completion Time Program Enclosure 1 Response to Request for Additional Information to NL-17-0783 Response to Request for Additional Information NRC RAI #5 (From February 3, 2017 NRC RAI)

While the guidance in NEI 06-09 states that no common cause failure (CCF) adjustment is required for planned maintenance, the NRC approval of NEI 06-09 is based on RG 1.177, as indicated in the NRC safety evaluation to NEI 06-09. Specifically, Section 2.2 of the NRC safety evaluation for NEI 06-09 (ADAMS Accession No. ML071200238) states that, "specific methods and guidelines acceptable to the NRC staff are [ ... ] outlined in RG 1.177 for assessing risk-informed TS changes." Further, Section 3.2 of the NRC safety evaluation states that compliance with the guidance of RG 1.174 and RG 1.177, "is achieved by evaluation using a comprehensive risk analysis, which assesses the configuration-specific risk by including contributions from human errors and common cause failures."

The guidance in RG 1.177, Section 2.3.3.1, states that, "CCF modeling of components is not only dependent on the number of remaining inservice components, but is also dependent on the reason components were removed from service (i.e. whether for preventative or corrective maintenance)." In relation to CCF for preventive maintenance, the guidance in RG 1.177, Appendix A, Section A-1.3.1.1 , states:

If the component is down because it is being brought down for maintenance, the CCF contributions involving the component should be modified to remove the component and to only include failures of the remaining components (also see Regulatory Position 2.3.1 of Regulatory Guide 1.177).

According to RG 1.177, if a component from a CCF group of three or more components is declared inoperable, the CCF of the remaining components should be modified to reflect the reduced number of available components in order to properly model the as-operated plant.

Please confirm and describe how the treatment of CCF either meets the guidance in RG 1.177 or meets the intent of this guidance when quantifying a RICT.

Response to RAI #5 The below response supplements the response to RAI #5 provided in the April14, 20171etter:

The Vogtle 1 & 2 Configuration Risk Management Program (CAMP) model includes common cause basic events in the fault trees. An example of common cause event modeling within the Vogtle 1 & 2 CRMP model is shown in Figures X-1, X-2, X-3, & X-4.

For planned maintenance, the Vogtle 1 & 2 CRMP does not adjust failure probabilities of common cause basic events. In the case of planned maintenance on a single component in a common cause group of four, the failure probability of the basic event representing independent failure is set to 1.0 and the failure probabilities for the common cause basic events are not modified to reflect a reduced number of available components. As a result, the common cause basic events involving failure of the component out of service for maintenance (7 total for the CC group of 4) remain in the fault trees. Thus, all eleven common cause basic events may appear in the cutsets upon re-quantification of the trees in support of the RICT calculation.

The method of modifying common cause basic events would involve re-calculation of the common cause basic event failure probabilities using common cause factors based on the reduced group size. For a common cause group of four, the common cause basic events involving failure of the component out of service for maintenance (7 total for the CC group of 4) would become zero (false) and would not appear in cutsets. The remaining 4 common cause E1-1 to NL-17-0783 Response to Request for Additional Information events would have a re-calculated failure probability using a higher common cause factor.

Thus, four common cause basic events could appear in the cutsets upon re-quantification of the trees in support of the RICT calculation. As stated above, SNC is not proposing to modify the factors for planned maintenance.

A comparison of the methods using the Vogtle 1 & 2 CRMP tool was performed to observe the impact on CDF/LERF results. The two methods generate CDF/LERF results that are negligibly different, and thus have a negligible impact on the calculated RICT.

The first scenario assessed is the '8' train battery removed from service for planned maintenance. The safety-related battery belongs to a common cause group of four. Adjustment of common cause events generates an increase in CDF of 3.0E-1 0/year as compared to the result from the approach that implements no adjustments. Adjustment of common cause events generates no change in LERF for the scenario. The impact of the common cause adjustment is a decrease of 4 seconds in the 24.2 day RICT.

The second scenario assessed is 'A' train inverter 1AD111 removed from service for planned maintenance. The safety-related inverter belongs to a common cause group of four.

Adjustment of common cause events generates an increase in CDF of 4.0E-09/year as compared to the result from the approach that implements no adjustments. Adjustment of common cause events generates an increase in LERF of 1.2E-09/year as compared to the result from the approach that implements no adjustments. The impact of the common cause adjustment is a decrease of 1 second in the 3.5 day RICT. Note that a RICT would not be permitted for the scenario based on instantaneous CDF and LERF exceeding the 1E-03/year and 1E-04/year thresholds.

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Vogtle Electric Generating Plant, Units 1 and 2 Supplemental Response to NRC Request for Additional Information of February 3, 2017, on the Requested TS Change to Adopt the Risk Informed Completion Time Program Enclosure 2 Marked-Up and Clean TS Pages for Section 5.5.22

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.20 Control Room Envelope Habitability Program (continued)

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

5.5.21 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c. The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

Insert 3 Vogtle Units 1 and 2 5.5-20 Amendment No. +a8 (Unit 1)

Amendment No. -MG (Unit 2)

INSERT3 5.5.22 Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI-06-09, Revision 0-A, "Risk-Managed Technical Specifications (RMTS) Guidelines." The program shall include the following:

a. The RICT may not exceed 30 days.

b. A RICT may only be utilized in MODE 1 and 2.

c. When a RICT is being used, any plant configuration change within the scope of the Configuration Risk Management Program must be considered for the effect on the RICT.

1. For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

2. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.

3. Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.

d. Use of a RICT is not permitted for voluntary entry into a configuration which represents a loss of a specified safety function or inoperability of all required trains of a system required to be OPERABLE.

e. Use of a RICT is permitted for emergent conditions which represent a loss of a specified safety function, or inoperability of all required trains of a system required to be OPERABLE, if one of more of the trains are considered "PRA Functional" as defined in Section 2.3.1 of NEI 06-09. The RICT for these loss of function conditions may not exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

f. Use of a RICT is permitted for emergent conditions which represent a loss of a specified safety function or inoperability of all required trains of a system required to be OPERABLE if one or more trains are considered "PRA Functional" as defined in Section 2.3.1 of NEI 06-09. However, the following additional constraints shall be applied to the criteria for "PRA Functional".

1. Any SSCs credited in the PRA Functionality determination shall be the same SSCs relied upon to perform the specified Technical Specifications safety function.

2. Design basis success criteria parameters shall be met for all design basis accident scenarios for establishing PRA Functionality during a Technical Specifications loss of function condition where a RICT is applied.

g. Upon entering a RICT for an emergent condition, the potential for a common cause (CC) failure must be addressed.

If there is a high degree of confidence, based on the evidence collected, that there is no CC failure mechanism that could affect the redundant components, the RICT calculation may use nominal CC factor probability.

If a high degree of confidence cannot be established that there is no CC failure that could affect the redundant components, the RICT shall account for the increased possibility of CC failure. Accounting for the increased possibility of CC failure shall be accomplished by one of two methods. If one of the two methods listed below is not used, the Technical Specifications Front Stop shall not be exceeded.

1. The RICT calculation shall be adjusted to numerically account for the increased possibility of CC failure, in accordance with RG 1.177, as specified in Section A-1.3.2.1 of Appendix A of the RG. Specifically, when a component fails, the CC failure probability for the remaining redundant components shall be increased to represent the conditional failure probability due to CC failure of these components, in order to account for the possibility the first failure was caused by a CC mechanism.

OR

2. Prior to exceeding the front stop, RMAs not already credited in the RICT calculation shall be implemented. These RMAs shall target the success of the redundant and/or diverse structures, systems, and components (SSG) of the failed SSG and, if possible, reduce the frequency of initiating events which call upon the function(s) performed by the failed SSG. Documentation of RMAs shall be available for NRC review.

h. A RICT entry is not permitted, or a RICT entry made shall be exited, for any condition involving a TS loss of function if a PRA Functionality determination that reflects the plant configuration concludes that the LCO cannot be restored without placing the TS inoperable trains in an alignment which results in a loss of functional level PRA success criteria.

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.20 Control Room Envelope Habitability Program (continued)

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

5.5.21 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c. The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

5.5.22 Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI-06-09, Revision 0-A, "Risk-Managed Technical Specifications (RMTS) Guidelines." The program shall include the following:

a. The RICT may not exceed 30 days.

b. A RICT may only be utilized in MODE 1 and 2.

c. When a RICT is being used, any plant configuration change within the scope of the Configuration Risk Management Program must be considered for the effect on the RICT.

1. For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

(continued)

Vogtle Units 1 and 2 5.5-20 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.22 Risk Informed Completion Time Program (continued)

2. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e.,

not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.

3. Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.

d. Use of a RICT is not permitted for voluntary entry into a configuration which represents a loss of a specified safety function or inoperability of all required trains of a system required to be OPERABLE.

e. Use of a RICT is permitted for emergent conditions which represent a loss of a specified safety function, or inoperability of all required trains of a system required to be OPERABLE, if one of more of the trains are considered "PRA Functional" as defined in Section 2.3.1 of NEI 06-09.

The RICT for these loss of function conditions may not exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

f. Use of a RICT is permitted for emergent conditions which represent a loss of a specified safety function or inoperability of all required trains of a system required to be OPERABLE if one or more trains are considered "PRA Functional" as defined in Section 2.3.1 of NEI 06-09. However, the following additional constraints shall be applied to the criteria for "PRA Functional".

1. Any SSCs credited in the PRA Functionality determination shall be the same SSCs relied upon to perform the specified Technical Specifications safety function.

2. Design basis success criteria parameters shall be met for all design basis accident scenarios for establishing PRA Functionality during a Technical Specifications loss of function condition where a RICT is applied.

g. Upon entering a RICT for an emergent condition, the potential for a common cause (CC) failure must be addressed.

If there is a high degree of confidence, based on the evidence collected, that there is no CC failure mechanism that could affect the redundant components, the RICT calculation may use nominal CC factor probability.

If a high degree of confidence cannot be established that there is no CC failure that could affect the redundant components, the RICT shall account for the increased possibility of CC failure. Accounting for the increased possibility of CC failure shall be accomplished by one of two methods. If one of the two methods listed below is not used, the Technical Specifications Front Stop shall not be exceeded.

(continued)

Vogtle Units 1 and 2 5.5-21 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.22 Risk Informed Completion Time Program

g. (continued)

1. The RICT calculation shall be adjusted to numerically account for the increased possibility of CC failure, in accordance with RG 1.177, as specified in Section A-1.3.2.1 of Appendix A of the RG. Specifically, when a component fails, the CC failure probability for the remaining redundant components shall be increased to represent the conditional failure probability due to CC failure of these components, in order to account for the possibility the first failure was caused by a CC mechanism.

OR

2. Prior to exceeding the front stop, RMAs not already credited in the RICT calculation shall be implemented. These RMAs shall target the success of the redundant and/or diverse structures, systems, or components (SSC) of the failed SSC and, if possible, reduce the frequency of initiating events which call upon the function(s) performed by the failed SSC. Documentation of RMAs shall be available for NRC review.

h. A RICT entry is not permitted , or a RICT entry made shall be exited, for any condition involving a TS loss of function if a PRA Functionality determination that reflects the plant configuration concludes that the LCO cannot be restored without placing the TS inoperable trains in an alignment which results in a loss of functional level PRA success criteria .

Vogtle Units 1 and 2 5.5-22 Amendment No. (Unit 1)

Amendment No. (Unit 2)