NL-19-0963, Removal of the Main Steam and Main Feedwater Valve Isolation Times from Technical Specifications Using Consolidated Line Item Improvement Process

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Removal of the Main Steam and Main Feedwater Valve Isolation Times from Technical Specifications Using Consolidated Line Item Improvement Process
ML19345E724
Person / Time
Site: Vogtle, Farley  Southern Nuclear icon.png
Issue date: 12/11/2019
From: Gayheart C
Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-19-0963
Download: ML19345E724 (29)
v • d • e


Text

.. Southern Nuclear Cheryl A. Ga yheart Regulatory Affairs Director 3535 Colonnade Parkway Birmingham, AL 35243 205 992 5316 tel 205 992 7601 fax DEC 11 2019 cagayhea@ southernco.com Docket Nos.: 50-348 50-424 NL-19-0963 50-364 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 Application for Technical Specification Change TSTF-491 , Removal of the Main Steam and Main Feedwater Valve Isolation Times from Technical Specifications Using Consolidated Line Item Improvement Process Ladies and Gentlemen:

In accordance with the provisions of 10 CFR 50.90, Southern Nuclear Operating Company (SNC) is submitting a request for an amendment to the technical specifications (TS), for Joseph M. Farley Nuclear Plant (FNP) Unit 1 Renewed Facility Operating License NPF-2 and Unit 2 Renewed Facility Operating License NPF-8, and Vogtle Electric Generating Plant (VEGP) Unit 1 Renewed Facility Operating License NPF-68 and Unit 2 Renewed Facility Operating License NPF-81.

The proposed amendment would modify the FNP and VEGP TS by removing the specific isolation time for the isolation valves from the associated standard technical specifications surveillance requirements. Enclosure 1 provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications . Enclosure 2 provides the existing TS pages marked up to show the proposed change. Enclosure 3 provides revised (clean) TS pages. Enclosure 4 provides the existing TS Bases pages marked up to show the proposed change (for information only).

SNC requests approval of the proposed license amendment by June 15, 2020 with the amendment being implemented within 90 days of issuance.

In accordance with 10 CFR 50.91 (b)(1 ), a copy of this application, with enclosures, is being provided to the designated State of Alabama and State of Georgia officials.

This letter contains no NRC commitments. If you should have any questions regarding this submittal, please contact Jamie Coleman at 205.992.6611 .

U.S. Nuclear Regulatory Commission NL-19-0963 Page 2 I declare under penalty of perjury under the laws of the United States of America that I am authorized by SNC to make this request and that the foregoing is true and correct.

Executed on the \1 "$-day of December 2019.

Respectfully submitted, Cheryl heart Director, Regulatory Affairs Southern Nuclear Operating Company CAG/kgl/sm

Enclosures:

1. Description and Assessment
2. Proposed Technical Specification Changes (Mark-up)
a. FNP Units 1 and 2 TS Marked-up Pages
b. VEGP Units 1 and 2 TS Marked-up Pages
3. Proposed Technical Specification Pages
a. FNP Units 1 and 2 TS Revised Pages
b. VEGP Units 1 and 2 TS Revised Pages
4. Proposed Changes to Technical Specification Bases Pages (for information only)
a. FNP Units 1 and 2 TS Bases Marked-up Pages
b. VEGP Units 1 and 2 TS Bases Marked-up Pages cc: Regional Administrator, Region II NRR Project Manager- Farley 1 & 2 and Vogtle 1 & 2 Senior Resident Inspector- Farley 1 & 2 and Vogtle 1 & 2 Director, Alabama Office of Radiation Control State of Georgia Environmental Protection Division RTYPE: CFA04.054, CVC7000

Joseph M. Farley Nuclear Plant - Units 1 and 2 Vogtle Electric Generating Plant- Units 1 and 2 Application for Technical Specification Change TSTF-491, Removal of the Main Steam and Main Feedwater Valve Isolation Times from Technical Specifications Using Consolidated Line Item Improvement Process Enclosure 1 Description and Assessment

Enclosure 1 - Description and Assessment 1.0 Description The proposed amendment would modify technical specifications by removing the specific isolation time for the isolation valves from the associated standard technical specifications

{STS) surveillance requirements (SRs).

The changes are consistent with Nuclear Regulatory Commission (NRC) approved lndustry!Technical Specification Task Force (TSTF) TSTF-491 Revision 2. The availability of this TS improvement was published in the Federal Register on December 29, 2006 as part of the consolidated line item improvement process (CLIIP).

2.0 Assessment 2.1 Applicability of TSTF-491 and Published Safety Evaluation Southern Nuclear Operating Company (SNC) has reviewed TSTF-491 (Reference 1),

and the NRC model safety evaluation (SE) (Reference 2) as part of the CLIIP . SNC has concluded that the information in TSTF-491, as well as theSE prepared by the NRC staff, are applicable to Farley Nuclear Plant (FNP) Units 1 and 2 and Vogtle Electric Generating Plant (VEGP) Units 1 and 2 and justify this amendment for the incorporation of the changes to the FNP and VEGP TS.

2.2 Optional Changes and Variations SNC is proposing the following variations from the TS changes described in the TSTF-491, Revision 2, or the applicable parts of the NRC staff's model SE referenced in the Federal Register on October 5, 2006. These differences are considered acceptable as not significant variations in TSTF-491 and the NRC staff's model SE.

SNC has adopted TSTF traveler TSTF-545 in the FNP and VEGP TS that is not shown in the STS markups of TSTF-491. TS 5.5.8, "lnservice Testing Program," was deleted in the FNP and VEGP TS and a new defined term, "INSERVICE TESTING PROGRAM,"

was added to Section 1.1 of the TS. References to the "lnservice Testing Program," in the TS SRs and associated Bases, are replaced with "INSERVICE TESTING PROGRAM" so that the SRs refer to the new definition in lieu of the deleted program.

FNP and VEGP adoption of TSTF-545 was approved on June 30, 2017 (Reference 3) .

Other editorial differences between the plant-specific TS SRs and the SRs in the STS markups of TSTF-491 are as follows:

  • The applicable SRs in both FNP and VEGP TS refer to verifying "closure" time instead of "isolation" time. The words isolation and closure are used interchangeably in the STS bases for SRs 3.7.2.1 and 3.7.3.1 and, therefore, this minor difference does not alter the SR intent.

The differences in the SRs and associated bases as a result of adopting TSTF-545 and other plant-specific editorial differences do not modify the intent or application of the proposed change, are considered not significant, and the model SE continues to be applicable.

E1-1

Enclosure 1 - Description and Assessment The FNP and VEGP main steam isolation valve (MSIV) system design is different than the STS MSIV design specified in the model SE. Both the FNP and VEGP MSIV system design includes two MSIVs per steam line instead of one MSIV per steam line. Since LCO 3.7.2 requires both MSIVs per steam line to be operable in the FNP TS and the VEGP TS, the closure time requirement would apply to all the MSIVs. This plant-specific design difference does not impact the intent or application of the proposed change and, therefore, is not considered to be a significant difference and the model SE continues to be applicable.

FNP TS Variations SR 3.7.3.1 does not specify a closure time for the main FW stop valve , main FW regulating valve or associated bypass valve. The closure time for each valve is verified in accordance with the time requirement in the inservice testing program. This is consistent with the statement in the STS SR 3.7.3.1 bases. As such, SR 3.7.3.1 is being revised consistent with TSTF-491 and the statement regarding closure time in accordance with the inservice testing program is relocated to the TS bases. Since the valve closure timing is not specifically addressed in SR 3.7.3.1 , this value is not relocated to a licensee controlled document (i.e., Technical Requirements Manual) and the bases is revised to reflect this difference. This difference does not impact the intent or application of the proposed change, is considered not significant, and the model SE continues to be applicable.

VEGP TS Variations SR 3.7.2.1 refers to the MSIV system . The TS Bases describes the MSIV system consisting of an MSIV and associated bypass valve. Closing the two MSIV systems on a steam line isolates each steam generator from the others, and isolates the turbine ,

steam dump system , and other auxiliary steam supplies from the steam generators.

Both MSIV systems in each steam line are required to be operable to meet LCO 3.7.2, therefore, SR 3.7.2.1 would apply to both MSIV systems per steam line. The bases is revised to reflect this difference. This design difference does not impact the intent or application of the proposed change , is considered not significant, and the model SE continues to be applicable.

SRs 3.7.2.1 and 3.7.3.1 contain the added phrase, " ...on an actual or simulated actuation signal." These SRs effectively combine the STS SRs (i.e ., SRs 3.7.2.1 and 3.7.2.2; and SRs 3.7.3.1 and 3.7.3.2) to verify the isolation time of each valve and ensure that each valve actuates on an actual or simulated signal. In addition, a note is applied to VEGP SR 3.7.3.1 allowing entry into and operation in mode 2 prior to performing the SR. The bases is revised to reflect these differences. These plant-specific differences do not impact the intent or application of the proposed change, is considered not significant, and the model SE continues to be applicable.

3.0 Regulatory Analysis 3.1 No Significant Ha~ards Consideration Determination Southern Nuclear Operating Company (SNC) has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the consolidated line item improvement process (CLIIP). SNC has concluded that the E1-2

Enclosure 1 - Description and Assessment proposed NSHCD presented in the Federal Register notice is applicable to FNP and VEGP and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

3.2 Verifications and Commitments As discussed in the notice of availability published in the Federal Register on December 29, 2006 for this TS improvement, plant-specific verifications were performed as follows:

In addition, SNC has proposed TS Bases consistent with TSTF-491 which provide guidance and details on how to implement the new requirements. Finally, FNP and VEGP TS have a Bases Control Program consistent with Section 5.5 of the Standard Technical Specifications (STS).

4.0 Environmental Evaluation The amendment changes requirements with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment adopting TSTF-491 , Rev 2, involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that TSTF-491 , Rev 2, involves no significant hazards considerations, and there has been no public comment on the finding in Federal Register Notice 71 FR 193, October 5, 2006.

Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) . Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

5.0 References

1. TSTF-491, Revision 2, "Removal of Main Steam and Main Feedwater Valve Isolation Times from Technical Specifications," dated May 18, 2006 (NRC Agencywide Documents Access and Management System Accession No. ML061500078).
2. NRC Model Safety Evaluation, Federal Register, Volume 71 , No. 193, pages 58886-58888, dated October 5, 2006.
3. Letter from M.D. Orenak (NRC) to J.J. Hutto (SNC) , "Joseph M. Farley Nuclear Plant, Units 1 and 2; Vogtle Electric Generating Plant, Units 1 and 2; and Edwin I. Hatch Nuclear Plant, Unit Nos. 1 and 2 - Issuance of Amendments Regarding the Adoption of TSTF-545, Revision 3, "TS lnservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing" (CAC Nos. MF8176, MF8177, MF8178, MF8179, MF8180, AND MF8181) ," dated June 30,2017 (NRC ADAMS Accession No. ML17152A218).

E1 -3

Joseph M. Farley Nuclear Plant - Units 1 and 2 Vogtle Electric Generating Plant - Units 1 and 2 Application for Technical Specification Change TSTF-491, Removal of the Main Steam and Main Feedwater Valve Isolation Times from Technical Specifications Using Consolidated Line Item Improvement Process Enclosure 2 Proposed Technical Specification Changes (Mark-up)

Enclosure 2.a FNP Units 1 and 2 TS Marked-up Pages

MSIVs 3.7.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. One or more steam lines E.1 Verify one MSIV closed in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> with two MSIVs affected steam line.

inoperable in MODE 2 At:ill or 3.

Once per 7 days thereafter F. Required Action and F.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition D or E AND not met.

F.2 Be in MODE4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 -----------------------------NOTE-------------------------------

Only required to be performed in MODES 1 and 2.

Verify closure time of each MSIV is ~ 7-seeGRGs. In accordance with the INSERVICE within limits TESTING PROGRAM Farley Units 1 and 2 3.7.2-2 Amendment No. m (Unit 1)

Amendment No.~ (Unit 2)

Main FW Stop Valves and MFRVs and Associated Bypass Valves 3.7.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. One or more MFRV C.1 Close or isolate bypass 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> bypass valves valve.

inoperable.

AND C.2 Verify bypass valve is closed Once per 7 days or isolated.

D. Two valves in the same D.1 Isolate affected flow path. 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> flow path inoperable.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Tim~ not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Verify the closure time of each Main FW Stop Valve, In accordance with MFRV, and associated bypass valve is *R-aGC-&FEiaAC-e the INSERVICE wRR-tfle-time requirement in--tRe-t-NSERVIGE TESTING tESTING PROGRAM. PROGRAM.

within limits Farley Units 1 and 2 3.7.3-2 Amendment No.~ (Unit 1)

Amendment No.~ (Unit 2)

Enclosure 2.b VEGP Units 1 and 2 TS Marked-up Pages

MSIVs 3.7.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

c. Required Action and C.1 Be in MODE 2. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A or B not met.

D. One or more steam lines D.1 Verify one MSIV system 7 days with one MSIV system closed in affected steam inoperable in MODE 2 or AND

3. line.

Once per 7 days thereafter.

E. One or more steam lines E.1 Verify one MSIV system 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> with two MSIV systems closed in affected steam inoperable in MODE 2 or line. AND 3.

Once per 7 days thereafter F. Required Action and F.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition D or AND E not met.

F.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 ----------------------------NOTE-----------------------------

Only required to be performed in MODES 1 and 2.

Verify closure time of each MSIV system is In accordance with the

~econds on an actual or simulated actuation INSERVICE TESTING signal . t ~ PROGRAM

~

Vogtle Units 1 and 2 3.7.2-2 Amendment No.48&{Unit 1)

Amendment No:-ffi (Unit 2)

MFIVs and MFRVs and Associated Bypass Valves 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more MFRVor C.1 Close or isolate bypass 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> MFIV bypass valves valve.

inoperable.

AND C.2 Verify bypass valve is Once per 7 days closed or isolated.

D. Both isolation systems D.1 Isolate affected feedwater 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable in one or line.

more feedwater lines.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 -----------------------------NOTE:-----------------------------

Only required to be performed in MODE 1.

Verify the closure time of each MFIV, MFRV, and In accordance with associated bypass valve is ~ &-seooRas on an the INSERVICE actual or simulated actuation signal. TESTING PROGRAM

~ within limits Vogtle Units 1 and 2 3.7.3-2 Amendment No.M+ (Unit 1)

Amendment No.+79 (Unit 2)

Joseph M. Farley Nuclear Plant - Units 1 and 2 Vogtle Electric Generating Plant - Units 1 and 2 Application for Technical Specification Change TSTF-491, Removal of the Main Steam and Main Feedwater Valve Isolation Times from Technical Specifications Using Consolidated Line Item Improvement Process Enclosure 3 Proposed Technical Specification Pages

Enclosure 3.a FNP Units 1 and 2 TS Revised Pages

MSIVs 3.7 .2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. One or more steam lines E.1 Verify one MSIV closed in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> with two MSIVs affected steam line.

inoperable in MODE 2 AND or 3.

Once per 7 days thereafter F. Required Action and F.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition D or E AND not met.

F.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 -------------------------------NOTE-------------------------------

Only required to be performed in MODES 1 and 2.

Verify closure time of each MSIV is within limits. In accordance with the INSERVICE TESTING PROGRAM Farley Units 1 and 2 3.7.2-2 Amendment No. (Unit 1)

Amendment No . (Unit 2)

Main FW Stop Valves and MFRVs and Associated Bypass Valves 3.7.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. One or more MFRV C.1 Close or isolate bypass 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> bypass valves valve.

inoperable.

AND C.2 Verify bypass valve is closed Once per 7 days or isolated.

D. Two valves in the same D.1 Isolate affected flow path . 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> flow path inoperable.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Verify the closure time of each Main FW Stop Valve , In accordance with MFRV, and associated bypass valve is within limits. the INSERVICE TESTING PROGRAM .

Farley Units 1 and 2 3.7.3-2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Enclosure 3.b VEGP Units 1 and 2 TS Revised Pages

MSIVs 3.7.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 2. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A or B not met.

D. One or more steam lines D.1 Verify one MSIV system 7 days with one MSIV system closed in affected steam inoperable in MODE 2 or AND

3. line.

Once per 7 days thereafter.

E. One or more steam lines E.1 Verify one MSIV system 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> with two MSIV systems closed in affected steam inoperable in MODE 2 or line. AND 3.

Once per 7 days thereafter F. Required Action and F.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition D or AND E not met.

F.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 ----------------------------NOTE-----------------------------

Only required to be performed in MODES 1 and 2.

Verify closure time of each MSIV system is In accordance with the within limits on an actual or simulated actuation INSERVICE TESTING signal. PROGRAM Vogtle Units 1 and 2 3.7.2-2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

MFIVs and MFRVs and Associated Bypass Valves 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more MFRV or C.1 Close or isolate bypass 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> MFIV bypass valves valve.

inoperable.

AND C.2 Verify bypass valve is Once per 7 days closed or isolated .

D. Both isolation systems D.1 Isolate affected feedwater 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable in one or line.

more feedwater lines.

E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 -----------------------------NOTE-----------------------------

Only required to be performed in MODE 1.

Verify the closure time of each MFIV, MFRV, and In accordance with associated bypass valve is within limits on an the INSERVICE actual or simulated actuation signal. TESTING PROGRAM Vogtle Units 1 and 2 3.7.3-2 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 Application for Technical Specification Change TSTF-491, Removal of the Main Steam and Main Feedwater Valve Isolation Times from Technical Specifications Using Consolidated Line Item Improvement Process Enclosure 4 Proposed Changes to Technical Specification Bases Pages (for information only)

Enclosure 4.a FNP Units 1 and 2 TS Bases Marked-up Pages

MSIVs B 3.7.2 BASES ACTIONS D.1 (continued) in the safety analysis remain valid . The 7-day Completion Time is reasonable, based on engineering judgment, in view of MSIV status indications available in the control room, and other administrative controls, to ensure that these valves are in the closed position .

With two MSIVs inoperable in one or more steam lines in MODE 2 or 3, action must be taken to restore one MSIV to OPERABLE status or verify one MSIV closed in the affected steam line(s) within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. In this condition , the affected steam line has no OPERABLE automatic isolation capability. Verifying one MSIV system closed ensures the safety function is accomplished for that steam line. The 4-hour Completion Time is reasonable considering the low probability of an accident occurring during this time that would require a MSIV to close.

For inoperable MSIVs that cannot be restored to OPERABLE status and are closed, the MSIV must be verified closed on a periodic basis .

Verification that the MSIV is closed on a periodic basis is necessary to ensure that the safety analysis assumptions remain valid . The 7-day Completion Time is reasonable, based on engineering judgment, considering the MSIV indications available in the control room , and other administrative controls, to ensure that these valves are closed .

F.1 and F.2 If the MSIVs cannot be restored to OPERABLE status or are not closed within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed at least in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from MODE 2 conditions in an orderly manner and without challenging unit systems.

of each MSIV within the limit given in Reference 6 SURVEILLANCE SR 3.7.2.1 M verifie~Jw REQUIREMENTS This SR closure time is 5 n an actual or simulated actuation signal. The MSIV olosure time is assumed in the (continued)

Farley Units 1 and 2 B 3.7.2-6 Revision 0

MSIVs This SR also verifies the valve closure time is in B 3.7.2 accordance with the INSERVICE TESTING PROGRAM .

BASES SURVEILLANCE SR 3.7.2.1 (continued) ~

REQUIREMENTS accident and containment analyses:VThis Surveil~ is normally performed while returning the unit to operation following a refueling outage.

The Frequency is in accordance with the INSERVICE TESTING PROGRAM , which encompasses the ASME OM Code (Ref. 5) .

Operating experience has shown that these components usually pass the Surveillance when performed in accordance with the INSERVICE TESTING PROGRAM . Therefore, the Frequency is acceptable from a reliability standpoint.

This SR is modified by a Note that allows entry into and operation in MODE 3 prior to performing the SR. If desired , this allows a delay of testing until MODE 3, to establish conditions consistent with those under which the acceptance criterion was generated . This surveillance may be performed in lower modes but must be performed prior to entry into MODE 2.

REFERENCES 1. FSAR, Section 10.3.

2. FSAR, Section 6.2.
3. FSAR, Section 15.4.2.
4. 10 CFR 50.67 .
5. ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) .

/1:-,.

Farley Units 1 and 2 B 3.7.2-7 Revision 88

Main FW Stop Valves and MFRVs and Associated Bypass Valves B 3.7 .3 BASES ACTIONS E.1 and E.2 (continued) experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems .

SURVEILLANCE SR 3.7.3.1 REQUIREMENTS This SR verifies that the closure time of each Main FW Stop Valve and MFRV and its associated bypass valve is in accordance with the requirements of the INSERVICE TESTING PROGRAM. The Main and is within that {--~w~~V-al¥e-afiG-Ivt~RV closure times are assumed in the accident

'-A..:A...A..A...A..-"-"~...A.Jo..A..J'-.J and containment analyses. This Surveillance is normally performed during return of the unit to operatior *allowing a refueling outage.

These valves should not be tested at power since even a part stroke exercise increases the risk of a valve closure with the unit generating power. This is consistent with the ASME OM Code (Ref. 2) .

The Frequency for this SR is in accordance with the INSERVICE TESTING PROGRAM . Operating experience has shown that these components usually pass the Surveillance when performed in accordance with the INSERVICE TESTING PROGRAM .

REFERENCES 1. FSAR, Section 10.4 .7.

2. ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) .

Farley Units 1 and 2 B 3.7.3-6 Revision 84

Enclosure 4.b VEGP Units 1 and 2 TS Bases Marked-up Pages

MSIVs within the limit given in Reference 9 B 3.7.2 of each MSIV system BASES SURVEILLANCE SR 3.7.2.1 and is REQUIREMEN TS within that This SR verifies that MSIV and by-pass valve closure time s rv-v-v-v-v-....r-.t...,..,...,.....,<"V"'.rv--rv-v-v-v-v........ "'!:::-&-~=**'l-9& on an actual or simulated actuation signal,-

. -+fle-fll~tet'+

This SR also verifies the closure time is assumed in the accident and containment analyses .

This Surveillanse

  • normally performe turning the unit to valve closure time is in operation followin * . SR accordance with the INSERVICE TESTING The Frequency is in accordance with the INSERVICE TESTING PROGRAM . PROGRAM . Operating experience has shown that these components usually pass the Surveillance when performed in accordance with the

'-".A..-".A..-"..A.Jo..A.Jo~~'-A.-1'-"-'"-"'-"-"-' INSERVICE TESTING PROGRAM . Therefore , the Frequency is acceptable from a reliability standpoint.

This SR is modified by a Note that allows entry into and operation in MODE 3 prior to performing the SR. If desired, this allows a delay of testing until MODE 3, to establish conditions consistent with those under which the acceptance criterion was generated .

REFERENCES 1. FSAR, Section 10.3.

2. FSAR, Section 6.2.
3. FSAR , Subsection 15.1.5.
4. FSAR, Subsection 15.4.9.
5. FSAR , Subsection 15.2.8.
6. 10CFR100.11 .
7. ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code).
8. Vogtle Electric Generating Plant, Units 1 and 2 - Issuance of Amendments Regarding Implementation of Topical Report Nuclear Energy Institute NEI 06-09 , "Risk-Informed Technical Specifications Initiative 48, Risk-Managed Technical Specifications (RMTS) Guidelines," Revision 0-A (CAC Nos.

ME9555 and ME9556) .

Vogtle Units 1 and 2 B 3.7.2-7 REVISION 48

MFIVs and MFRVs and Associated Bypass Valves B 3.7.3 BASES ACTIONS D.1 (continued)

The term isolation system as used in this Condition consists of an MFIV and associated bypass valve or an MFRV and associated bypass valve. An OPERABLE system may include inoperable valve(s) provided the inoperable valves are closed and deactivated . This is acceptable since the closed isolation valve(s) are performing their intended safety function . Since the MODE of Applicability excepts valves that are closed and deactivated, the LCO is no longer applicable to those valves .

E.1 and E.2 If the MFIV(s) and MFRV(s) and the associated bypass valve(s) cannot be restored to OPERABLE status , or closed , or isolated within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status ,

the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> . The allowed Completion Time is reasonable , based on operating experience , to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems .

SURVEILLANCE SR 3.7.3.1 within the limit given in Reference 3 REQUIREMENTS This SR also verifies the valve closure time is in accordance with the INSERVICE TESTING PROGRAM.

(continued)

Vogtle Units 1 and 2 B 3.7.3-6 REVISION 47

MFIVs and MFRVs and Associated Bypass Valves B 3.7.3 BASES (continued)

REFERENCES 1. FSAR , Subsection 10.4 .7.

2. ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) .

~

Vogtle Units 1 and 2 B 3.7.3-7 REVISION 39

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