NL-24-0294, Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency
| ML24354A346 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/19/2024 |
| From: | Coleman J Southern Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| NL-24-0294 | |
| Download: ML24354A346 (1) | |
Text
._ Southern Nuclear December 19, 2024 Docket Nos.: 50-424 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Regulatory Affairs 3535 Colonnade Parkway Birmingham, AL 35243 205 992 5000 NL-24-0294 10 CFR 50.90 Vogtle Electric Generating Plant - Units 1 & 2 Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency Ladies and Gentlemen:
Pursuant to 10 CFR 50.90, Southern Nuclear Operating Company (SNC) requests a license amendment to the Vogtle Electric Generating Plant (VEGP) Units 1 and 2 Renewed Facility Operating Licenses NPF-68 and NPF-81 respectively. The proposed amendment revises the surveillance Frequency for containment spray nozzle testing specified by Surveillance Requirement (SR) 3.6.6.8. Specifically, the proposed change would replace the current testing frequency, as specified by the Surveillance Frequency Control Program, with an event-based frequency to verify the spray nozzles are unobstructed following activities that could cause nozzle blockage.
The enclosure provides a basis for the proposed change. Attachment 1 contains marked-up Technical Specification (TS) pages. Attachment 2 contains revised (clean) TS pages. provides the marked-up TS Bases pages for information only.
SNC requests approval of the proposed amendment within 12 months of completion of the NRC's acceptance review. Once approved, the amendment shall be implemented within 60 days.
In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Georgia State Official.
U. S. Nuclear Regulatory Commission NL-24-0294 Page 2 This letter contains no NRC commitments. If you have any questions, please contact Ryan Joyce at 205.992.6468.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 19th day of December 2024.
Respectfully submitted, Jamie M. Coleman Director, Regulatory Affairs Southern Nuclear Operating Company JMC/jdj/cbg
Enclosure:
Basis for Proposed Changes Attachments: 1. Proposed Technical Specification Changes (Marked-up Pages)
- 2. Revised Technical Specification Pages
- 3. Proposed Technical Specification Bases Pages (Marked-up) - For Information Only cc:
Regional Administrator, Region II NRR Project Manager - Vogtle 1 & 2 Senior Resident Inspector - Vogtle 1 & 2 State of Georgia Environmental Protection Division RType: CVC?000
Vogtle Electric Generating Plant - Units 1 & 2 Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency Enclosure Basis for Proposed Changes
Enclosure to NL-24-0294 Basis for Proposed Changes 1.0
SUMMARY
DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit or early site permit," Southern Nuclear Operating Company (SNC) requests a license amendment to the Vogtle Electric Generating Plant (VEGP) Units 1 and 2 Renewed Facility Operating Licenses NPF-68 and NPF-81 respectively. The proposed amendment revises the surveillance Frequency for containment spray nozzle testing specified by Surveillance Requirement (SR) 3.6.6.8. Specifically, the proposed change would replace the current testing frequency, as specified by the Surveillance Frequency Control Program (SFCP), with an event-based frequency to verify the spray nozzles are unobstructed following activities that could cause nozzle blockage.
2.0 DETAILED DESCRIPTION 2.1 System Design and Operation The Containment Spray and Containment Cooling systems provide containment atmosphere cooling to limit post-accident pressure and temperature in containment to less than the design values. Reduction of containment pressure and the iodine removal capability of the spray reduces the release of fission product radioactivity from containment to the environment, in the event of a Design Basis Accident (OBA), to within limits. The Containment Spray and Containment Cooling systems are designed to meet the requirements of 10 CFR 50, Appendix A, General Design Criteria (GDC) 38, "Containment Heat Removal," GDC 39, "Inspection of Containment Heat Removal Systems," GDC 40, "Testing of Containment Heat Removal Systems," GDC 41, "Containment Atmosphere Cleanup," GDC 42, "Inspection of Containment Atmosphere Cleanup Systems," and GDC 43, "Testing of Containment Atmosphere Cleanup Systems".
The Containment Spray System (CSS) consists of two separate trains of equal capacity, each capable of meeting the design bases. Each train includes a containment spray pump, spray headers, nozzles, valves, and piping. The CSS provides a spray of cold borated water into the upper regions of containment to reduce the containment pressure and temperature and to reduce fission products from the containment atmosphere during a OBA. Each train of the CSS provides adequate spray coverage to meet the system design requirements for containment heat removal.
2.2 Current Technical Specification Requirements SR 3.6.6.8 states, "Verify each spray nozzle is unobstructed." The Frequency of SR 3.6.6.8 currently states, "In accordance with the Surveillance Frequency Control Program". The Technical Specification (TS) Bases for SR 3.6.6.8 provide detail regarding the required spray nozzle testing.
2.3 Reason for Proposed Change The proposed change will eliminate unnecessary testing of the spray nozzles. The design of the CSS and cleanliness controls utilized during maintenance activities ensure that line or nozzle blockage is unlikely. Performance of SR 3.6.6.8 at the current frequency has the potential to result in unwarranted occupational radiation exposure and increased outage costs without a E-1
Enclosure to NL-24-0294 Basis for Proposed Changes commensurate increase in system reliability or performance. Testing would be performed based on activities or conditions that could potentially cause nozzle blockage.
2.4 Description of the Proposed Change The Frequency of SR 3.6.6.8 is revised to state, "Following activities that could result in nozzle blockage".
A mark-up of the proposed change to SR 3.6.6.8 is provided in Attachment 1. Attachment 2 provides the "clean" retyped SR 3.6.6.8. Attachment 3 provides a mark-up of the TS SR 3.6.6.8 Bases for information only.
3.0 TECHNICAL EVALUATION
3.1 Technical Analysis The proposed amendment will modify VEGP TS SR 3.6.6.8 to eliminate the SFCP Frequency for verifying the containment spray nozzles are unobstructed. Currently, the surveillance requires the spray nozzles be tested in accordance with the SFCP. SNC proposes to replace the current SR Frequency with a statement that would require verification that each spray nozzle is unobstructed following "activities that could cause nozzle blockage." Since maintenance directly or indirectly involving the CSS nozzles is infrequent, the proposed surveillance will ensure the spray nozzles remain unobstructed following activities that could potentially cause nozzle blockage by requiring testing. The testing methods are described in the TS Bases.
3.1.1. Performance History Periodic in-place air flow tests through the CSS spray nozzles have been conducted in accordance with the interval specified in the TS. Spray nozzles were verified unobstructed by delivering airflow to the nozzles, through the headers, via test lines.
SNC has performed the following tests in accordance with TS SR 4.6.2.1.d (currently SR 3.6.6.8) which had an initial Frequency of 5 years. The results of these tests demonstrated unobstructed flow through the CSS nozzles with one exception on Unit 1.
During performance of SR 4.6.2.1.d (currently SR 3.6.6.8) for Unit 1 in 1996, an obstruction was identified in one nozzle on the lower ring of the B train at 180 degrees. The obstruction was evaluated and concluded that the condition would have no significant impact on the ability of the sprays to perform their safety function considering that there are 342 stainless steel spray nozzles in the containment. The subsequent test in 2006 did not identify an obstruction in any spray nozzle.
Unit 1 Unit 2 1/3/1986 2/3/1988 10/4/1991 10/13/1993 3/2/1996 10/21/2002 10/4/2006 E-2
Enclosure to NL-24-0294 Basis for Proposed Changes By letter dated September 25, 1996 (Reference 1 ), the NRC issued a license amendment to replace the existing TS with a set of TS based on NUREG-1431, Revision 1, "Standard Technical Specifications Westinghouse Plants." As part of this replacement, the Frequency of the containment spray nozzle test was extended from 5 years to 10 years, to align with the guidance in NUREG-1366. An additional periodic CSS nozzle flow test has been conducted at VEGP Units 1 and 2 since the implementation of this amendment. The results of these tests demonstrated unobstructed flow through each nozzle.
Then by letter dated January 19, 2011 (Reference 2) the NRC issued a License Amendment to move certain SR Frequencies to a SFCP. The Frequency for SR 3.6.6.8 was moved to the SFCP. It was subsequently extended to 20 years.
3.1.2. Nozzle Blockage Mechanisms The NRC staff previously performed a comprehensive examination of all TS SRs to identify those that should be improved, as documented in NUREG-1366 (Reference 3). This evaluation considered the purpose of the SR and the effect that the performance of the SR has on personnel and on plant equipment. As it relates to the CSS, the report identified that the only reported problems regarding nozzle blockage were related to construction activities. In general, once the system is tested after construction, it is not subject to blockage. Three cases were identified, and all three cases involved a construction error. This report was published in December of 1992. A search of Licensee Event Reports (LERs submitted after December 1992 identified two relevant LERs (References 4 and 5), both from the same unit. Both LERs describe spray nozzle obstructions caused by boric acid solution which was not removed from system low points that entrapped water in the spray headers after the headers were filled with borated water during previous spray header overfill events. The entrapped borated water subsequently evaporated, causing boric acid to precipitate and form obstructions in the nozzles. The number of blocked nozzles was low.
There have been no occurrences of inadvertent flow through the spray nozzles subsequent to the performance of the last nozzle flow test on each VEGP Unit. The CSS spray headers are isolated from system flow during normal operation and pump testing, therefore minimizing the potential for boric acid accumulation. In the event of inadvertent fluid flow through the nozzles, such as the result of spurious actuation, SNC would evaluate testing to determine if the nozzles have remained unobstructed.
3.1.3. Foreign Material Exclusion (FME)
The FME program at VEGP is governed by a nuclear fleet procedure. The FME fleet procedure specifies appropriate precautions to minimize inadvertent and uncontrolled introduction of foreign materials into plant systems and components. The FME procedure requires that personnel perform and document an "as found" inspection when a system, component, or process is opened or breached. The procedure also includes FME practices for maintaining cleanliness of plant systems and components during maintenance activities. Final cleanliness inspections verify the system, component, or process is free of foreign material prior to final closure. The SNC corrective action program is used in the event of a loss of FME integrity. If FME integrity is lost through the intrusion or discovery of foreign material, the FME procedure directs the worker to stop work, notify the First Line Supervisor, and develop a recovery plan for the foreign material. If the retrieval of the foreign material is unsuccessful, an evaluation is required to determine further necessary actions. The fleet FME procedure provides controls that E-3
Enclosure to NL-24-0294 Basis for Proposed Changes minimize the potential for introducing foreign material into systems during maintenance activities, and these controls would be in place if the CSS is opened for maintenance.
Therefore, the FME program provides reasonable assurance that foreign material that could adversely affect the CSS's ability to perform its safety function would not be left in the system as a result of maintenance activities.
During maintenance activities on the CSS since the last spray nozzle test, work practices and post work inspections have maintained system cleanliness in accordance with the FME procedure. A review of the maintenance history of the spray nozzles determined that there has been no maintenance performed on the containment spray nozzles or headers since the last test on each Unit.
3.2 Conclusions NUREG-1366 (Reference 3) found that cases of spray nozzle obstruction in pressurized water reactor containment spray systems were related to construction activities. Previously performed surveillance tests at VEGP found that the spray nozzles were unobstructed, with a single exception. Therefore, the proposed change, along with existing programs, processes, and procedures at VEGP will ensure the containment spray nozzles remain unobstructed, and that appropriate tests will be performed should activities or conditions occur which could potentially cause spray nozzle obstruction. The design of the containment spray system, its maintenance and testing history, FME program controls, and the proposed change to adopt an event-based testing approach specified in TS SR 3.6.6.8 for verifying no nozzle blockage provides reasonable assurance that the containment spray system nozzles will remain unobstructed.
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met.
10 CFR 50 Appendix A, GDC 38, 39, 40, 41, 42 and 43 GDC 38, "Containment Heat Removal," states, in part, that a system to remove heat from the reactor containment shall be provided and that the system safety function shall be to reduce rapidly the containment pressure and temperature following any LOCA and maintain them at acceptably low levels.
GDC 39, "Inspection of Containment Heat Removal System," states, in part, that the containment heat removal system shall be designed to permit appropriate periodic inspection of important components, such as the sumps, spray nozzles, and piping to assure the integrity and capability of the system.
GDC 40, "Testing of Containment Heat Removal System," states, in part, that the containment heat removal system shall be designed to permit appropriate periodic pressure and functional testing to assure (1) the structural and leaktight integrity of its components, (2) the operability and performance of the active components of the system, and (3) the operability of the system as a whole, and under conditions as close to the design as practical the performance of the full operational sequence that brings the system into operation.
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Enclosure to NL-24-0294 Basis for Proposed Changes GDC 41, "Containment Atmosphere Cleanup," states, in part, that systems to control fission products which may be released into the reactor containment shall be provided as necessary to reduce the concentration and quality of fission products released to the environment following postulated accidents.
GDC 42, "Inspection of Containment Atmosphere Cleanup Systems," states, in part, that the containment atmosphere cleanup systems shall be designed to permit appropriate periodic inspection of important components, such as filter frames, ducts, and piping to assure the integrity and capability of the systems.
GDC 43, "Testing of Containment Atmosphere Cleanup Systems," states, in part, that the containment atmosphere cleanup systems shall be designed to permit appropriate periodic pressure and functional testing to assure (1) the structural and leaktight integrity of its components, (2) the operability and performance of the active components of the systems such as fans, filters, dampers, pumps, and valves and (3) the operability of the systems as a whole and, under conditions as close to design as practical, the performance of the full operational sequence that brings the systems into operation.
The proposed change has no effect on the design of the containment heat removal system. The applicable GDC do not specify the frequency or method of inspection. The changes proposed in this request will continue to meet the above regulatory requirements.
10 CFR 50.36 The NRC's regulatory requirements related to the content of the TS are set forth in 10 CFR 50.36, "Technical specifications." Per 10 CFR 50.36(c)(3), surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.
The regulatory requirements in 10 CFR 50.36 are not specific regarding surveillance requirements other than to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. The proposed change is consistent with the requirements of 10 CFR 50.36(c)(3).
4.2 Precedent The following stations requested a change from a time-based surveillance to an event-based surveillance for the containment spray system nozzles. V. C. Summer and Shearon Harris also relocated their surveillance methods to the TS Bases. VEGP TS Bases already contain a discussion of the surveillance methods for this test. Therefore, this portion of these precedents does not apply to this request.
Joseph M. Farley Nuclear Power Plant LAR (Reference 6)
V. C. Summer LAR (Reference 7) and NRC approval (Reference 8)
Shearon Harris LAR (Reference 9) and NRC approval (Reference 10)
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Enclosure to NL-24-0294 Basis for Proposed Changes 4.3 No Significant Hazards Consideration Analysis Southern Nuclear Operating Company (SNC) requests a license amendment to the Vogtle Electric Generating Plant (VEGP) Units 1 and 2 Renewed Facility Operating Licenses NPF-68 and NPF-81 respectively. The proposed amendment revises the Surveillance Frequency for containment spray nozzle testing specified by Surveillance Requirement (SR) 3.6.6.8.
Specifically, the proposed change would replace the current testing frequency, as specified by the Surveillance Frequency Control Program, with an event-based frequency to verify the spray nozzles are unobstructed following activities that could cause nozzle blockage.
SNC has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
- 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed amendment modifies the frequency for performance of a surveillance test which does not impact any failure modes that could lead to an accident. The proposed frequency change does not affect the ability of the spray nozzles or spray system to perform their accident mitigation function as assumed and therefore there is no effect on the consequence of any accident. Verification of no blockage continues to be required, but now verification will be performed following activities that could result in nozzle blockage.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The containment spray system is not being physically modified and there is no impact on the capability of the system to perform accident mitigation functions. No system setpoints are being modified and no changes are being made to the method in which borated water is delivered to the spray nozzles. The testing requirements imposed by this proposed change to check for nozzle blockage following activities that could cause nozzle blockage do not introduce new failure modes for the system.
The proposed amendment does not introduce accident initiators or malfunctions that would cause a new or different kind of accident.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does the proposed amendment involve a significant reduction in a margin of safety?
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Enclosure to NL-24-0294 Basis for Proposed Changes Response: No The proposed amendment does not change or introduce any new setpoints at which mitigating functions are initiated. No changes to the design parameters of the spray systems are being proposed. There are no changes in system operation being proposed by this change that would impact an established safety margin. The proposed change modifies the frequency for verification of nozzle operability in such a way that continued high confidence exists that the spray system will continue to function as designed.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, SNC concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.
4.4 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
5.0 ENVIRONMENTAL CONSIDERATION
A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.
Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
6.0 REFERENCES
- 1. Letter from NRC to SNC, "Issuance of Amendments," dated September 25, 1996 (ADAMS Accession No. 9610090381)
- 2. Letter from NRC to SNC, "Issuance of Amendments Regarding Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program," dated January 19, 2011 (ADAMS Accession No. ML102520083)
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Enclosure to NL-24-0294 Basis for Proposed Changes
- 3. NUREG-1366, "Improvements to Technical Specifications Surveillance Requirements,"
dated December 1992
- 4. LER 2007-01-000, Palo Verde Nuclear Generating Station Unit 3, "Condition Prohibited by Technical Specification Resulting from Containment Spray Nozzle Blockage," dated April 7, 2008
- 5. LER 2010-002-001, Palo Verde Nuclear Generating Station Unit 3, "Condition Prohibited by Technical Specification Resulting from Containment Spray Nozzle Blockage," dated June 27, 2012
- 6. Letter from SNC to the Nuclear Regulatory Commission, "Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency," dated April 5, 2024 (ADAMS Accession No. ML24096B775)
- 7. Letter from Dominion Energy South Carolina (Virgil C. Summer Nuclear Station) to the Nuclear Regulatory Commission, "License Amendment request - Technical Specifications Nozzle Blockage Testing Requirement Change for Reactor Building Spray System," dated April 22, 2022 (ADAMS Accession No. ML22115A104)
- 8. Letter from NRC to Dominion Energy South Carolina, "Issuance of Amendment No. 224 to Change Nozzle Blockage Testing Requirement for Reactor Building Spray System,"
dated February 21, 2023 (ADAMS Accession No. ML23012A015)
- 9. Letter from Shearon Harris Nuclear Power Plant to the Nuclear Regulatory Commission, "License Amendment Request Regarding Change to Containment Spray Nozzle Test Frequency," dated March 24, 2021 (ADAMS Accession No. ML21083A317)
- 10. Letter from NRC to Shearon Harris Nuclear Power Plant, "Issuance of Amendment No.
190 Regarding Revision to Containment Spray Nozzle Test Frequency," dated February 10, 2022 (ADAMS Accession No. ML21351A472)
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Vogtle Electric Generating Plant - Units 1 & 2 Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency Proposed Technical Specification Changes (Marked-Up Pages)
Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS (continued)
SR 3.6.6.7 SR 3.6.6.8 SR 3.6.6.9 SURVEILLANCE Verify each containment cooling train starts automatically on an actual or simulated actuation signal.
Verify each spray nozzle is unobstructed.
Verify containment spray locations susceptible to gas accumulation are sufficiently filled with water.
FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance 'Nith the Surveillance Frequency Control Program Following activities that could result in nozzle blockage In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.6.6-3 Amendment No. 1-78XXX (Unit 1)
Amendment No. 1-WXXX (Unit 2)
Vogtle Electric Generating Plant - Units 1 & 2 Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency Revised Technical Specification Pages
Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS (continued)
SR 3.6.6.7 SR 3.6.6.8 SR 3.6.6.9 SURVEILLANCE Verify each containment cooling train starts automatically on an actual or simulated actuation signal.
Verify each spray nozzle is unobstructed.
Verify containment spray locations susceptible to gas accumulation are sufficiently filled with water.
FREQUENCY In accordance with the Surveillance Frequency Control Program Following activities that could result in nozzle blockage In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.6.6-3 Amendment No. XXX (Unit 1)
Amendment No. XXX (Unit 2)
Vogtle Electric Generating Plant - Units 1 & 2 Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency Proposed Technical Specification Bases Pages (Marked-up) - For Information Only
BASES SURVEILLANCE REQUIREMENTS Activities that could cause nozzle blockage include inadvertent fluid flow through the nozzles, a loss of FME control within the system boundary, or a major configuration change. An evaluation based on the specific situation will SR 3.6.6.4 (continued)
Containment Spray and Cooling Systems B 3.6.6 OPERABILITY, trend performance, and detect incipient failures by abnormal performance. The Frequency of the SR is in accordance with the INSERVICE TESTING PROGRAM.
In addition to the acceptance criteria of the INSERVICE TESTING PROGRAM, performance of this SR also verifies that pump performance is greater than or equal to the performance assumed in the safety analysis.
SR 3.6.6.5 and SR 3.6.6.6 These SRs require verification that each automatic containment spray valve actuates to its correct position and that each containment spray pump starts upon receipt of an actual or simulated actuation of a containment High-3 pressure signal. This surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Any change in the scope or frequency of SR 3.6.6.6 requires reevaluation of STI Evaluation number 417332, in accordance with the Surveillance Frequency Control Program.
The surveillance of containment sump isolation valves is also required by SR 3.5.2.5. A single surveillance may be used to satisfy both requirements.
SR 3.6.6.7 This SR requires verification that each containment cooling train actuates upon receipt of an actual or simulated safety injection signal and operates at low speed. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.6.6.8 determine the appropriate With the containment spray inlet valves closed and the spray method for performing the header drained of any solution, low pressure air or smoke can surveillance.
be blown through test connections. This SR ensures that each
spray nozzle is unobstructed and provides assurance that spray coverage of the containment during an accident is not degraded.
(continued)
Vogtle Units 1 and 2 B 3.6.6-9 REVISION XX 47