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{{Adams
#REDIRECT [[NL-14-1974, Vogtle, Units 1 & 2 - Clarification of Response to Request for Additional Information on License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Rev. 0, Risk Informed Technical Specifications Initiative 4b, Ri]]
| number = ML14346A643
| issue date = 12/12/2014
| title = Vogtle, Units 1 & 2 - Clarification of Response to Request for Additional Information on License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Rev. 0, Risk Informed Technical Specifications Initiative 4b, Risk
| author name = Pierce C R
| author affiliation = Southern Co, Southern Nuclear Operating Co, Inc
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000424, 05000425
| license number =
| contact person =
| case reference number = NL-14-1974, TAC ME9555, TAC ME9556
| document type = Letter, Technical Specification, Amendment
| page count = 12
| project = TAC:ME9555, TAC:ME9556
| stage = Response to RAI
}}
 
=Text=
{{#Wiki_filter:Charles R. Pierce Regulatory Affairs Director December 12, 2014 Docket Nos.: 50-424 50-425 Southern Nuclear Operating Company, Inc. 40 Inverness Center Parkway Post Office Box 1295 Birmingham. AL 35242 Tel 205.992.7872 Fax 205.992.7601 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant , Units 1 & 2 COMPANY NL-14-1974 Clarification of Response to Request for Additional Information on Plant Vogtle License Amendment Request to Revise Technical Specifications to Implement NEI 06-09 , Revision 0 , " R i s k Informed Technical Specifications Initiative 4b , Risk-Managed Technical Specifications (RMTS) Guidelines" Ladies and Gentlemen:
By Reference 1, Southern Nuclear Operating Company (SNC) submitted a license amendment request for the Vogtle Electric Generating Plant (VEGP) Technical Specifications (TS) to permit the use of the Risk Managed Technical Specifications per Reference
: 2. Per References 3 , 5 (as amended by Reference
: 6) and 8, the NRC requested additional information to facilitate their review. SNC provided responses to those requests by References 4, 7, and 10. Further clarification was requested to a specific response provided in Reference 10 , and Enclosure 1 to this letter contains the additional information. Enclosure 2 to this letter includes a revision to the markup of the TS Programs and Manuals section, 5.5, and Enclosure 3 to this letter is the clean typed TS page corresponding to the markup prov i ded in Enclosure
: 2. This letter contains no NRC commitments.
If you have any questions , please contact Ken McElroy at (205) 992-7369.
U. S. Nuclear Regulatory Commission NL-14-1974 Page2 Mr. C. R. Pierce states he is Regulatory Affairs Director of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true. Respectfully submitted, c.n C. R. Pierce Regulatory Affairs Director CRP/EGA -om to and subscribed before me this /2_--IJ....
day bet--'2014. My commission expires: t/z /z.ot '8 I I
 
==References:==
: 1. Southern Nuclear Operating Company letter, NL-12-1344, dated September 13, 2012, License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, "Risk Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS) Guidelines'
: 2. NEI 06-09-A, Risk Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS) Guidelines, November, 2006 3. NRC Letter dated May 16, 2013, Vogtle Electric Generating Plant, Units 1 and 2 (VEGP) Request for Additional Information, (TAC Nos. ME9555 and ME9556) 4. Southern Nuclear Operating Company letter, NL-13-1540, dated August 2, 2013, Vogtle Electric Generating Plant Response to Request for Additional Information on Plant Vogtle License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, "Risk Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS) Guidelines" 5. NRC Letter dated June 9, 2014, Vogtle Electric Generating Plant, Units 1 and 2, Request for Additional Information (TAC Nos. ME9555 and ME9556) 6. NRC Letter dated June 25, 2014, Vogtle Electric Generating Plant, Units 1 and 2-Corrected
-Request for Additional Information, (TAC Nos. ME9555 and ME 9556) -
U. S. Nuclear Regulatory Commission NL-14-1974 Page3 7. Southern Nuclear Operating Company letter, NL-14-1016, dated July 17, 2014, Vogtle Electric Generating Plant, Units 1 and 2, Response to Request for Additional Information on Plant Vogtle License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, "Risk Informed Technit;al Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines" 8. NRC Letter dated October 14, 2014, Vogtle Electric Generating Plant, Units 1 and 2, Request for Additional Information (TAG Nos. ME9555 and ME9556) 9. NRC Letter dated April 24, 2013, Vogtle Electric Generating Plant, Units 1 and 2, Issuance of Amendments Regarding Adoption of TSTF-439, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO" (TAG Nos. ME9470 and ME9471) 10. Southern Nuclear Operating Company letter, NL-14-1703, dated November 11, 2014, Vogtle Electric Generating Plant, Units 1 and 2, Response to Request for Additional Information on Plant Vogtle License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, "Risk Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines"
 
==Enclosures:==
: 1. Clarification of Response to Nuclear Regulatory Commission Question 2. Revised Technical Specifications Mark-up 3. Revised Technical Specifications Clean-Typed Pages cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President
& CEO Mr. D. G. Bost, Executive Vice President
& Chief Nuclear Officer Mr. D. R. Madison, Vice President-Fleet Operations Mr. M. D. Meier, Vice President-Regulatory Affairs Mr. B. K. Taber, Vice President-Vogtle 1 & 2 Mr. B. J. Adams, Vice President-Engineering Mr. G.W. Gunn, Regulatory Affairs Manager-Vogtle 1 & 2 (Acting) RType: CVC7000 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager-Vogtle 1 & 2 Mr. L. M. Cain, Senior Resident Inspector-Vogtle 1 & 2 State of Georgia Mr. J. H. Turner, Director-Environmental Protection Division Vogtle Electric Generating Plant, Units 1 & 2 Clarification of Response to Request for Additional Information on Plant Vogtle License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, "Risk Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines" Enclosure 1 Clarification of Response to Nuclear Regulatory Commission Question Enclosure 1 to NL-14-1974 Clarification of Response to NRC Question NRC PRA RAJ Question 11.1: The response does not discuss why LERF considerations do not exclude TS LCO 3.6.2 from the RICT program. The following provides additional clarification for discussion on this issue. The LAR Table E1-3 shows that LERF is less than the front stop for both the "low'' and "high" RICT. The response to PRA RAI13.1 suggests this is due to the PRA modeling which is the same for both cases, i.e., that the airlock condition renders the containment inoperable.
In the response, PRA functionality could potentially result in extending the CT to the backstop (clarify if "backstop" refers to the 30 day backstop).
Since for the Table E1-3 "low'' RICT case, the containment is apparently failed, it is not clear how PRA functionality could result in the containment DBA limits being met. Therefore, it is not clear that the Table E1-3 "low'' RICT case is representative of the TS LCO condition.
: 1. Explain whether the 30 day backstop applies to TS LCO 3.6.2. The NEI 06-09 Section 11 guidance on the inclusion of SSCs in the model may have relevant discussion similar to the ESF room coolers (TS LCO 3.7.14), e.g., there is a supporting technical analysis documented.
: 2. The response to PRA 13.1 notes that PRA functionality could be used to extend the CT for TS LCO 3.6.2 Condition C. Condition C involves two different applicable limits: one limit is associated with the airlock performance and the other limit is associated with the containment operability.
The TS Bases provides discussion on these limits. PRA functionality represents a condition outside TS limits (i.e. a component is inoperable).
PRA functionality as applied forTS LCO 3.6.2 Condition C may represent a condition outside the airlock limit, but cannot represent a condition outside the containment limits; otherwise the containment would be inoperable and TS LCO 3.6.2 would not apply. Please confirm that the airlock PRA functionality determination includes consideration of the containment operability limits that are applicable to Condition C.1. SNC Response to PRA RAJ 11.1: LCO 3.6.2 Condition C would be entered for conditions associated with one or more containment air locks being inoperable for reasons other than Condition A or Condition B. Condition A defines a condition in which one or more air locks have one inoperable containment air lock door and Condition B is associated with the interlock feature. Condition C could be entered for reasons including leakage, which is the basis of ensuring an overall containment leakage evaluation is initiated immediately per Required Action C.1. The Vogtle PRA containment air lock success criterion is equivalent to the design basis requirements.
Therefore, the current Vogtle PRA would not allow establishment of PRA functionality if leakage of both doors on one air lock exceeded design basis requirements resulting in Condition C of LCO 3.6.2 being entered. However, Condition C states ''for reasons other than Condition A or B" and is therefore all inclusive of conditions that would result in one or more containment air locks being inoperable for reasons other than Condition A. This application is consistent with TSTF-505, Rev. 1. The Vogtle Tech Spec Bases for LCO 3.6.2 states that "Each of the doors contains double gasketed seals and local leakage rate testing capability to ensure pressure integrity." Vogtle has the capability to perform not only leak rate testing of the double gasketed seals on each of E1-1 Enclosure 1 to NL-14-1974 Clarification of Response to NRC Question the air lock doors, but also has the capability of performing an air lock leak rate test (pressure test). It would be possible, although unlikely, that one of the gasketed seals in each door of a containment air lock be non-functional as indicated by failure of leak rate tests of the door seals. This would result in Condition C of LCO 3.6.2 being entered for two inoperable air lock doors. The Vogtle Tech Spec Bases for LCO 3.6.2 Required Actions C.1 states: 'With one or more air locks inoperable for reasons other than those described in Condition A orB, Required Action C. 1 requires action to be initiated immediately to evaluate previous combined leakage rates using current air lock test results. An evaluation is acceptable, since it is overly conservative to immediately declare the containment inoperable if both doors in an air lock have failed a seal test or if the overall air lock leakage is not within limits. In many instances (e.g., only one seal per door has failed), containment remains OPERABLE, yet only 1 hour (per LCO 3.6. 1) would be provided to restore the air lock door to OPERABLE status prior to requiring a plant shutdown.
In addition, even with both doors failing the seal test, the overall containment leakage rate can still be within limits." This postulated event of having one failed seal per air lock door on a single air lock represents a condition other than Condition A or B requiring entry into Condition C. However, if a subsequent air lock leak test was conducted and concluded that the remaining gasket on each air lock door was intact (i.e., the test which pressurizes between the double gasketed air lock door seals fails acceptance criteria, but the test pressurizing the volume between the air lock doors passes due to the remaining functional gasket on each door), it might be concluded that PRA functionality exists on one or more doors allowing a RICT calculation consistent with TSTF-505, Rev. 1. In this situation, a PRA Functionality evaluation will document the technical basis for concluding the TS Inoperable condition will result in declaring the condition PRA Functional and the CRM Tool will calculate a 30 day RICT backstop.
SNC recognizes that our current PRA success criteria does not allow for such an evaluation to establish PRA functionality if design basis leakages are exceeded, but that does not preclude SNC from performing technical analysis to provide such a basis in the future. E1-2 Vogtle Electric Generating Plant, Units 1 & 2 Clarification of Response to Request for Additional Information on Plant Vogtle License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, "Risk Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines" Enclosure2 Revised Technical Specifications Mark-up Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.20 5.5.21 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 requi r ed by paragraphs c and d , respectively. 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. Vogtle Units 1 and 2 5.5-20 Amendment No.I: (Unit 1) Amendment No. +4G (Unit 2)
INSERT 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 Risk Informed Completion Time 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 hours 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 or more of the trains are considered "PRA functional" as defined in Section 2.3.1 of NEI 06-09. f. 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 PRA Functionality.
Vogtle Electric Generating Plant, Units 1 & 2 Clarification of Response to Request for Additional Information on Plant Vogtle License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, "Risk Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines" Enclosure3 Revised Technical Specifications Clean-Typed Pages Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.20 5.5.21 5.5.22 Control Room Envelope Habitabilitv 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.
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. 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 Risk Informed Completion Time 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. Amendment No. (Unit 1) (Unit 2)
Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 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 hours 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 or more of the trains are considered "PRA functional" as defined in Section 2.3.1 of NEI 06-09. f. 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 PRA Functionality.
Vogtle Units 1 and 2 5.5-21 Amendment No. Amendment No. (Unit 1) (Unit 2)}}

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