Text

License Amendment Request to Revise Technical Specifications Regarding Generic Letter 2008-01, Managing Gas Accumulation in Accordance with TSTF-523, Revision 2, Using the Consolidated Line Item Improvement Process (CLIIP)
	ML15132A662
Person / Time
Site:	Vogtle
Issue date:	05/12/2015
From:	Pierce C; Southern Co Services, Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GL-08-001, NL-15-0422, TSTF-523, Rev. 2
	Download: ML15132A662 (52)
	v • d • e

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

40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35201 Tel 205.992.7872 Fax 205.992.7601 MAY 1 2 201-5 Docket Nos.: 50-424 NL-15-0422 50-425 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant- Units 1 and 2 License Amendment Request to Revise Technical Specifications Regarding Generic Letter 2008-01, Managing Gas Accumulation in accordance with TSTF-523, Revision 2. Using the Consolidated Line Item Improvement Process (CLIIP)

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 Vogtle Electric Generating Plant (VEGP), Units 1 and 2.

The proposed amendment would modify TS requirements related to Generic Letter 2008-01, "IVanaging Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray systems," as described in TSTF-523, Revision 2, "Generic Letter 2008-01, l\t1a.naging Gas Accumulation." SNC committed to submit this proposed change in Vogtle Electric Generating Plant Response to NRC Generic Letter 2008-1, "Response to Request for Additional Information," M...102140115.

Enclosure 1 provides a description of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Enclosure 2 provides the eXisting TS pages marked up to show the proposed changes. Enclosure 3 provides revised (clean) TS pages. Enclosure 4 provides existing TS Bases pages marked up to show the proposed changes.

SNC requests approval of the proposed license amendments by May 30, 2016. The proposed changes would be implemented 'Nithin 120 days of issuance of the amendment.

In accordance 'Nith 10 CFR 50.91 (b)(1 ), "State Consultation," a copy of this application and its reasoned analysis about no significant hazards considerations is being provided to the designated Georgia officials.

U.S. Nuclear Regulatory Commission NL-15-0422 Page2 This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.

Mr. C. R. Pierce states he is Regulatory Affairs Director of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.

e, 1<,

Respectfull~bmitted, jJ)Ai.

C. R. Pierce Regulatory Affairs Director CRP/GLS/Iac s~:}J to and suy~d before me this ~day or~ZVl,.__.;,.,..~e~cua::;,.;;,_"'*-___,, 2015.

~Ubnt~

My commission expires: /0 - Z~ J.o 11

Enclosures:

1. Basis for Proposed Change

2. VEGP Technical Specification Marked Up Pages

3. VEGP Technical Specification Clean Typed Pages

4. VEGP Technical Specification Bases Marked Up Pages (for information only) cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bast, Executive Vice President & Chief Nuclear Officer Mr. B. K. Taber, Vice President- Vogtle 1 & 2 Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. B. J. Adams, Vice President- Engineering Mr. D. R. Madison, Vice President- Fleet Operations Mr. G. W.Gunn, Regulatory Affairs Manager- Vogtle 1 & 2 RType: CVC7000 U.S. Nuclear Regulatory Commission Mr. V. M. McCree, Regio'nal 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 License Amendment Request to Revise Technical Specifications Regarding GL 2008-01, Managing Gas Accumulation, TSTF-523 Revision 2, Using the Consolidated Line Item Improvement Process (CLIIP)

Enclosure 1 Basis for Proposed Change to NL-15-0422 Basis for Proposed Change Table of Contents 1.0 Description 2.0 Assessment 3.0 Regulatory Analysis 4.0 Environmental Evaluation E1-1 to NL-15-0422 Basis for Proposed Change

1.0 DESCRIPTION

The proposed change revises or adds Surveillance Requirements to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit pelformance of the verification. The changes are being made to address the concerns discussed in Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems."

The proposed amendment is consistent with TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation." The availability of this Technical Specification {TS) improvement was published in the Federal Register on January 15, 2014 as part of the consolidated line item improv~ment process (CLIIP).

2.0 ASSESSMENT 2.1 Applicabilitv of Published Safetv Evaluation Southern Nuclear Operating Company (SNC) has reviewed the safety evaluation dated December 23, 2013 as part of the CLIIP. This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-523. As described in the subsequent paragraphs, SNC has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the Nuclear Regulatory Commission (NRC) staff are applicable to Vogtle Electric Generating Plant (VEGP), Units 1 and 2, and justify this amendment for the incorporation of the changes to the VEGP Units 1 and 2 TS.

2.2 Optional Changes and Variations SNC is proposing the following variations from the TS changes described in the TSTF-523, Revision 2, or the applicable parts of the NRC staff's model safety evaluation dated December 23, 2013.

VEGP Units 1 and 2 TS utilize different numbering than the Standard Technical Specifications on which TSTF-523 was based. Specifically, SR 3.4.8.4 was added to reflect addition of the new SR 3.4.8.3 reflected in the TSTF-523 in the RCS Loops - Mode 5, Loops Not Filled. SR 3.6.6.9 was added to reflect addition of the new SR 3.6.6.4 reflected in the TSTF-523 in the Containment Spray and Cooling Systems. By numbering this addition to the end of this section it precluded having to make administrative changes to VEGP Unit 1 and 2 existing SRs. Also, in the RHR and Coolant Circulation- Low Water Level section 3.9.6 at VEGP Units 1 and 2, the next available SR number to use is SR 3.9.6.2 instead of SR 3.9.6.3, as reflected in TSTF-523. These differences are administrative and do not affect the applicability of TSTF-523 to the VEGP Units 1 and 2 TS.

The Technical Specification Bases for the note added for SR 3.5.2.2 and SR 3.6.6.1 explaining the site process for administratively controlling opening vent flow paths is clarified. This administrative variance does not affect the applicability of TSTF-523 to the VEGP Units 1 and 2 TS.

The Technical Specification Bases for RHR per SR 3.4.6.4, SR 3.4.7.4, SR 3.4.8.4, SR 3.9.5.2, and SR 3.9.6.2 clarifies that the RHR Loop is adequately filled and vented by virtue of pelforming the operating procedure and when the RHR Loop is in service in accordance with operating procedures. Also, the RHR system is assumed to remain sufficiently filled with water and may be restarted following short term duration RHR shutdowns, if no evolutions were pelformed that can introduce voids into the RHR loop.

E1-2 to NL-15-0422 Basis for Proposed Change

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination SNC requests adoption of TSTF-523, Rev. 2, "Generic Letter 2008-01, Managing Gas Accumulation," which is an approved change to the standard technical specifications

,(STS), into the Vogtle Electric Generating Plants Unit 1 and 2 technical specifications (TS).

The proposed change revises or adds Surveillance Requirements to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification.

SNC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change revises or adds Surveillance Requirements (SRs) that require verification that the Emergency Core Cooling System (ECCS), the Residual Heat Removal (RHR) System, and the Containment Spray (CS) System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. Gas accumulation in the subject systems is not an initiator of any accident previously evaluated. As a result, the probability of any accident previously evaluated is not significantly increased. The proposed SRs ensure that the subject systems continue to be capable to perform their assumed safety function and are not rendered inoperable due to gas accumulation. Thus, the consequences of any accident previously evaluated are not significantly increased.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create th13 possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change revises or adds SRs that require verification that the ECCS, the RHR System, and the CS System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the proposed change does not impose any new or different requirements that could initiate an accident. The proposed change does not alter assumptions made in the safety analysis and is consistent with the safety analysis assumptions.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

E1-3 to NL-15-0422 Basis for Proposed Change

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change revises or adds SRs that require verification that the ECCS, the RHR System, and the CS System are not rendered inoperable due to accumulated gas and to provide allowances which permit performance of the revised verification. The proposed change adds new requirements to manage gas accumulation in order to ensure the subject systems are capable of performing their assumed safety functions.

The proposed SRs are more comprehensive than the current SRs and will ensure that the assumptions of the safety analysis are protected. The proposed change does not adversely affect any current plant safety margins or the reliability of the equipment assumed in the safety analysis. Therefore, there are no changes being made to any safety analysis assumptions, safety limits or limiting safety system settings that would adversely affect plant safety as a result of the proposed change.

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.

4.0 ENVIRONMENTAL EVALUATION The proposed change 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 change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change 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 change.

E1-4

Vogtle Electric Generating Plant License Amendment Request to Revise Technical Specificat ions Regarding GL 2008-01, Managing Gas Accumulation, TSTF-523 Revision 2, Using the Consolida ted Line Item Improvem ent Process (CLIIP)

Enclosure 2 VEGP Technical Specification Marked Up Pages

t:nc1osure <! 10 NL*l:>-I.J4:u!

VEGP Technical Specification Marl<ed Up Pages RCS Loops- MODE 4 3.4.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.6.3 Verify correct pump breaker alignment and In accordance with indicated power are available to the required the Surveillance pump that is not in operation. Frequency Control Program SR 3.4.6.4 ---------------------------------NOTE---------------------------

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

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

Amendment No. +4G (Unit 2)

E2-1

CIII,;I\J:;Uf8 I! 10 I'IL-10*\)q~

VEGP Technical Specification Marked Up Pages RCS Loops- MODE 5, Loops Filled 3.4.7 SURVEILLANCE REQUIREMENTS (continued)

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

/

SR 3.4.7.4 Verify required RHR loop locations susceptible to In accordance with the gas accumulation are sufficiently filled with water. Surveillance Frequency Control Program Vogtle Units 1 and 2 3.4.7-3 Amendment No. +58 (Unit 1)

Amendment No. +4Q (Unit 2)

E2-2

Enclosure 2 to NL-15-0422 VEGP Technical Specification Marked Up Pages RCS Loops - MODE 5, Loops Not Filled 3.4.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR loop inoperable. A.1 Initiate action to restore Immediately RHR loop to OPERABLE status.

B. Required RHR loops B.1 Suspend all operations Immediately inoperable. involving reduction in RCS boron concentration.

OR AND No RHR loop in operation.

B.2 Initiate action to restore Immediately one RHR loop to OPERABLE status and to operation.

c. One or more valves used C.1 Initiate action to secure Immediately to isolate unborated water valve(s) in closed sources not secured in position.

closed position.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR loop is in operation. In accordance with the Surveillance Frequency Control Program SR 3.4.8.2 Verify correct breaker alignment and indicated powe In accordance with the are available to the required RHR pump that is not i Surveillance Frequency operation. Control Program SR 3.4.8.3 Verify each valve that isolates unborated water In accordance with the sources is secured in the closed position. Surveillance Frequency Control Program

"'f Insert SR 3.4.8.41ocated on next page j Vogtle Units 1 and 2 3.4.8-2 Amendment No. .:t-00 (Unit 1)

Amendment No. W Unit 2)

E2-3

Enclosure 2 to NL-15-0422 VEGP Technical Specification Marked Up Pages

/ Insert as SR 3.4.8.4 SR 3.4.8.4 Verify required RHR loop locations susceptible to In accordance with the gas accumulation are sufficiently filled with water. Surveillance Frequency Control Program E2-4 to NL-15-0422 VEGP Technical Specification Mar1<ed Up Pages ECCS- Operating 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 VerWy the following valves are in the listed In accordance with position with the power lockout switches in the the Surveillance lockout position. Frequency Control Program Valve Number Valve Function Valve Position HV-8835 Sl Pump Cold Leg lnj. OPEN HV-8840 RHR Pump Hot Leg lnj. CLOSED HV-8813 Sl Pump Mini Flow lsol. OPEN HV-8806 Sl Pump Suction from RW ST OPEN HV-8802A, B Sl Pump Hot Leg lnj. CLOSED HV-8809A, B RHR Pump Cold Leg lnj. OPEN SR 3.5.2.2 VerWy each ECCS manual, power operated, and In accordance with automatic valve in the flow path, that is not the Surveillance locked, sealed, or otherwise secured in position, Frequency Control is in the correct position. Program SR 3.5.2.3 VeFify ~GGS 13i13iR§ is h:lll ef '<t,JClteF.\ In accordance with the Surveillance Verify ECCS locations susceptible to gas Frequency Control accumulation are sufficiently filled with water. Program SR 3.5.2.4 VerWy each ECCS pump's developed head at the In accordance with test flow point is greater than or equal to the the lnservice Testing required developed head. Program SR 3.5.2.5 VerWy each ECCS automatic valve in the flow In accordance with path that is not locked, sealed, or otherwise the Surveillance secured in position actuates to the correct Frequency Control position on an actual or simulated actuation Program signal.

(contmued)

NOTE--------------------------------

Not required to be met for system vent flow paths opened under administrative control Vogtle Units 1 and 2 3.5.2-2 Amendment No. -+.§8 (Unit 1)

Amendment No. +4G (Unit 2)

E2-5

Enclosure 2 to NL-15*0422 VEGP Technical Specification Marked Up Pages Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 Verify each containment spray manual, power In accordance with operated, and automatic valve in the flow path the Surveillance that is not locked, sealed, or otherwise secured in Frequency Control position is in the correct position. Program SR 3.6.6.2 Operate each containment cooling train fan unit In accordance with for ~ 15 minutes. the Surveillance Frequency Control Program SR 3.6.6.3 Verify each pair of containment fan coolers In accordance with cooling water flow rate is~ 1359 gpm. the Surveillance Frequency Control Program SR 3.6.6.4 Verify each containment spray pump's developec In accordance with head at the flow test point is greater than or equa the lnservice Testing to the required developed head. Program SR 3.6.6.5 Verify each automatic containment spray valve in In accordance with the flow path that is not locked, sealed, or the Surveillance otherwise secured in position actuates to the Frequency Control correct position on an actual or simulated Program actuation signal.

SR 3.6.6.6 Verify each containment spray pump starts In accordance with automatically on an actual or simulated actuation the Surveillance signal. Frequency Control Program

\ ~.;urmnut:lUJ

NOTE----------------------------

Not required to be met for system vent flow paths opened under administrative control.

Vogtle Units 1 and 2 3.6.6-2 Amendment No.--+W (Unit 1)

Amendment No. +4G- (Unit 2)

E2*6

Enclosure 2 to NL-15-0422 VEGP Technical Specification Marl<:ed Up Pages Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SA 3.6.6.7 Ver~y each containment cooling train starts In accordance with automatically on an actual or simulated actuation the Surveillance signal. Frequency Control Program SA 3.6.6.8 Ver~y each spray nozzle is unobstructed. In accordance with the Surveillance Frequency Control

/

Program

/_

SA 3.6.6.9 Ver~y , conta i nment spray locations susceptible In accordance with the to gas accumulation are sufficiently filled with Surveillance water. Frequency Control Program Vogtle Units 1 and 2 3.6.6-3 Amendment No.--+a8 (Unit 1)

~mendment No. ~ (Unit 2)

E2-7 to NL-15-0422 VEGP Technical Specification Marked Up Pages RHR and Coolant Circulation- High Water Level 3.9.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.4 Close all containment 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months penetrations providing direct access from containment atmosphere to outside atmosphere.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 Verify one RHR loop is in operation and circulating In accordance with reactor coolant at a flow rate of ~ 3000 gpm. the Surveillance Frequency Control Program SR 3.9.5.2 Verify required RHR loop locations susceptible to In accordance with gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.9.5-2 Amendment No. +as (Unit 1)

Amendment No. +4G- (Unit 2)

E2-8 to NL-15-0422 VEGP Technical Specification Marked Up Pages RHR and Coolant Circulation- Low Water Level 3.9.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) 8.2 Initiate action to restore Immediately one RHR loop to operation.

AND 8.3 Close all containment 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months penetrations providing direct access from containment atmosphere to outside atmosphere.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SA 3.9.6.1 Verify one RHR loop is in operation and circulating In accordance with reactor coolant at a flow rate of ~ 3000 gpm. the Surveillance Frequency Control I

Program I

SR 3.9.6.2 Verify require,d RHR loop locations susceptible to In accordance with gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.9.6-2 Amendment No. +as (Unit 1)

Amendment No. +4G (Unit 2)

E2-9

Vogtle Electric Generating Plant License Amendment Request to Revise Technical Specifications Regarding GL 2008-01, Managing Gas Accumulation, TSTF-523 Revision 2, Using the Consolidated Line Item Improvement Process (CLIIP)

Enclosure 3 VEGP Technical Specification Clean Typed Pages

RCS Loops- MODE 4 3.4.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.6.3 Verify correct pump breaker alignment and In accordance with indicated power are available to the required the Surveillance pump that is not in operation. Frequency Control Program SR 3.4.6.4 ----------------------------NOTE-----------------------------

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

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

Amendment No. (Unit 2)

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

SURVEILLANCE FREQUENCY SA 3.4.7.3 Verify correct breaker alignment and indicated In accordance with power are available to the required AHA pump the Surveillance that is not in operation. Frequency Control Program SA 3.4.7.4 Verify required AHA loop locations susceptible to In accordance with gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.4.7 Amendment No. (Unit 1)

Amendment No. (Unit 2)

RCS Loops - MODE 5, Loops Not Filled 3.4.8 SURVEILLANCE REQUIREMENTS {continued)

SURVEILLANCE FREQUENCY SR 3.4.8.4 Verify required RHR loop locations susceptible to In accordance with the gas accumulation are sufficiently filled with water. Surveillance Frequency Control Program Vogtle Units 1 and 2 3.4.8-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

ECCS -Operating 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify the following valves are in the listed In accordance with position with the power lockout switches in the the Surveillance lockout position. Frequency Control Program Valve Number Valve Function Valve Position HV-8835 Sl Pump Cold Leg lnj. OPEN HV-8840 RHR Pump Hot Leg lnj. CLOSED HV-8813 Sl Pump Mini Flow lsol. OPEN HV-8806 Sl Pump Suction from RWST OPEN HV-8802A, 8 Sl Pump Hot Leg lnj. CLOSED HV-8809A, 8 RHR Pump Cold Leg lnj. OPEN SR 3.5.2.2 --------------------------NOTE------------------------------

Not required to be met for system vent flow paths opened under administrative control Verify each ECCS manual, power operated, and In accordance with automatic valve in the flow path, that is not the Surveillance locked, sealed, or otherwise secured in position, Frequency Control is in the correct position. Program SR 3.5.2.3 Verify ECCS locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program SR 3.5.2.4 Verify each ECCS pump's developed head at the In accordance with test flow point is greater than or equal to the the lnservice Testing required developed head. Program SR 3.5.2.5 Verify each ECCS automatic valve in the flow In accordance with path that is not locked, sealed, or otherwise the Surveillance secured in position actuates to the correct Frequency Control position on an actual or simulated actuation Program signal.

(continued)

Vogtle Units 1 and 2 3.5.2-2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 ---------------------------NOTE-------------------------------

Not required to be met for system vent flow paths opened under administrative control.

Verify each containment spray manual, power In accordance with operated, and automatic valve in the flow path the Surveillance that is not locked, sealed, or otherwise secured in Frequency Control position is in the correct position. Program SR 3.6.6.2 Operate each containment cooling train fan unit In accordance with for~ 15 minutes. the Surveillance Frequency Control Program SR 3.6.6.3 Verify each pair of containment fan coolers In accordance with cooling water flow rate is ~ 1359 gpm. the Surveillance Frequency Control Program SR 3.6.6.4 Verify each containment spray pump's developed In accordance with head at the flow test point is greater than or equa the lnservice Testing to the required developed head. Program SR 3.6.6.5 Verify each automatic containment spray valve in In accordance with the flow path that is not locked, sealed, or the Surveillance otherwise secured in position actuates to the Frequency Control correct position on an actual or simulated Program actuation signal.

SR 3.6.6.6 Verify each containment spray pump starts In accordance with automatically on an actual or simulated actuation the Surveillance signal. Frequency Control Program (continued)

Vogtle Units 1 and 2 3.6.6-2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.6.7 Verify each containment cooling train starts In accordance with automatically on an actual or simulated actuation the Surveillance signal. Frequency Control Program SR 3.6.6.8 Verify each spray nozzle is unobstructed. In accordance with the Surveillance Frequency Control Program SR 3.6.6.9 Verify containment spray locations susceptible to In accordance with gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.6.6-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

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

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 Verify one RHR loop is in operation and circulating In accordance with the reactor coolant at a flow rate of ;;::: 3000 gpm. Surveillance Frequency Control Program SR 3.9.5.2 Verify required RHR loop locations susceptible to In accordance with the gas accumulation are Sufficiently filled with water. Surveillance Frequency Control Program Vogtle Units 1 and 2 3.9.5-2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

RHR and Coolant Circulation - Low Water Level 3.9.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) 8.2 Initiate action to restore Immediately one RHR loop to operation.

AND 8.3 Close all containment 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months penetrations providing direct access from containment atmosphere to outside atmosphere.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 Verify one RHR loop is in operation and circulating In accordance with reactor coolant at a flow rate of~ 3000 gpm. the Surveillance Frequency Control Program SR 3.9.6.2 Verify required RHR loop locations susceptible to In accordance with gas accumulation are sufficiently filled with water. the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.9.6-2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Vogtle Electric Generating Plant License Amendment Request to Revise Technical Specifications Regarding GL 2008-01, Managing Gas Accumulation, TSTF-523 Revision 2, Using the Consolidated Line Item Improvement Process (CLIIP)

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

RCS Loops-l\tODE 4 B 3.4.6 BASES LCO An OPERABLE RCS loop is comprised of an OPERABLE RCP and (continued) an OPERABLE SG Vlilich has the minimum v.ater level specWied in SR 3.4.6.2, and the necessary aspects of the Auxiliary Feedv.ater and Condensate Storage Tank Systems available to provide feedv.ater. Additionally, the OPERABILITY of an SG must include a means by Vlilich the decay heat may be removed (i.e., the capability of the atmospheric relief valve to stroke or the condenser is available).

Similarly for the RHR System, an OPERABLE RHR loop comprises an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger. RCPs and RHR pumps are OPERABLE~ they are capable of being po'Aered and are able to provide forced flow if required. Mmagement of gas voids is important to RHR System OPERABILITY.

APPLICABIUTY In l\tODE 4, this LCO ensures forced circulation of the reactor coolant to remove decay heat from the core and to provide proper boron mixing. One loop of either RCS or RHR provides sufficient circulation for these purposes. Ho\r\ever, tv..o loops consisting of any combination of RCS and RHR loops are required to be OPERABLE to meet single failure considerations.

Operation in other l\tODES is covered by:

LCO 3.4.4, "RCS Loops- l\tODES 1 and 2";

LCO 3.4.5, "RCS Loops- l\tODE 3";

LCO 3.4.7, "RCS Loops-l\tODE 5, Loqps Filled"; LCO 3.4.8, "RCS Loops - MODE 5, Loops Not Filled"; LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation- HghWater Level" (l\tODE 6); and LCO 3.9.6, "Residual Heat RE;~moval (RHR) and Coolant Circulation- Low Water Level" (l\tODE 6).

ACTIONS If one required RCS loop is inoperable and Mo RHR loops are inoperable, redundancy for heat removal is lost. Action must be initiated to restore a second RCS or RHR loop to OPERABLE status. The immediate Completion Time reflects the importance of maintaining the availability of mo paths for heat removal.

(continued)

Vogtle Units 1 and 2 B 3.4.6-3 Rev.

E4-1 to NL-15-0422 VEGP Technical Specification Bases Marked Up Pages (for information only)

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

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

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

SR 3.4.6.4 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the required RHR loop(s) and may also prevent ooter hammer, pump cavitation, and pumping of noncondensiblegas into the reactor vessel.

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

(continued)

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

RCS Loops -l'vODE 4 B 3.4.6 BASES SURVEILLANCE SR 3.4.6.4 REQUIRErvENTS (continued) The RHR System is OPERABLE VIAlen it is sufficiently filled vvHh water.

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

When the RHR System is restored to service. the surveillance is met by virtue of the performance of operating procedures that ensure the RHR Loop is adequately filled and vented. The performance of these manual actions ensures that the surveillance is met.

RHR System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path VIAlich are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. 1\/bnitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions. the plant configuration. or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monttoring) may be used to monitor the susceptible location. 1\/bnitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The SR may be met for a RHR Loop by virtue of having a loop in service in accordance with operating procedures.

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

(continued)

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

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

RCS Loops-fvODE 4 8 3.4.6 BASES SURVEILLANCE SR 3.4.6.4 REQUIRErvENTS (continued) This SR is mod~ied by a Note that states the SR is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering IVODE 4. In a rapid shutdo'Ml, there may be insufficient time to verify all susceptible locations prior to entering WODE 4.

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

REFERENCES None.

Vogtle Units 1 and 2 8 3.4.6-7 REVISION E4-4

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

RCS Loops- M:>DE 5, Loops Filled B 3.4.7 BASES LCO Utilization of Note 1 is permitted provided the following conditions are (continued) met, along wth any other conditions imposed by initial startup test procedures:

a. No operations are permitted that would dilute the RCS boron concentration, therefore maintaining the margin to criticality.

Boron reduction is prohibited because a unform concentration distribution throughout the RCS cannot be ensured IM'len in natural circulation; and

b. Core outlet temperature is maintained at least 1ooF below saturation temperature, so that no vapor bubble may form and possibly cause a natural circulation flow obstruction.

Note 2 alloiJ\S one RHR loop to be inoperable for a period of up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provided that the other RHR loop is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable loop during the only time W'len such testing is safe and possible.

Note 3 requires that the secondary side 'Miter temperature of each SG be < 50°F above each of the RCS cold leg temperatures before the start of a reactor coolant pump (RCP) during fvDDE 5 wth the RCS loops filled. This restriction is to prevent a low temperature overpressure event due to a thermal transient W'len an RCP is started.

Note 4 provides for an orderly transition from fvDDE 5 to fvDDE 4 during a planned heatup by permitting removal of RHR loops from operation W'len at least one RCS loop is in operation. This Note provides for the transition to fvDDE 4 IM'lere an RCS loop is permitted to be in operation and replaces the RCS circulation function provided by the RHR loops.

RHR pumps are OPERABLE if they are capable of being po~Aered and are able to provide flow if required. A SG can perform as a heat sink IM'len it has an adequate vvater level and is OPERABLE. Mmagement of gas voids is important to RHR Svstem OPERABILITY. Additional requirements for an SG to be available as a heat sink are:

a. RCS loops and reactor pressure vessel filling and venting complete; and (continued)

Vogtle Units 1 and 2 B 3.4.7-3 Rev.

E4-5

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

RCS Loops -1\tDDE 5, Loops Filled B 3.4.7 BASES SURVEILLANCE SR 3.4.7.3 (continued)

REQUIREfvENTS VerWication is performed'by verifying proper breaker alignment and poW9r available to the RHR pump. If secondary side vater level is above the highest point of the SG U-tubes in at least tv.o SGs, this Surveillance is not needed. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

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

Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information, including piping and instrumentation dra'A1ngs, isometric dra'Aoings, plan and elevation dra'A1ngs, and calculations. The design review is supplemented by system valk downs to validate the system hg h points and to confirm the location and orientation of important components that can become sources of gas or could other'A1se cause gas to be trapped or dfficult to remove during system maintenance or restoration. Susceptible locations depend on plant and system configuration , such as stand-by versus operating conditions.

The RHR System is OPERABLE W'len it is sufficiently filled with water.

Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with vater), the Surveillance may be declared met. Accumulated gas should be eliminated or brought 'A1thin the acceptance criteria limits.

When the RHR System is restored to service. the surveillance is met by virtue of the performance of operating procedures that ensure the RHR Loop is adequately filled and vented. The performance of these manual actions ensures that the surveillance is met.

(continued)

Vogtle Units 1 and 2 B 3.4.7-6 E4-6 REVISION I

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

RCS Loops- WDE 5, Loops Filled 8 3.4.7 BASES SURVEILLANCE SR 3.4.7.4 (continued)

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

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

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

The SR may be met for a RHR Loop by virtue of having a loop in service in accordance with operating procedures.

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

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

REFERENCES None.

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

RCS Loops -1\JDDE 5, Loops Not Filled B 3.4.8 BASES LCO Note 3 allow; valves in the f loV~.path fom the RM\N srI through (continued) the chemical mixing tank, to the suction of the charging pumps to be open under administrative control provided the SDM requirements of LCO 3.1.1 are met and the high flux at shutdo'M'I alarm is OPERABLE. (OPERABILITY of the high flux at shutdo'M'I alarm is defined by LCO 3.3.8.) This permits the addition of chemicals to the RCS as necessary in this 1\JDDE of operation 'Ahile minimizing the risk of an uncontrolled boron dilution transient.

An OPERABLE RHR loop is comprised of an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger. RHR pumps are OPERABLE Wthey are capable of being powered and are able to provide flow if required. Management of gas voids is important to RHR System OPERABILITY.

APPLICABILITY In 1\JDDE 5 wth loops not filled, this LCO requires core heat removal and coolant circulation by the RHR System.

Operation in other 1\JDDES is covered by:

LCO 3.4.4, "RCS Loops- llvODES 1 and 2";

LCO 3.4.5, "RCS Loops- llvODE 3";

LCO 3.4.6, "RCS Loops- llvODE 4";

LCO 3.4.7, "RCS Loops- llvODE 5, Loops Filled";

LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation- High Water Level" (1\JDDE 6); and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation- LowWater Level" (1\JDDE 6).

ACTIONS If only one RHR loop is OPERABLE and in operation, redundancy for RHR is lost. Action must be initiated to restore a second loop to OPERABLE status. The immediate Completion Time reflects the importance of maintaining the availability of t\\0 paths for heat removal.

(continued)

Vogtle Units 1 and 2 B 3.4.8-3 Rev. I E4-8

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

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

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

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

The RHR System is OPERABLE IJ\hen it is sufficiently filled with ooter. Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If tt is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e., the system is sufficiently filled with ooter). the Surveillance may be declared met. Accumulated gas should I:E eliminated or brought within the acceptance criteria limits. When the RHR System is restored to service, the surveillance is met by virtue of the performance of operating procedures that ensure the RHR Loop is adequately filled and vented. The performance of these manual actions ensures that the surveillance is met.

continued Vogtle Units 1 and 2 B 3.4.8-5 E4-9 Revision No. I

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

RCS Loops -1\/DDE 5, Loops Not Filled B3.4.8 BASES SURVEILLANCE SR 3.4.8.4 REQUIREI'vENTS (continued) AHA System locations susceptible to gas accumulation are monitored and, if gas is found. the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path \Mlich are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

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

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

The SR may be met for a RHR Loop by virtue of having a loop in service in accordance with operating procedures.

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

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

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

REFERENCES 1. FSAR, Subsection 15.4.6.

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

ECCS- Operating B 3.5.2 BASES APPLICABLE The effects on containment mass and energy releases are SAFETY ANALYSES accounted for in appropriate analyses (Refs. 3 and 4). The (continued) LCO ensures that an ECCS train wll deliver sufficient Vlater to match boil off rates soon enough to minimize the consequences c:t the core being uncovered followng a large LOCA. It also ensures that the centrWugal charging and Sl pumps wll deliver sufficient V\ater and boron during a small LOCA to maintain core subcriticality. For smaller LOCAs, the centriugal charging pump delivers sufficient fluid to maintain RCS inventory. For a small break LOCA, the steam generators continue to serve as the heat sink, providing part of the required core cooling.

The ECCS trains satisfy Criterion 3 c:t 10 CFR 50.36 (c)(2)(ii).

LCO In l\tODES 1, 2, and 3, t'NO independent (and redundant) ECCS trains are required to ensure that sufficient ECCS flow is available, assuming a single failure affecting either train. Additionally, individual components wthin the ECCS trains may be called upon to mitigate the consequences of other transients and accidents.

In l\tODES 1, 2, and 3, an ECCS train consists of a centrifugal charging subsystem, an Sl subsystem, and an RHR subsystem. Each train includes the piping, instruments, and controls to ensure an OPERABLE flow path capable of taking suction from the FW ST upon an Sl signal and automatically transferring suction to the containment sump.

During an event requiring ECCS actuation, a flow path is required to provide an abundant supply of V\ater from the FW ST to the RCS via the ECCS pumps and their respective supply headers to each c:l the four cold leg injection nozzles. In the long term, this flow path may be swtched to take its supply from the containment sump and to supply its flow to the RCS hot and cold legs. 1\/anagement of gas voids is important to ECCS OPERABILITY.

The flow path for each train must maintain its designed independence to ensure that no single failure can disable both ECCS trains.

(continued)

Vogtle Units 1 and 2 B 3.5.2-5 Rev. 1 10/01 E4-11

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

ECCS -Operating B3.5.2 BASES SURVEILLANCE SR 3.5.2.2 (continued)

REQUIREtvENTS The Surveillance is mod~ied by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing an individual who can rapidly close the system vent flow path ~directed.

SR 3.5.2.3 ECCS piping and components have the ,YVith tho exception of the operating centrluoal chaFQing pump, the EGGS pumps are normally in a standbv. nonoperating mode. As such, flow path piping has the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessaryfor Maintaining the piping from the EGGS pumps to the RGS full of 'l.ater proper operation cl the ECCS and may also ensures that the svstom will perform properly, injecting its full capacity into the RGS upon demand. This *1~11 atse prevent v.ater hammer, pump cavitation, and pumping of noncondensble gas (e.g., air. nitrogen. or hydrogen) into the reactor vessel followng an Sl signal or during shutdov.n cooling .

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

The ECCS is OPERABLE W"len it is sufficiently filled wth water.

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

the Surveillance may be declared met. Accumulated gas should be eliminated or brought wthin the acceptance criteria limits.

(continued)

Vogtle Units 1 and 2 B 3.5.2-9 REVISION +4 E4*12

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

ECCS -Operating B 3.5.2 BASES SURVEILLANCE SR 3.5.2.3 (continued)

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

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

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

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

SR 3.5.2.4 Periodic surveillance testing of ECCS pumps to detect gross degradation caused by impeller structural damage or other hydraulic component problems is required by Section XI of the ASIVE Code.

This type of testing may be accomplished by measuring the pump developed head at only one point of the pump characteristic curve.

This verifies that the measured performance is wthin an acceptable tolerance of the original pump baseline performance. SRs are specified in the lnservice Testing Program, "Wlich encompassesSection XI of the ASIVE Code.Section XI of the ASIVE Code provides the activities and Frequencies necessary to satisfy the requirements.

In addition to the acceptance criteria of the lnservice 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 3.5.2.5 and SR 3.5.2.6 These Surveillances demonstrate that each automatic ECCS valve actuates to the required position on an actual or simulated Sl and AN Sf level low-low (for RHR semiautomatic swtchover to the (continued)

Vogtle Units 1 and 2 B 3.5.2-10 REVISION ~

E4-13

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

ECCS -ShutdoWl B 3.5.3 BASES LCO In IVODE 4, an ECCS train consists of a centrWugal charging (continued) subsystem and an RHR subsystem. Each train includes the piping, instruments, and controls to ensure an OPERABLE flow path capable of taking suction from the AN STand transferring suction to the containment sump.

During an event requiring ECCS actuafion, a flow path is required to provide an abundant supply of Vloater from the FW ST to the RCS via the ECCS pumps and their respective supply headers to each of the four cold leg injection nozzles. In the long term, this flow path may be swtched to take its supply from the containment sump and to deliver its flow to the RCS hot and cold legs. 1\t\:inagement of gas voids is important to ECCS OPERABILITY.

APPLICABILITY In IVODES 1, 2, and 3, the OPERABILITY requirements for ECCS are covered by LCO 3.5.2.

In IVODE 4 wth RCS temperature below 350°F, one OPERABLE ECCS train is acceptable wthout single failure consideration, on the basis of the stable reactMty of the reactor and the limited core cooling requirements.

In IVODES 5 and 6, plant conditions are such that the probability of an event requiring ECCS injection is extremely low. Core cooling requirements in IVODE 5 are addressed by LCO 3.4.7, "RCS Loops-IVODE 5, Loops Filled," and LCO 3.4.8, "RCS Loops-IVODE 5, Loops Not Filled." IVODE 6 core cooling requirements are addressed by LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation -High Water level," and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation- LowWater Level."

ACTIONS A Note prohibits the application of LCO 3.0.4b to an inoperable ECCS centrWugal charging pump subsystem 'Atlen entering IVODE 4. There is an increased risk associated wth entering IVODE 4 from IVODE 5 with an inoperable ECCS centrlugal charging pump subsystem, and the provisions of LCO 3.0.4b, W'lich allow entry into a IVODE or other specWied condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

(continued)

Vogtle Units 1 and 2 B 3.5.3-2 Rev. I E4-14 to NL-15-0422 VEGP Technical Speclflcatlon Bases Marked Up Pages (for Information only)

Containment Spray and Cooling Systems B 3.6.6 BASES APPLICABLE The modeled Containment Cooling System actuation from the SAFETY ANALYSES containment analysis is based upon a response time associated (continued) with exceeding the containment Hig h-1 pressure setpoint to achieving full Containment Cooling System air and safety grade cooling water flow. The Containment Cooling System fan response time of 48 seconds includes signal delay and DG startup (for loss of offsite po\\er) (Ref. 3).

The Containment Spray System and the Containment Cooling System satisfy Criterion 3 of 10 CFR 50.36 (c)(2)(ii).

LCO During a DBA, a minimum of one containment cooling train and one containment spray train are required to maintain the containment peak pressure and temperature below the design limits (Ref. 4).

Additionally, one containment spray train is also required to remove iodine from the containment atmosphere and maintain concentrations below those assumed in the safety analysis. To ensure that these requirements are met, too containment spray trains and t'AO containment cooling trains must be OPERABLE. Therefore, in the event of an accident, at least one train in each system operates, assuming the oorst case single active failure occurs.

Each Containment Spray System typically includes a spray pump, spray headers, nozzles, valves, piping, instruments, and controls to ensure an OPERABLE flow path capable of taking suction from the FW ST upon an ESF actuation signal and manually transferring suction to the containment sump. r\/anagement of gas voids is important to Containment Spray System OPERABILITY.

Each Containment Cooling System typically includes demisters, cooling coils, dampers, fans, instruments, and controls to ensure an OPERABLE flow path.

APPLICABIUTY In l\tODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment and an increase in containment pressure and temperature requiring the operation of the containment spray trains and containment cooling trains.

(continued)

Vogtle Units 1 and 2 B 3.6.6-5 Rev.

E4-15 to NL-15-0422 VEGP Technical Specification Bases Marked Up Pages (for information only)

Containment Spray and Cooling Systems B3.6.6 BASES ACTIONS C.1 and C.2 (continued)

If the inoperable containment spray or cooling train cannot be restored to OPERABLE status wthin the required Completion Time, the plant must be brought to a l'vODE in W"lich the LCO does not apply. To achieve this status, the plant must be brought to at least l'vODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to l'vODE 5 wthin 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months . The allo~Aed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach l'vODE 3 from full power conditions in an orderly manner and wthout challenging plant systems. The extended interval to reach l'vODE 5 alloV\5 additional time for attempting restoration of the containment spray or cooling train and is reasonable W"len considering the driving force for a release of radioactive material from the Reactor Coolant System is reduced in l'vODE 3.

SURVEILLANCE SR 3.6.6.1 REQUIREI'vENTS VerWying the correct alignment for manual, po~Aer operated, and automatic valves in the containment spray flow path provides assurance that the proper flow paths wll exist for Containment Spray System operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these ~Aere verified to be in the correct position prior to locking, sealing, or securing. This SR does not require any testing or valve manipulation. Rather, it involves verification that those valves outside containment (only check valves are inside containment) and capable of potentially being mispositioned are in the correct position.

The Surveillance is modified by a Note which exempts system vent flow paths opened under administrative control. The administrative control should be proceduralized and include stationing an individual who can rapidly close the system vent flow path if directed.

SR 3.6.6.2 Operating each pair of containment cooling fan units for~ 15 minutes ensures that all fan units are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage or fan (continued)

Vogtle Units 1 and 2 B 3.6.6-7 REVISION E4-16 to NL-15-0422 VEGP Technical Specification Bases Marked Up Pages (for information only)

Containment Spray and Cooling Systems 83.6.6 BASES SURVEILLANCE SA 3.6.6.5 and SR 3.6.6.6 (continued)

REQUIREfvENTS Program. Any change in the scope or frequency of SR 3.6.6.6 requires reevaluation of STI Evaluation number 417332, in accordance wth 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 With the containment spray inlet valves closed and the spray header drained of any sdution, low pressure air or smoke can be blo'Ml 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.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.6.9 Containment Spray System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the containment spray trains and may also prevent water hammer and pump cavitation.

Selection of Containment Spray System locations susceptible to gas accumulation is based on a review of system design information.

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

(continued)

Vogtle Units 1 and 2 B 3.6.6-9 REVISION E4-17

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

Containment Spray and Cooling Systems B3.6.6 BASES SURVEILLANCE SR 3.6.6.9 (continued)

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

Accumulatedgas should be eliminated or brought within the acceptance criteria limits.

Containment Spray System locations susceptible to gas accumulation are monitored and. ~ gas is found. the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path W'lich are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions.

the plant configuration. or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations W'lere the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

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

REFERENCES 1. 10 CFR 50, Appendix A, GDC 38, GDC 39, GDC40, GDC 41, GDC 42, and GDC 43.

2. 10 CFR 50, Appendix K.

3. FSAR, Chapter 7.

(continued)

Vogtle Units 1 and 2 B 3.6.6-10 REVISION E4-18

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

AHA and Coolant Circulation- High Water Level B3.9.5 BASES APPLICABLE AHA and Coolant Circulation- High Water Level satisfies Criterion 4 SAFETY ANALYSES of 10 CFR 50.36 (c)(2)(ii).

(continued)

LCO Only one AHA loop is required for decay heat removal in M)DE 6, with the 'Hater level~ 23ft above the top of the reactor vessel flange.

Only one AHA loop is required to be OPERABLE, because the volume of 'Hater above the reactor vessel f lane provides backup decay heat removal capability. At least one AHA loop must be OPERABLE and in operation to provide:

a. Removal of decay heat;

b. Mixing of borated coolant to minimize the possibility of criticality; and

c. Indication of reactor coolant temperature.

An OPERABLE AHA loop includes an AHA pump, a heat exchanger, valves, piping, instruments, and controls to ensure an OPERABLE flow path and to determine the low end temperature. The flow path starts in one of the RCS hot legs and is returned to the RCS cold legs.

Management of gas voids is important to AHA System OPERABILITY.

The LCO is modfied by a Note that alloVIS the required operating RHR loop to be removed from service for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided no operations are permitted that 'IIIOuld cause a reduction of the RCS boron concentration. Boron concentration reduction is prohibited because unWorm concentration distribution cannot be ensured wthout forced circulation. This permits operations such as core mapping or alterations in the vicinity of the reactor vessel hot leg nozzles and RCS to RHR isolation wive testing.

During this 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period, decay heat is removed by natural convection to the large mass of 'Hater in the refueling cavity.

APPLICABIUTY One AHA loop must be OPERABLE and in operation in M)DE 6, wth the 'Hater level ~ 23ft above the top of the reactor vessel flane, to provide decay heat removal and mixing of the borated coolant. The 23ft 'Hater level was selected (continued}

Vogtle Units 1 and 2 B 3.9.5-2 Rev.

E4-19

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

RHR and Coolant Circulation- High Water Level 83.9.5 BASES ACTIONS A.3 (continued) water level~ 23ft above the top of the reactor vessel flange, corrective actions shall be initiated immediately.

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

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

SURVEILLANCE SA 3.9.5.1 REQUIREIVENTS This Surveillance demonstrates that the RHR loop is in operation and circulating reactor coolant. The flow rate (FIC-0618A and FIC-0619A) is determined by the flow rate necessary to provide sufficient decay heat removal capability and to provide mixing of the borated coolant to prevent thermal and boron stratWication in the core. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.9.5.2 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessarvfor proper operation of the RHR loops and may also prevent water hammer. pump cavitation. and pumping of noncondensiblegas into the reactor vessel.

Selection of RHR System locations susceptible to gas accumulation is based on a review of system design information. including piping and instrumentation drawngs, isometric drawngs. plan and elevation drawngs, and calculations. The design review is supplemented by system walk dovvns to validate the system hgh points and to confirm the location and orientation of important components that can become sources of gas or could other\ftAse cause gas to be trapped or difficult (continued)

Vogtle Units 1 and 2 8 3.9.5-4 E4-20 REVISION I

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

AHA and Coolant Circulation- High Water Level B3.9.5 BASES SURVEILLANCE SR 3.9.5.2 (continued)

REQUIREtv'ENTS to remove during svstem maintenance or restoration. Susceptible locations depend on plant and system configuration, such as stand-by versus operating conditions .

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

Acceptance criteria are established for the volume of accumulated gas at susceptible locations. If accumulated gas is discovered that exceeds the acceptance criteria for the susceptible location (or the volume of accumulated gas at one or more susceptible locations exceeds an acceptance criteria for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the accumulated gas (i.e .. the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits. When the RHR System is restored to service, the surveillance is met by virtue of the performance of operating procedures that ensure the RHR Loop is adequately filled and vented. The performance of these manual actions ensures that the surveillance is met.

RHR System locations susceptible to gas accumulation are monitored and, ~gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path \M1ich are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

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

operating parameters, remote monitoring) may be used to monitor the susceptible location. l'vbnitorinq is not required for susceptible locations \M1ere the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The SA may be met for a RHR Loop by virtue of having a loop in service in accordance with operating procedures.

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

(continued)

Vogtle Units 1 and 2 B3.9.5-4 E4-21 REVISION I

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

AHA and Coolant Circulation- High Water Level 83.9.5 BASES SURVEILLANCE SA 3.9.5.2 (continued)

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

REFERENCES NONE Vogtle Units 1 and 2 8 3.9.5-5 E4-22 REVISION I

r.nCI05Uf6 410 NL.*l:l*U4~

VEGP Technical Specification Bases Marked Up Pages (for Information only)

RHR and Coolant Circulation- LowWater Level B3.9.6 BASES LCO Additionally, one loop of RHR must be in operation in order (continued) to provide:

a. Removal of decay heat;

b. Mixing of borated coolant to minimize the possibility of criticality; and

c. Indication of reactor coolant temperature.

This LCO is modfied by a Note that allows one RHR loop to be inoperable for a period of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months provided the other loop is OPERABLE and in operation. Prior to declaring the loop inoperable, consideration should be given to the existing plant confguration. This consideration should include that the core time to boil is short, there is no draining operation to further reduce RCS water level and that the capability exists to inject borated water into the reactor vessel. This permits surveillance tests to be performed on the inoperable loop during a time W"len these tests are safe and possible.

An OPERABLE RHR loop consists of an RHR pump, a heat exchanger, valves, piping, instruments and controls to ensure an OPERABLE flow path and to determine the low end temperature. The flow path starts in one of the RCS hot legs and is returned to the RCS cold legs. l\lanagement of gas voids is important to RHR System OPERABILITY.

APPLICABILITY Tm RHR loops are required to be OPERABLE, and one RHR loop must be in operation in MODE 6, wth the water level < 23ft above the top of the reactor vessel flange, to provide decay heat removal and mixing of the borated coolant. Requirements for the RHR System in other fvODES are covered by LCOs in Section 3.4, Reactor Coolant System (RCS), and Section 3.5, Emergency Core Cooling Systems (ECCS). RHR loop requirements in fvODE 6 wth the water level

~ 23ft are located in LOO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation- High Water Level."

ACTIONS A.1 and A.2 If less than the required number of RHR loops are OPERABLE, action shall be immediately initiated and continued until the RHR loop is

{continued)

Vogtle Units 1 and 2 B 3.9.6-2 REVISION E4*23

t:OCIOSUrB 4 {0 I'lL*1 :l*U4~

VEGP Technical Specification Bases Marked Up Pages (for information only)

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

SURVEILLANCE SR 3.9.6.1 REQUIREfvENTS This Surveillance demonstrates that one RHR loop is in operation and circulating reactor coolant. The flow rate is determined by the flow rate necessary to provide sufficient decay heat removal capability and to provide mixing of the borated coolant to prevent thermal and boron stratWication in the core. In addition, during operation of the RHR loop with the ooter level in the vicinity of the reactor vessel nozzles, the RHR pump suction requirements must be met. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.9.6.2 RHR System piping and components have the potential to develop voids and pockets of entrained gases. Preventing and managing gas intrusion and accumulation is necessary for proper operation of the RHR loops and may also prevent ooter hammer, pump cavitation, and pumping of non condensible gas into the reactor vessel.

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

The RHR System is OPERABLE W'len it is sufficiently filled with water.

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

When the RHR System is restored to service, the surveillance is met by virtue of the performance of operating procedures that ensure the RHR Loop is adequately filled and vented. The performance of these manual actions ensures that the surveillance is met.

(continued)

Vogtle Units 1 and 2 B 3.9.6-4 E4*24 REVISION I

VEGP Technical Specification Bases Marked Up Pages (for Information only)

AHA and Coolant Circulation- LowWater Level 83.9.6 BASES SURVEILLANCE SR 3.9.6.2 (continued)

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

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

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

The SR may be met for a RHR Loop by virtue of having a loop in service in accordance with operating procedures.

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

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

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