Text

Issuance of Amendments Regarding Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program
	ML102520083
Person / Time
Site:	Vogtle
Issue date:	01/19/2011
From:	Martin R; Plant Licensing Branch II
To:	Ajluni M; Southern Nuclear Operating Co
	martin re, NRR/DORL, 415-1493
References
	TAC ME4091, TAC ME4092
	Download: ML102520083 (131)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 19, 2011 Mr. Mark J. Ajluni Nuclear Licensing Director Southern Nuclear Operating Company, Inc P.O. Box 1295, Bin - 038 Birmingham, Alabama 35201-1295

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2, ISSUANCE OF AMENDMENTS REGARDING RELOCATION OF SPECIFIC SURVEILLANCE FREQUENCY REQUIREMENTS TO A LICENSEE CONTROLLED PROGRAM (TAC NOS. ME4091 AND ME4092)

Dear Mr. Ajluni:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 158 to Facility Operating License NPF-68 and Amendment No. 140 to Facility Operating License NPF-81 for the Vogtle Electric Generating Plant, Units 1 and 2. The amendments consist of changes to the Facility Operating Licenses in response to your application dated June 15, 2010, as supplemented on January 7, 2011. Specifically, the amendments relocate specific surveillance frequency requirements to a licensee-controlled program using the Technical Specification Task Force (TSTF) recommendation 425-A Revision 3. The Notice of Availability of TSTF-425A was published in the Federal Register on July 6, 2009 (74 FR 31996). This item was not formally converted using Consolidated Line Item Improvement Process because of the nature of utilizing Probability Risk Analysis in the development of the surveillance frequencies, but the methodology is acceptable.

A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely,

,)-eC4/J1~~

V Robert E. Martin, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-424 and 50-425

Enclosures:

1. Amendment No. 158 to NPF-68

2. Amendment No. 140 to NPF-81

3. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON. GEORGIA VOGTLE ELECTRIC GENERATING PLANT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 158 License No. NPF-68

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment to the Vogtle Electric Generating Plant, Unit 1 (the facility) Facility Operating License No. NPF-68 filed by the Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated June 15, 2010, as supplemented January 7, 2011, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

-2

2. Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-68 is hereby amended to read as follows:

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 158, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 120 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION ia J. Kulesa, Chie~

Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Attachment Changes to License No. NPF-68 Date of Issuance: January 19, 2011

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA VOGTLE ELECTRIC GENERATING PLANT, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 140 License No. NPF-81

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment to the Vogtle Electric Generating Plant, Unit 2 (the facility) Facility Operating License No. NPF-81 filed by the Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated June 15, 2010, as supplemented January 7, 2011, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

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2. Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-81 is hereby amended to read as follows:

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 140, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 120 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

'P39 \ ~

ria J. Kulesa, Chief" Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to License No. NPF-81 Date of Issuance: January 19, 2011

ATTACHMENT TO LICENSE AMENDMENT NO. 158 FACILITY OPERATING LICENSE NO. NPF-68 DOCKET NO. 50-424 AND TO LICENSE AMENDMENT NO. 140 FACILITY OPERATING LICENSE NO. NPF-81 DOCKET NO. 50-425 Replace the following pages of the Licenses with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages License License License No. NPF-68, page 4 License No. NPF-68, page 4 License No. NPF-81, page 3 License No. NPF-81, page 3 Page Page iii iii 3.1.1-1 3.1.1-1 3.1.2-2 3.1.2-2 3.1.4-3 3.1.4-3 3.1.4-4 3.1.4-4 3.1.5-2 3.1.5-2 3.1.6-3 3.1.6-3 3.1.7-3 3.1.7-3 3.1.8-2 3.1.8-2 3.2.1-3 3.2.1-3 3.2.1-5 3.2.1-5 3.2.2-3 3.2.2-3 3.2.3-1 3.2.3-1 3.2.4-4 3.2.4-4 3.3.1-9 3.3.1-9 3.3.1-10 3.3.1-10 3.3.1-11 3.3.1-11 3.3.1-12 3.3.1-12 3.3.1-13 3.3.1-13 3.3.2-7 3.3.2-7 3.3.2-8 3.3.2-8 3.3.3-5 3.3.3-5

-2 Remove Pages Insert Pages 3.3.4-2 3.3.4-2 3.3.5-2 3.3.5-2 3.3.5-3 3.3.5-3 3.3.6-4 3.3.6-4 3.3.6-5 3.3.6-5 3.3.7-5 3.3.7-5 3.3.8-2 3.3.8-2 3.4.1-2 3.4.1-2 3.4.3-2 3.4.3-2 3.4.4-1 3.4.4-1 3.4.5-2 3.4.5-2 3.4.5-3 3.4.5-3 3.4.6-2 3.4.6-2 3.4.6-3 3.4.6-3 3.4.7-2 3.4.7-2 3.4.7-3 3.4.7-3 3.4.8-2 3.4.8-2 3.4.9-2 3.4.9-2 3.4.11-3 3.4.11-3 3.4.12-4 3.4.12-4 3.4.12-5 3.4.12-5 3.4.13-2 3.4.13-2 3.4.14-4 3.4.14-4 3.4.15-3 3.4.15-3 3.4.15-4 3.4.15-4 3.4.16-2 3.4.16-2 3.4.16-3 3.4.16-3 3.5.1-2 3.5.1-2 3.5.2-2 3.5.2-2 3.5.2-3 3.5.2-3 3.5.4-2 3.5.4-2 3.5.5-2 3.5.5-2 3.5.6-2 3.5.6-2 3.6.2-5 3.6.2-5 3.6.3-4 3.6.3-4 3.6.3-5 3.6.3-5 3.6.4-1 3.6.4-1 3.6.5-1 3.6.5-1 3.6.6-2 3.6.6-2 3.6.6-3 3.6.6-3 3.7.4-2 3.7.4-2 3.7.5-3 3.7.5-3 3.7.5-4 3.7.5-4 3.7.6-1 (Unit 1) 3.7.6-1 (Unit 1) 3.7.6-1 (Unit 2) 3.7.6-2 (Unit 2) 3.7.7-2 3.7.7-2

-3 Remove Pages Insert Pages 3.7.8-2 3.7.8-2 3.7.9-3 3.7.9-3 3.7.10-4 3.7.10-4 3.7.13-1 3.7.13-1 3.7.13-2 3.7.13-2 3.7.14-2 3.7.14-2 3.7.15-1 3.7.15-1 3.7.16-1 3.7.16-1 3.7.17-1 3.7.17-1 3.8.1-7 3.8.1-7 3.8.1-8 3.8.1-8 3.8.1-9 3.8.1-9 3.8.1-10 3.8.1-10 3.8.1-11 3.8.1-11 3.8.1-12 3.8.1-12 3.8.1-13 3.8.1-13 3.8.1-14 3.8.1-14 3.8.1-15 3.8.1-15 3.8.1-16 3.8.1-16 3.8.1-17 3.8.1-17 3.8.3-3 3.8.3-3 3.8.3-4 3.8.4-2 3.8.4-2 3.8.4-3 3.8.4-3 3.8.6-3 3.8.6-3 3.8.6-4 3.8.6-4 3.8.7-2 3.8.7-2 3.8.8-2 3.8.8-2 3.8.9-2 3.8.9-2 3.8.10-2 3.8.10-2 3.9.1-1 3.9.1-1 3.9.2-2 3.9.2-2 3.9.3-2 3.9.3-2 3.9.4-2 3.9.4-2 3.9.5-2 3.9.5-2 3.9.6-2 3.9.6-2 3.9.7-2 3.9.7-2 5.5-20 5.5-20

- 4 (1 ) Maximum Power Level Southern Nuclear is authorized to operate the facility at reactor core power levels not in excess of 3625.6 megawatts thermal (100 percent power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Spedfications contained in Appendix A, as revised through Amendment No. 158 and the Environmental Protection Plan contained in Appendix B. both of Which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Southern Nuclear Operating Company shall be capable of establishing containment hydrogen monitoring within 90 minutes of initiating safety injection following a loss of coolant accident.

(4) Deleted (5) Deleted (6) Deleted (7) Deleted (8) Deleted (9) Deleted (10) Mitigation Strategy License Condition The licensee shall develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the follOWing:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-avaIlable pre-staged equipment

6. Training on integrated fire response strategy Renewed Operating License No. NPF-68 Amendment No. 158

-3 (2) Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia, pursuant to the Act and 10 CFR Part 50, to possess but not operate the facility at the designated 10caUon in Burke County, Georgia, in accordance with the procedures and limitations set forth in this license:

(3) Southern Nuclear, pursuant to the Act and 10 CFR Part 70, to receive, possess, and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (4) Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40, and 70 to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitor'ing equipment calibration, and as fission detectors in amounts as required; (5) Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; (6) Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40. and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility authorized herein.

C. This license shall be deemed to contain and Is SUbject 10 the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is SUbject lo all applicable provisions of the Act and to the rUles, regulations. and orders of the Commission now or hereafter in effect, and is subject to the additional conditions specified or incorporated below.

(1 ) Maximum Power Level Southern Nuclear is authorized to operate the facility at reactor core power levels not in excess of 3625.6 megawatts thermal (100 percent power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Srpl"'!fications contained in Appendix A, as revised through Amendment No. 140 and the Environmental Protection Plan contained in Appendix 8, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

The Surveillance Requirements (SRs) contained in the Appendix A Technical Specifications and listed below are not required to be pertormed immediately upon implementation of Amendmenl No. 74. The SRs listed below shall be Renewed Operatira License NPF*B1 Amendment No .140

TABLE OF CONTENTS CONTAINMENT SySTEMS................................................................... 3.6.1-1 3.6.1 Containment 3.6.1-1 3.6.2 Containment Air Locks 3.6.2-1 3.6.3 Containment Isolation Valves 3.6.3-1 3.6.4 Containment Pressure............................................................................ 3.6.4-1 3.6.5 Containment Air Temperature 3.6.5-1 3.6.6 Containment Spray and Cooling Systems.............................................. 3.6.6-1 3.6.7 Deleted 3.6.7-1 3.7 PLANT SYSTEMS 3.7.1-1 3.7.1 Main Steam Safety Valves (MSSVs)...................................................... 3.7.1-1 3.7.2 Main Steam Isolation Valves (MSIVs) 3.7.2-1 3.7.3 Main Feedwater Isolation Valves (MFIVs) and Main Feedwater Regulation Valves (MFRVs) and Associated Bypass Valves 3.7.3-1 3.7.4 Atmospheric Relief Valves (ARVs) 3.7.4-1 3.7.5 Auxiliary Feedwater (AFW) System........................................................ 3.7.5-1 3.7.6 Condensate Storage Tank (CST) - (Redundant CSTs).......................... 3.7.6-1 3.7.7 Component Cooling Water (CCW) System 3.7.7-1 3.7.8 Nuclear Service Cooling Water (NSCW) System 3.7.8-1 3.7.9 Ultimate Heat Sink (UHS)....................................................................... 3.7.9-1 3.7.10 Control Room Emergency Filtration System (CREFS) - Both Units Operating............................................................................... 3.7.10-1 3.7.11 Control Room Emergency Filtration System (CREFS) - One Unit Operating 3.7.11-1 3.7.12 Control Room Emergency Filtration System (CREFS) - Both Units Shutdown 3.7.12-1 3.7.13 Piping Penetration Area Filtration and Exhaust System (PPAFES) 3.7.13-1 3.7.14 Engineered Safety Features (ESF) Room Cooler and Safety Related Chiller System........................................................ 3.7.14-1 3.7.15 Fuel Storage Pool Water Level............................................................... 3.7.15-1 3.7.16 Secondary Specific Activity....... 3.7.16-1 3.7.17 Fuel Storage Pool Boron Concentration................................................. 3.7.17-1 3.7.18 Fuel Assembly Storage in the Fuel Storage PooL.................................. 3.7.18-1 (continued)

Vogtle Units 1 and 2 iii Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

SDM 3.1.1 3.1 REACTIVITY CONTROL SYSTEMS 3.1.1 SHUTDOWN MARGIN (SDM)

LCO 3.1.1 SDM shall be ~ the limit specified in the COLR.

APPLICABILITY: MODES 3, 4, and 5.

ACTIONS

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

While this LCO is not met, transition to a lower MODE within the Applicability is not permitted.

CONDITION REQUIRED ACTION COMPLETION TIME A. SDM not within limit. A.1 Initiate boration to restore 15 minutes SDM to within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.1 Verify SDM is::?: the limit specified in the COLR. In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.1.1-1 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Core Reactivity 3.1.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2.1 --------------------------NOTE-----------------------

The predicted reactivity values may be adjusted (normalized) to correspond to the measured core reactivity prior to exceeding a fuel burnup of 60 effective full power days (EFPD) after each fuel loading.

Verify measured core reactivity is within +/- 1% Liklk Once prior to of predicted values. entering MODE 1 after each refueling In accordance with the Surveillance Frequency Control Program VogUe Units 1 and 2 3.1.2-2 Amendment No. 158 (Unit 1)

Amendment No.140 (Unit 2)

Rod Group Alignment Limits 3.1.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition B not met.

D. More than one rod not D.1.1 Verify SDM is ~ the limit 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months within alignment limit. specified in the COLR.

OR D.1.2 Initiate boration to restore 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months required SDM to within limit.

AND D.2 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.4.1 Verify individual rod positions within alignment In accordance with limit. the Surveillance Frequency Control Program Once within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months thereafter when the rod position deviation monitor is inoperable (continued)

Vogtle Units 1 and 2 3.1.4-3 Amendment No.1 58 (Unit 1)

Amendment No.140 (Unit 2)

Rod Group Alignment Limits 3.1.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.4.2 Verify rod freedom of movement by moving each In accordance with rod not fully inserted in the core ~ 10 steps in the Surveillance either direction. Frequency Control Program SR 3.1.4.3 Verify rod drop time of each rod, from the physical Prior to reactor fully withdrawn position, is s; 2.7 seconds from the criticality after beginning of decay of stationary gripper coil each removal of voltage to dashpot entry, with: the reactor head

b. All reactor coolant pumps operating.

Vogtle Units 1 and 2 3.1.4-4 Amendment No.158 (Unit 1)

Amendment No.140 (Unit 2)

Shutdown Bank Insertion Limits 3.1.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.5.1 Verify each shutdown bank is within the insertion In accordance with limits specified in the COLR. the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.1.5-2 Amendment No. 158 (Unit 1)

Amendment No.140 (Unit 2)

Control Bank Insertion Limits 3.1.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.6.2 Verify each control bank insertion is within the In accordance with limits specified in the COLR. the Surveillance Frequency Control Program Once within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months thereafter when the rod insertion limit monitor is inoperable SR 3.1.6.3 Verify sequence and overlap limits specified in the In accordance with COLR are met for control banks not fully the Surveillance withdrawn from the core. Frequency Control Program Vogtle Units 1 and 2 3.1.6-3 Amendment No.158 (Unit 1)

Amendment No.140 (Unit 2)

Rod Position Indication 3.1.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.7.1 Verify each DRPI agrees within 12 steps of the In accordance with group demand position for the full indicated range the Surveillance of rod travel. Frequency Control

! Program Vogtle Units 1 and 2 3.1.7-3 Amendment No.158 (Unit 1)

Amendment No. 140 (Unit 2)

PHYSICS TESTS Exceptions - MODE 2 3.1.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. RCS lowest loop C.1 Restore RCS lowest loop 15 minutes average temperature not average temperature to within limit. within limit.

D. Required Action and D.1 Be in MODE 3. 15 minutes associated Completion Time of Condition C not met.

I SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.8.1 Perform a CHANNEL OPERATIONAL TEST on Within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior power range and intermediate range channels per to initiation of SR 3.3.1.7, SR 3.3.1.8, and Table 3.3.1-1. PHYSICS TESTS SR 3.1.8.2 Verify the RCS lowest loop average temperature In accordance with is ~ 541°F. the Surveillance Frequency Control Program SR 3.1.8.3 Verify SDM is ~ the limit specified in the COLR. In accordance with I the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.1.8-2 Amendment No.158 (Unit 1)

Amendment No.140 (Unit 2)

FQ{Z) 3.2.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify FQ{Z) is within steady state limit. Once after each refueling after achieving equilibrium conditions at any power level exceeding 50% RTP Once after achieving equilibrium conditions after exceeding, by

~ 20% RTP. the THERMAL POWER at which FQ{Z) was last verified In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.2.1-3 Amendment No.158 (Unit 1)

Amendment No.140 (Unit 2)

Fa(Z) 3.2.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.2 (continued) Once after achieving equilibrium conditions after exceeding, by

~ 20% RTP, the THERMAL POWER at which Fa(Z) was last verified In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.2.1-5 Amendment NO.158 (Unit 1)

Amendment No. 140 (Unit 2)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.2.1 Verify F~H is within limits specified in the COLR. Once after each refueling prior to THERMAL POWER exceeding 75% RTP In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.2.2-3 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

AFD (RAOC Methodology) 3.2.3 3.2 POWER DISTRIBUTION LIMITS 3.2.3 AXIAL FLUX DIFFERENCE (AFD) (Relaxed Axial Offset Control (RAOC) Methodology)

LCO 3.2.3 The AFD shall be maintained within the limits specified in the COLR.

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

The AFD shall be considered outside limits when two or more OPERABLE excore channels indicate AFD to be outside limits.

APPLICABILITY: MODE 1 with THERMAL POWER ~ 50% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. AFD not within limits. A.1 Reduce THERMAL 30 minutes POWER to < 50% RTP.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.3.1 Verify AFD within limits for each OPERABLE In accordance with excore channel. the Surveillance Frequency Control Program Once within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and every 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months thereafter with the AFD monitor alarm inoperable VogUe Units 1 and 2 3.2.3-1 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

QPTR 3.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.4.1 ------------------------NOTE----------------------------

With one power range channel inoperable, the remaining three power range channels can be used for calculating QPTR.

Verify QPTR is within limit by calculation. In accordance with the Surveillance Frequency Control Program Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter with the QPTR alarm inoperable SR 3.2.4.2 ---------------------NOTE------------------

Only required to be performed if input to QPTR from one or more Power Range Neutron Flux channels is inoperable with THERMAL POWER

~ 75% RTP.

Confirm that the normalized symmetric power Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months distribution is consistent with QPTR.

In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.2.4-4 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

RTS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS

N 0 TE---------------------------------------------------

Refer to Table 3.3.1-1 to determine which SRs apply for each RTS Function.

SURVEILLANCE FREQUENCY SR 3.3.1.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.1.2 ------------------------N 0 TES-----------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is ~ 15% RTP.

Compare results of calorimetric heat balance In accordance with calculation to power range channel output. Adjust the Surveillance power range channel output if calorimetric heat Frequency Control balance calculation results exceed power range Program channel output by more than +2% RTP.

SR 3.3.1.3 ---------------------NOTES--------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is ~ 15% RTP.

Compare results of the incore detector In accordance with measurements to Nuclear Instrumentation System the Surveillance (NIS) AFD. Adjust NIS channel if absolute Frequency Control difference is ;;::. 3%. Program (continued)

Vogtle Units 1 and 2 3.3.1-9 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

RTS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.4 ------------------------NOTE------------------------------

This Surveillance must be performed on the reactor trip bypass breaker prior to placing the bypass breaker in service.

Perform TADOT. In accordance with the Surveillance Frequency Control Program SR 3.3.1.5 Perform ACTUATION LOGIC TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.1.6 ------------------NOTES---------------------

1. Not required to be performed until 7 days after THERMAL POWER is ~ 75% RTP.

2. Neutron detectors are excluded from CHANNEL CALIBRATION.

Calibrate excore channels to agree with incore In accordance with detector measurements. the Surveillance Frequency Control

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _I_p_r_o_gr_a_m---, ...,..,....

(continued)

Vogtle Units 1 and 2 3.3.1-10 Amendment No. 158 (Unit 1)

Amendment No.140 (Unit 2)

RTS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.7 ----------------------------N OTES--------------------------

1. For the Source Range Instrumentation this surveillance shall include verification that interlocks P-6 and P-10 are in their required state for existing unit conditions.

2. Not required to be performed for Source Range Instrumentation prior to entering MODE 3 from MODE 2 until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after entry into MODE 3.

Perform COT. In accordance with the Surveillance Frequency Control i Program I

SR 3.3.1.8 -----------------NOTE--------------------

Only required when not performed within previous 31 days.

Perform COT. Prior to Reactor Startup SR 3.3.1.9 -------------------------NOTE-.--------------------

Verification of setpoint is not required.

Perform TADOT. In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.3.1-11 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

RTS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.10 ------------------------------NOTE--------------------------

This Surveillance shall include verification that the time constants are adjusted to the prescribed values.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.1.11 -------------------N0 TE--------------------------

Neutron detectors are excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control

Program SR 3.3.1.12 Perform COT. In accordance with the Surveillance Frequency Control Program SR 3.3.1.13 -----------------------N OT E------------------------

Verification of setpoint is not required.

Perform TADOT. In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.3.1-12 Amendment No.158 (Unit 1)

Amendment No.140 (Unit 2)

RTS Instrumentation 3.3.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.14 ---------------------------N OTES------------------------

1. Only required when not performed within previous 31 days.

2. Verification of setpoint is not required.

Perform TADOT. After each MODE 3 entry for unit shutdown and prior to exceeding the P-9 interlock trip setpoint.

SR 3.3.1.15 -------------------------N0 TE-------------------------

Neutron detectors are excluded from response time testing.

Verify RTS RESPONSE TIME is within limits. In accordance with the Surveillance Frequency Control Program SR 3.3.1.16 -------------------------NOTE S--------------------

1. Only required when not performed within previous 31 days.

2. Verification of setpoint is not required.

Perform COT. After each MODE 3 entry for unit shutdown and prior to exceeding the P-9 interlock trip setpoint.

Vogtle Units 1 and 2 3.3.1-13 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

ESFAS Instrumentation 3.3.2 SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.2-1 to determine which SRs apply for each ESFAS Function.

SURVEILLANCE FREQUENCY SR 3.3.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.2.2 Perform ACTUATION LOGIC TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.3 Perform MASTER RELAY TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.2.4 Perform COT. In accordance with the Surveillance Frequency Control Program SR 3.3.2.5 Perform SLAVE RELAY TEST. In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.3.2-7 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

ESFAS Instrumentation 3.3.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.2.6 ---------------------------NOTE-----------------------------

Verification of setpoint not required for manual initiation functions.

Perform TADOT. In accordance with the Surveillance Frequency Control Program SR 3.3.2.7 ------------------------N0 TE----------------------------

This Surveillance shall include verification that the time constants used for the Steam Line Pressure instrument functions are adjusted to the prescribed values.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.2.8 -------------------------NOTE--------------------------

Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after SG pressure is

~ 900 psig.

Verify ESFAS RESPONSE TIMES are within limit. In accordance with the Surveillance Frequency Control Program SR 3.3.2.9 ----------------------NO TE---------------------------

Verification of setpoint not required.

Perform TADOT. In accordance with the Surveillance Frequency Control Program VogUe Units 1 and 2 3.3.2-8 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

PAM Instrumentation 3.3.3 SURVEILLANCE REQUIREMENTS

N OTE-------------------------------------------------------

SR 3.3.3.1 and SR 3.3.3.2 apply to each PAM instrumentation Function in Table 3.3.3-1.

SURVEILLANCE FREQUENCY SR 3.3.3.1 Perform CHANNEL CHECK for each required In accordance with instrumentation channel. the Surveillance Frequency Control

, Program SR 3.3.3.2 ----------------------- NOTE------------------------

Neutron detectors are excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.3.3-5 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Remote Shutdown System 3.3.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.4.1 Perform CHANNEL CHECK for each required In accordance with monitoring instrumentation channel that is normally the Surveillance energized. ! Frequency Control Program SR 3.3.4.2 Verify each required control circuit and transfer In accordance with switch is capable of performing the intended the Surveillance function. Frequency Control Program SR 3.3.4.3 ----------------------NOTE--------------------------

Neutron detectors are excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION for each In accordance with required monitoring instrumentation channel. the Surveillance I Frequency Control Program Vogtle Units 1 and 2 3.3.4-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

LOP Instrumentation 3.3.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Actions and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Times not met in MODES AND 1,2,3, or 4.

D.2 Be in MODE 5. ! 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months E. Required Action and E.1 Enter applicable Immediately associated Completion Condition(s) and Time not met when the Required Action(s) for the associated DG is associated DG made required OPERABLE by inoperable by LOP DG LCO 3.8.2. start instrumentation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.5.1 Perform COT. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2 Perform CHANNEL CALIBRATION with Nominal Trip In accordance with Setpoint and Allowable Value as follows: the Surveillance Frequency Control A. Loss of voltage Allowable Value ~ 2912 V with Program a time delay of ~ 0.8 second.

Loss of voltage Nominal Trip Setpoint 2975 V with a time delay of $ 0.8 second.

B. Degraded voltage Allowable Value ~ 3683 V with a time delay of $ 20 seconds.

Degraded voltage Nominal Trip Setpoint 3746 V with a time delay of $ 20 seconds.

(continued)

Vogtle Units 1 and 2 3.3.5-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

LOP Instrumentation 3.3.5 SURVEILLANCE FREQUENCY SR 3.3.5.3 --------------------------NOTE----------------------------

Not required to be performed for the turbine-driven Auxiliary Feedwater (AFW) pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after Steam Generator pressure is ~ 900 psig.

Verify AFW system ESF RESPONSE TIME for loss In accordance with of voltage and degraded voltage on the 4.16 kV ESF the Surveillance buses within limit. Frequency Control I Program Vogtle Units 1 and 2 3.3.5-3 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Containment Ventilation Isolation Instrumentation 3.3.6 SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.6-1 to determine which SRs apply for each Containment Purge and Exhaust Isolation Function.

SURVEILLANCE FREQUENCY SR 3.3.6.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.6.2 Perform ACTUATION LOGIC TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.6.3 Perform MASTER RELAY TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.6.4 Perform COT. In accordance with the Surveillance Frequency Control Program SR 3.3.6.5 Perform SLAVE RELAY TEST. In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.3.6-4 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Containment Ventilation Isolation Instrumentation 3.3.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.6.6 --------------------- NOTE-------------------------------

Verification of setpoint not required.

Perform TADOT. In accordance with the Surveillance Frequency Control Program SR 3.3.6.7 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.6.8 Verify RESPONSE TIMES are within limits. In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.3.6-5 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

CREFS Actuation Instrumentation 3.3.7 SURVEILLANCE REQUIREMENTS

N0 TE-----------------------------------------------

Refer to Table 3.3.7-1 to determine which SRs apply for each CREFS Actuation Function.

SURVEILLANCE FREQUENCY SR 3.3.7.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.7.2 Perform COT. In accordance with the Surveillance Frequency Control Program SR 3.3.7.3 Perform ACTUATION LOGIC TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.7.4 -------------------N0 TE-------------------------

Verification of setpoint is not required.

Perform TADOT. In accordance with the Surveillance Frequency Control Program SR 3.3.7.5 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program SR 3.3.7.6 Verify ESF RESPONSE TIME for radio-gas In accordance with monitors within limit. the Surveillance Frequency Control Program VogUe Units 1 and 2 3.3.7-5 Amendment No.158 (Unit 1)

Amendment No.140 (Unit 2)

High Flux at Shutdown Alarm 3.3.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

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

Not required to be performed prior to entering MODE 3 from MODE 2 until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after entry into MODE 3.

SR 3.3.8.1 Perform COT. In accordance with the Surveillance Frequency Control Program SR 3.3.8.2 Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.3.8-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

RCS Pressure, Temperature, and Flow DNB Limits 3.4.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.1.1 Verify pressurizer pressure is ~ 2199 psig. In accordance with the Surveillance Frequency Control Program SR 3.4.1.2 Verify RCS average temperature is ~ 592.5°F. In accordance with the Surveillance Frequency Control Program SR 3.4.1.3 Monitor RCS total flow rate for degradation. In accordance with the Surveillance Frequency Control Program SR 3.4.1.4 ----------------------N OTE----_.-------------------

Not required to be performed until 7 days after

~ 90% RTP.

Verify by precision heat balance that RCS total In accordance with flow rate is ~ 384,509 gpm. the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.4.1-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

RCS PIT Limits 3.4.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. ---------NOTE---------- C.1 Initiate action to restore Immediately Required Action C.2 parameter(s) to within shall be completed limits.

whenever this Condition is entered. AND C.2 Determine RCS is Prior to entering Requirements of LCO acceptable for continued MODE4 not met any time in other operation.

than MODE 1, 2, 3, or 4.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.3.1 ---------------------NOTE---------------------

Only required to be performed during RCS heatup and cooldown operations and RCS inservice leak and hydrostatic testing.

Verify RCS pressure, RCS temperature, and RCS In accordance with heatup and cooldown rates are within the limits I the Surveillance specified in the PTLR. I Frequency Control Program Vogtle Units 1 and 2 3.4.3-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

RCS Loops - MODES 1 and 2 3.4.4 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.4 RCS Loops - MODES 1 and 2 LCO 3.4.4 Four RCS loops shall be OPERABLE and in operation.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of LCO A.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.4.1 Verify each RCS loop is in operation. In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.4.4-1 Amendment No.158 (Unit 1)

Amendment No.140 (Unit 2)

RCS Loops - MODE 3 3.4.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One required RCS loop C.1 Restore required RCS 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months not in operation, and loop to operation.

reactor trip breakers closed and Rod Control OR System capable of rod withdrawal. i C.2 De-energize all control 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months rod drive mechanisms (CRDMs).

D. Two required RCS loops D.1 De-energize all CRDMs. Immediately inoperable.

AND OR D.2 Suspend all operations Immediately No RCS loop in involving a reduction of operation. RCS boron concentration.

AND D.3 Initiate action to restore Immediately one RCS loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1 Verify required RCS loops are in operation. In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.4.5-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

RCS Loops - MODE 3 3.4.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.2 Verify steam generator secondary side water In accordance with levels are above the highest point of the steam the Surveillance generator U-tubes for required RCS loops. Frequency Control Program SR 3.4.5.3 Verify correct breaker alignment and indicated i In accordance with power are available to the required pump that is I the Surveillance not in operation. I Frequency Control Program Vogtle Units 1 and 2 3.4.5-3 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

RCS Loops - MODE 4 3.4.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One required RHR loop B.1 Be in MODE 5. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months inoperable.

AND Two required RCS loops I inoperable.

C. Both required RCS or C.1 Suspend all operations Immediately RHR loops inoperable. involving a reduction of RCS boron concentration.

OR AND No RCS or RHR loop in operation. C.2 Initiate action to restore Immediately one loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify one RHR or RCS loop is in operation. In accordance with the Surveillance Frequency Control Program SR 3.4.6.2 Verify SG secondary side water levels are above In accordance with the highest point of the steam generator U-tubes the Surveillance for reqUired RCS loops. Frequency Control Program (continued)

Vogtle Units 1 and 2 3.4.6-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

RCS Loops - MODE 4 3.4.6 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 Vogtle Units 1 and 2 3.4.6-3 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

RCS Loops - MODE 5, Loops Filled 3.4.7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR loop A.1 Initiate action to restore a Immediately inoperable. second RHR loop to OPERABLE status.

AND OR Required SGs secondary side water A.2 Initiate action to restore Immediately levels not within limits. required SG secondary side water levels to within limits.

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

OR AND No RHR loop in operation. B.2 Initiate action to restore Immediately one RHR loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 Verify one RHR loop is in operation. In accordance with the Surveillance Frequency Control Program SR 3.4.7.2 Verify SG secondary side water level is above the In accordance with highest point of the steam generator U-tubes for the Surveillance the required SGs. Frequency Control Program (continued)

Vogtle Units 1 and 2 3.4.7-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

RCS Loops - MODE 5, Loops Filled 3.4.7 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 Program Vogtle Units 1 and 2 3.4.7-3 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

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 power In accordance with the are available to the required RHR pump that is not in 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 Vogtle Units 1 and 2 3.4.8-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Pressurizer 3.4.9 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.9.1 Verify pressurizer water level is ~ 92%. In accordance with the Surveillance Frequency Control Program SR 3.4.9.2 Verify capacity of each required group of In accordance with pressurizer heaters is ~ 150 kW. the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.4.9-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Pressurizer PORVs 3.4.11 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME F. (continued) F.2 Restore one block valve 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to OPERABLE status.

AND F.3 Restore remaining 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months block valve to OPERABLE status.

G. Required Action and G.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition F not AND met.

G.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.11.1 ---------------------N0 TE--------------------------

Not required to be performed with block valve closed in accordance with the Required Action of Conditions A, B, or E.

Perform a complete cycle of each block valve. In accordance with the Surveillance Freq uency Control Program SR 3.4.11.2 Perform a complete cycle of each PORV. In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.4.11-3 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

COPS 3.4.12 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.12.1 Verify both safety injection pumps are incapable In accordance with the of injecting into the RCS. Surveillance Frequency Control Program SR 3.4.12.2 Verify each accumulator is isolated. In accordance with the Surveillance Frequency Control Program SR 3.4.12.3 Verify RHR suction valves are open for each In accordance with the required RHR suction relief valve. Surveillance Frequency Control Program SR 3.4.12.4 ---------------------N aTE------------------------

Only required to be performed when complying with LCO 3.4.12.b.

Verify RCS vent size within specified limits. In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.4.12-4 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

COPS 3.4.12 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.12.5 Verify PORV block valve is open for each In accordance with the required PORV. Surveillance Frequency Control Program SR 3.4.12.6 ---------------------NOTE-------------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after decreasing RCS cold leg temperature to s; the COPS arming temperature specified in the PTLR.

Perform a COT on each required PORV, In accordance with the excluding actuation. Surveillance Frequency Control Program SR 3.4.12.7 Perform CHANNEL CALIBRATION for each In accordance with the required PORV actuation channel. Surveillance Frequency Control Program Vogtle Units 1 and 2 3.4.12-5 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

RCS Operational LEAKAGE 3.4.13 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.13.1 ----------------------------NOTES-----------------------

1. Not required to be performed in MODE 3 or 4 until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of steady state operation.

2. Only required to be performed during steady state operation.

3. Not applicable to primary to secondary LEAKAGE.

Perform RCS water inventory balance. Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving steady state operation In accordance with the Surveillance Frequency Control Program SR 3.4.13.2 ------------------------NOTE-----------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of steady state operation.

Verify primary to secondary LEAKAGE is ~ 150 In accordance with the gallons per day through anyone SG. Surveillance Frequency Control Program Vogtle Units 1 and 2 3.4.13-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

RCS PIV Leakage 3.4.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.14.1 (continued) For systems rated at less than 50% RCS design pressure, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months following valve actuation (except for valves HV-8701A1B and HV-8702A1B).

SR 3.4.14.2 Verify RHR System suction isolation valve In accordance with interlock prevents the valves from being opened the Surveillance with a simulated or actual RCS pressure signal Frequency Control

~ 450 psig. II Program Vogtle Units 1 and 2 3.4.14-4 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required containment E.1 Restore required 30 days atmosphere radioactivity containment atmosphere monitor inoperable. radioactivity monitor to OPERABLE status.

AND OR Required containment air cooler condensate E.2 Restore required 30 days flow rate monitor containment air cooler inoperable. condensate flow rate monitor to OPERABLE status.

F. Required Action and F.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND F.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months G. All required leakage G.1 Enter LCO 3.0.3. Immediately detection systems inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 Perform CHANNEL CHECK of containment In accordance with normal sumps level and reactor cavity sump level the Surveillance monitors. Frequency Control Program (continued)

Vogtle Units 1 and 2 3.4.15-3 Amendment No. 158 (Unit 1)

Amendment No. 'i40 (Unit 2)

RCS Leakage Detection Instrumentation 3.4.15 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.15.2 Perform CHANNEL CHECK of the required In accordance with containment atmosphere radioactivity monitor. the Surveillance Frequency Control Program SR 3.4.15.3 Perform COT of the required containment In accordance with atmosphere radioactivity monitor. the Surveillance Frequency Control Program SR 3.4.15.4 Perform CHANNEL CALIBRATION of the In accordance with containment sump monitors. the Surveillance Frequency Control Program SR 3.4.15.5 Perform CHANNEL CALIBRATION of the In accordance with required containment atmosphere radioactivity the Surveillance monitor. Frequency Control Program SR 3.4.15.6 Perform CHANNEL CALIBRATION of the In accordance with required containment air cooler condensate flow the Surveillance rate monitor. Frequency Control Program Vogtle Units 1 and 2 3.4.15-4 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

RCS Specific Activity 3.4.16 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3 with 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Tavg < 500°F.

Time of Condition A not met.

OR DOSE EQUIVALENT 1-131 in the unacceptable region of Figure 3.4.16-1.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.16.1 Verify reactor coolant gross specific In accordance with activitY:5 100/E jlCi/gm. the Surveillance Frequency Control Program SR 3.4.16.2 -----------------------N0 TE-------------------------

Only required to be performed in MODE 1.

Verify reactor coolant DOSE EQUIVALENT 1-131 In accordance with specific activity :5 1.0 !1Ci/gm. the Surveillance Frequency Control Program Between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after a THERMAL POWER change of ~ 15% RTP within a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period (continued)

Vogtle Units 1 and 2 3.4.16-2 Amendment No.158 (Unit 1)

Amendment No. 140 (Unit 2)

RCS Specific Activity 3.4.16 SURVEILLANCE FREQUENCY SR 3.4.16.3 -----------------------NOTE---------------------------

Not required to be performed until 31 days after a minimum of 2 effective full power days and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for ~ 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

Determine Efrom a sample taken in MODE 1 In accordance with after a minimum of 2 effective full power days and the Surveillance 20 days of MODE 1 operation have elapsed since Frequency Control the reactor was last subcritical for ~ 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . Program Vogtle Units 1 and 2 3.4.16-3 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Accumulators 3.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify each accumulator isolation valve is fully In accordance with open. the Surveillance Frequency Control Program SR 3.5.1.2 Verify borated water volume in each accumulator In accordance with is ~ 6555 gallons and ~ 6909 gallons. the Surveillance Frequency Control Program SR 3.5.1.3 Verify nitrogen cover pressure in each In accordance with accumulator is ~ 617 psig and ~ 678 psig. the Surveillance Frequency Control Program SR 3.5.1.4 Verify boron concentration in each accumulator is In accordance with

~ 1900 ppm and ~ 2600 ppm. the Surveillance Frequency Control Program For each affected accumulator, once within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after each solution volume increase of ~ 67 gallons, that is not the result of addition from the refueling water storage tank SR 3.5.1.5 Verify power is removed from each accumulator In accordance with isolation valve operator when pressurizer the Surveillance pressure is > 1000 psig. Frequency Control Program Vogtle Units 1 and 2 3.5.1-2 Amendment No.158 (Unit 1)

Amendment No.140 (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 SI Pump Cold Leg Inj. OPEN HV-8840 RHR Pump Hot Leg Inj. CLOSED HV-8813 SI Pump Mini Flow Isol. OPEN HV-8806 SI Pump Suction from RWST OPEN HV-8802A, B SI Pump Hot Leg Inj. CLOSED HV-8809A, B RHR Pump Cold Leg Inj. OPEN SR 3.5.2.2 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 piping is full of water. In accordance with 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 Inservice 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. 158 (Unit 1)

Amendment No. 140 (Unit 2)

ECCS - Operating 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.6 Verify each ECCS pump starts automatically on In accordance with an actual or simulated actuation signal. the Surveillance Frequency Control Program SR 3.5.2.7 Verify, by visual inspection, each ECCS train In accordance with containment sump suction inlet is not restricted by the Surveillance debris and the suction inlet trash racks and Frequency Control screens show no evidence of structural distress or Program abnormal corrosion.

Vogtle Units 1 and 2 3.5.2-3 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

RWST 3.5.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or D AND not met.

E.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.4.1 -----------------------N 0 TE--------------------------

Only required to be performed when ambient air temperature is < 40°F.

Verify RWST borated water temperature is In accordance with the

~ 44°F and::;; 116°F. Surveillance Frequency Control Program SR 3.5.4.2 Verify RWST borated water volume is ~ 686,000 In accordance with the gallons. Surveillance Frequency Control Program SR 3.5.4.3 Verify RWST boron concentration is ~ 2400 ppm In accordance with the and ~ 2600 ppm. Surveillance Frequency Control Program SR 3.5.4.4 Verify each sludge mixing pump isolation valve In accordance with the automatically closes on an actual or simulated Surveillance RWST Low-Level signal. Frequency Control Program Vogtle Units 1 and 2 3.5.4-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Seal Injection Flow 3.5.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.5.1 ---------------------------NO TE--------------------------

Not required to be performed until 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months after the Reactor Coolant System pressure stabilizes at:?: 2215 psig and:::; 2255 psig.

Verify manual seal injection throttle valves are In accordance with the adjusted to give a flow within the ECCS safety Surveillance analysis limits. Frequency Control Program Vogtle Units 1 and 2 3.5.5-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

ECCS Recirculation Fluid pH Control System 3.5.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.6.1 Perform a visual inspection of the Recirculation In accordance with Fluid pH Control System and verify the following: the Surveillance Frequency Control a) Three storage baskets are in place, and Program b) have maintained their integrity, and c) the baskets contain a total of

~ 11,484 pounds (220 cubic feet) and

$ 14,612 pounds (260 cubic feet) of trisodium phosphate crystals.

Vogtle Units 1 and 2 3.5.6-2 Amendment No. 158 (Unit 1)

Amendment No.140 (Unit 2)

Containment Air Locks 3.6.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.1 -------------------------N 0 TES-------------------------

1. An inoperable air lock door does not invalidate the previous successful performance of the overall air lock leakage test.

2. Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1.

Perform required air lock leakage rate testing in In accordance with accordance with the Containment Leakage Rage the Containment Testing Program. Leakage Rate Testing Program SR 3.6.2.2 Verify only one door in the air lock can be opened In accordance with at a time. the Surveillance Frequency Control Program Vogtle Units land 2 3.6.2-5 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Containment Isolation Valves 3.6.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and 0.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND 0.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.1 Verify each 24 inch purge valve is sealed closed, In accordance with except for one purge valve in a penetration flow the Surveillance path while in Condition C of this LCO. Frequency Control Program SR 3.6.3.2 Verify each 14 inch purge valve is closed, except In accordance with when the associated penetration(s) is (are) the Surveillance permitted to be open for purge or venting Frequency Control operations and purge system surveillance and Program maintenance testing under administrative control.

SR 3.6.3.3 ----------------------------N OTE----------------------

Valves and blind flanges in high radiation areas may be verified by use of administrative controls.

Verify each containment isolation manual valve In accordance with and blind flange that is located outside the Surveillance containment and required to be closed during Frequency Control accident conditions is closed, except for Program containment isolation valves that are open under administrative controls.

(continued)

Vogtle Units 1 and 2 3.6.3-4 Amendment No. 158 (U nit 1)

Amendment No, 140 (Unit 2)

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.3.4 -------------------------NaTES---------------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. The fuel transfer tube blind flange is only required to be verified closed once after refueling prior to entering MODE 4 from MODE 5.

Verify each containment isolation manual valve Prior to entering and blind flange that is located inside containment MODE 4 from and required to be closed during accident MODE 5 if not conditions is closed, except for containment performed within the isolation valves that are open under previous 92 days administrative controls.

SR 3.6.3.5 Verify the isolation time of each power operated In accordance and each automatic containment isolation valve is with the Inservice within limits. Testing Program SR 3.6.3.6 Perform leakage rate testing for containment In accordance with purge valves with resilient seals. the Surveillance Frequency Control Program SR 3.6.3.7 Verify each automatic containment isolation valve In accordance with that is not locked, sealed, or otherwise secured in the Surveillance position, actuates to the isolation position on an Frequency Control actual or simulated actuation signal. Program VogUe Units 1 and 2 3.6.3-5 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Containment Pressure 3.6.4 3.6 CONTAINMENT SYSTEMS 3.6.4 Containment Pressure LCO 3.6.4 Containment pressure shall be:::: -0.3 psig and :5 +1.8 psig.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Containment pressure A.1 Restore containment 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months not within limits. pressure to within limits.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1 Verify containment pressure is within limits. In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.6.4-1 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Containment Air Temperature 3.6.5 3.6 CONTAINMENT SYSTEMS 3.6.5 Containment Air Temperature LCO 3.6.5 Containment average air temperature shall be $ 120°F.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Containment average air A.1 Restore containment I B hours temperature not within average air temperature limit. to within limit.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.5.1 Verify containment average air temperature is In accordance with within limit. the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.6.5-1 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS SU RVEILLANC E 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 developed In accordance with head at the flow test point is greater than or equal the Inservice 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. 158 (Unit 1)

Amendment No. 140 (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 Vogtle Units 1 and 2 3.6.6-3 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

ARVs 3.7.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify one complete cycle of each ARV. In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.7.4-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

AFW System 3.7.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1 Verify each AFW manual, power operated, and In accorda nce with automatic valve in each water flow path, and in the Surveillance both steam supply flow paths to the steam turbine Frequency Control driven pump, that is not locked, sealed, or Program otherwise secured in position, is in the correct position.

SR 3.7.5.2 ---------------------------NaTE--------------------

Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after ~ 900 psig in the steam generator.

Verify the developed head of each AFW pump at In accordance with the flow test point is greater than or equal to the the Surveillance required developed head. Frequency Control Program SR 3.7.5.3 Verify each AFW automatic valve that is not In accordance with locked, sealed, or otherwise secured in position the Surveillance actuates to the correct position on an actual or Frequency Control simulated actuation signal. Program SR 3.7.5.4 ------------------------N aTE---------------------------

Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after ~ 900 psig in the steam generator.

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

Vogtle Units 1 and 2 3.7.5-3 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

AFW System 3.7.5 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.5.5 Verify that each AFW pumphouse ESF supply fan In accordance with starts and associated dampers actuate on a the Surveillance simulated or actual actuation signal. Frequency Control Program SR 3.7.5.6 Verify that the ESF outside air intake and exhaust In accordance with dampers for the turbine-driven AFW pump the Surveillance actuate on a simulated or actual actuation signal. Frequency Control Program Vogtle Units 1 and 2 3.7.5-4 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

CST 3.7.6 THIS PAGE APPLICABLE TO UNIT 1 ONLY 3.7 PLANT SYSTEMS 3.7.6 Condensate Storage Tank (CST)

LCO 3.7.6 One CST shall be OPERABLE with a safety-related volume

~ 340,000 gallons.

APPLICABILITY: MODES 1, 2, and 3, ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. CST volume not within A.1 Align Auxiliary Feedwater 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit. pumps to OPERABLE CST.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE4 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.6.1 Verify the CST volume is within limit. In accordance with the Surveillance Frequency Control Program Vogtle Unit 1 3.7.6-1 Amendment No.158 (Unit 1)

CST 3.7.6 THIS PAGE APPLICABLE TO UNIT 2 ONLY 3.7 PLANT SYSTEMS 3.7.6 Condensate Storage Tank (CST)

LCO 3.7.6 Two CSTs shall be OPERABLE with:

a. A combined safety-related volume of ~ 378,000 gallons; and

b. The CST aligned to supply the auxiliary feedwater pumps shall have a safety-related volume ~ 340,000 gallons.

APPLICABILITY: MODES 1, 2, and 3, ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. CST volume(s) not A.1 Restore volume(s) to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months within limit(s). within Iimit(s).

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 4 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.6.1 Verify CST volumes within limits. In accordance with the Surveillance Frequency Control Program Vogtle Unit 2 3.7.6-2 Amendment No. 140 (Unit 2)

CCW System 3.7.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.7.1 ------------------------N0 TE---------------------------

Isolation of CCW flow to individual components does not render the CCW System inoperable.

Verify each CCW manual, power operated, and In accordance with automatic valve in the flow path servicing safety the Surveillance related equipment, that is not locked, sealed, or Frequency Control otherwise secured in position, is in the correct Program position.

SR 3.7.7.2 Verify each CCW pump starts automatically on an In accordance with actual or simulated actuation signal. the Surveillance Frequency Control I Program Vogtle Units 1 and 2 3.7.7-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

NSCW 3.7.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.8.1 ------------~-------------NOT E-----------------------------

Isolation of NSCW system flow to individual components does not render the NSCW system inoperable.

Verify each NSCW system manual, power In accordance with operated, and automatic valve in the flow path the Surveillance servicing safety related equipment, that ;s not Frequency Control locked, sealed, or otherwise secured in position, Program is in the correct position.

SR 3.7.8.2 Verify each NSCW system automatic valve in the In accordance with flow 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.

SR 3.7.8.3 Verify each NSCW system pump starts In accordance with automatically on an actual or simulated actuation the Surveillance signal. Frequency Control Program Vogtle Units 1 and 2 3.7.8-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

UHS 3.7.9 SURVEILLANCE REQUIREMENTS SU RVE ILLANCE FREQUENCY SR 3.7.9.1 Verify water level of NSCW basin is ~ 80.25 ft. In accordance with the Surveillance Frequency Control Program SR 3.7.9.2 Verify water temperature of NSCW basin is In accordance with the

~ 90°F. Surveillance Frequency Control Program SR 3.7.9.3 Operate each required NSCW cooling tower fan In accordance with the for ~ 15 minutes. Surveillance Frequency Control Program SR 3.7.9.4 Verify NSCW basin transfer pump operation. In accordance with the Inservice Testing Program SR 3.7.9.5 Verify ambient wet-bulb temperature ~ 63°F In accordance with the when one NSCW tower fan is out-of-service and Surveillance daily high temperature (dry-bulb) is forecasted to Frequency Control be> 48°F. Program Vogtle Units 1 and 2 3.7.9-3 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

CREFS - Both Units Operating 3.7.10 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Verify control room air temperature ~ 85°F. In accordance with the Surveillance Frequency Control Program SR 3.7.10.2 Operate each CREFS train for ~ 10 continuous In accordance with hours with the heater control circuit energized. the Surveillance Frequency Control Program SR 3.7.10.3 Perform required CREFS filter testing in In accordance with accordance with the Ventilation Filter Testing the VFTP Program (VFTP).

SR 3.7.10.4 Verify each CREFS train actuates (switches to In accordance with emergency mode) on an actual or simulated the Surveillance actuation signal. Frequency Control Program SR 3.7.10.5 Perform required CRE unfiltered air inleakage In accordance with testing in accordance with the Control Room the Control Room Envelope Habitability Program. Envelope Habitability Program Vogtle Units 1 and 2 3.7.10-4 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

PPAFES 3.7.13 3.7 PLANT SYSTEMS 3.7.13 Piping Penetration Area Filtration and Exhaust System (PPAFES)

LCO 3.7.13 Two PPAFES trains shall be OPERABLE.

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

The PPAFES boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One PPAFES train A.1 Restore PPAFES train to 7 days inoperable. OPERABLE status.

B. Two PPAFES trains B.1 Restore PPAFES 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months inoperable due to boundary to OPERABLE inoperable PPAFES status.

boundary.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.13.1 Operate each PPAFES train for ~ 15 minutes. In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.7.13-1 Amendment No. 158 (Unit1)

Amendment No. 140 (Unit 2)

PPAFES 3.7.13 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.13.2 Perform required PPAFES filter testing in In accordance with the accordance with the Ventilation Filter Testing VFTP Program (VFTP).

SR 3.7.13.3 Verify each PPAFES train actuates on an actual In accordance with the or simulated actuation signal. Surveillance Frequency Control Program SR 3.7.13.4 Verify one PPAFES train can maintain a negative In accordance with the pressure ~ 0.250 inches water gauge relative to Surveillance atmospheric pressure during the post accident Frequency Control mode of operation at a flow rate of Program 15,500 cfm +/- 10%.

Vogtle Units 1 and 2 3.7.13-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

ESF Room Cooler and Safety-Related Chiller System 3.7.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.14.1 Verify each ESF room cooler and safety-related In accordance with chiller system manual, power-operated and the Surveillance automatic valve servicing safety-related Frequency Control equipment that is not locked, sealed, or otherwise Program secured in position, is in the correct position.

SR 3.7.14.2 Verify each ESF room cooler and safety-related In accordance with chiller system automatic valve servicing safety the Surveillance related equipment that is not locked, sealed, or Frequency Control otherwise secured in position actuates to the Program correct position on an actual or simulated actuation signal.

SR 3.7.14.3 Verify each ESF room cooler fan and safety In accordance with related chiller system (pump and chiller) start the Surveillance automatically on an actual or simulated actuation Frequency Control signal. Program Vogtle Units 1 and 2 3.7.14-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Fuel Storage Pool Water Level 3.7.15 3.7 PLANT SYSTEMS 3.7.15 Fuel Storage Pool Water Level LCO 3.7.15 The fuel storage pool water level shall be ~ 23 ft over the top of irradiated fuel assemblies seated in the storage racks.

APPLICABILITY: During movement of irradiated fuel assemblies in the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel storage pool water A.1 ---------NOTE------------

level not within limit. LCO 3.0.3 is not applicable.

Suspend movement of Immediately irradiated fuel assemblies in the fuel storage pool.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.15.1 Verify the fuel storage pool water level is ~ 23 ft In accordance with above the top of the irradiated fuel assemblies the Surveillance seated in the storage racks. Frequency Control Program Vogtle Units 1 and 2 3.7.15-1 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Secondary Specific Activity 3.7.16 3.7 PLANT SYSTEMS 3.7.16 Secondary Specific Activity LCO 3.7.16 The specific activity of the secondary coolant shall be :5 0.10 J.!Ci/gm DOSE EQUIVALENT 1-131.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Specific activity not A.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months within limit.

AND A.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.16.1 Verify the specific activity of the secondary In accordance with coolant is:5 0.10 J.!Ci/gm DOSE EQUIVALENT the Surveillance 1-131. I Frequency Control Program Vogtle Units 1 and 2 3.7.16-1 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Fuel Storage Pool Boron Concentration 3.7.17 3.7 PLANT SYSTEMS 3.7.17 Fuel Storage Pool Boron Concentration LCO 3.7.17 The fuel storage pool boron concentration shall be 2: 2000 ppm.

APPLICABILITY: When fuel assemblies are stored in the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION I, COMPLETION TIME A. Fuel storage pool boron ------------------N OTE--------------

concentration not within LCO 3.0.3 is not applicable.

limit.

A.1 Suspend movement of Immediately fuel assemblies in the fuel storage pool.

AND A.2.1 Initiate action to restore Immediately fuel storage pool boron concentration to within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.17.1 Verify the fuel storage pool boron concentration is In accordance with within limit. the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.7.17-1 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated In accordance with power availability for each required offsite circuit. the Surveillance Frequency Control Program SR 3.8.1.2 ---------------------------NOTES-----------------------

1. Performance of SR 3.8.1.7 satisfies this SR.

2. All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

3. A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met.

Verify each DG starts from standby conditions In accordance with and achieves steady state voltage ~ 4025 V and the Surveillance

4330 V, and frequency ~ 58.8 Hz and Frequency Control

61.2 Hz. Program (continued)

Vogtle Units 1 and 2 3.8.1-7 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.3 --------------------------NOTES--------------------------

1. DG loadings may include gradual loading as recommended by the manufacturer.

2. Momentary transients outside the load range do not invalidate this test.

3. This Surveillance shall be conducted on only one DG at a time.

4. This SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2 or SR 3.8.1.7.

Verify each DG is synchronized and loaded and In accordance with operates for ~ 60 minutes at a load ~ 6500 kW the Surveillance and S; 7000 kW. Frequency Control Program SR 3.8.1.4 Verify each day tank contains ~ 650 gal of fuel oil. In accordance with the Surveillance Frequency Control Program SR 3.8.1.5 Check for and remove accumulated water from In accordance with each day tank. the Surveillance Frequency Control Program SR 3.8.1.6 Verify the fuel oil transfer system operates to In accordance with automatically transfer fuel oil from storage tanks the Surveillance to the day tank. Frequency Control Program (continued)

Vogtle Units 1 and 2 3.8.1-8 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.7 --------------------------NOTE-----------------------

All DG starts may be preceded by an engine prelube period.

Verify each DG starts from standby condition and In accordance with achieves in $; 11.4 seconds, voltage;?: 4025 V and the Surveillance

$; 4330 V, and frequency;?: 58.8 Hz and Frequency Control

$; 61.2 Hz. Program SR 3.8.1.8 -----------------------NOTE--------------------------

Credit may be taken for unplanned events that satisfy this SR.

Verify each DG rejects a load;?: its associated In accordance with single largest post accident load, and: the Surveillance Frequency Control

a. Following load rejection, the frequency is Program

$; 64.5 Hz;

b. Within 3 seconds following load rejection, the voltage is ;?: 3750 V and $; 4330 Vor

$; 4550 V when performing the test synchronized with offsite power; and

c. Within 3 seconds following load rejection.

the frequency is ;?: 58.8 Hz and $; 61.2 Hz.

(continued)

Vogtle Units 1 and 2 3.8.1-9 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

AC Sources - Operating 3.8.1 SURVEILLANCE FREQUENCY SR 3.8.1.9 -------------------------N 0 TE--------------------------

Credit may be taken for unplanned events that satisfy this SR.

Verify each DG operating as close as practicable In accordance with to 3390 kVAR while maintaining voltage $ 4330 V the Surveillance does not trip and voltage is maintained $ 5000 V Frequency Control during and following a load rejection of ~ 6500 kW Program and $ 7000 kW.

(continued)

Vogtle Units 1 and 2 3.8.1-10 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

AC Sources - Operating 3.8.1 SURVEILLANCE FREQUENCY SR 3.8.1.10 ---------------------------NOTES-------------------------

1. All DG starts may be preceded by an engine prelube period.

2. This Surveillance shall not be performed in MODE 1, 2, 3, or 4. However, credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated loss of offsite In accordance with power signal: the Surveillance Frequency Control

a. De-energization of emergency buses; Program

b. Load shedding from emergency buses;

c. DG auto-starts from standby condition and:

1. energizes permanently connected loads in ::; 11.5 seconds,

2. energizes auto-connected shutdown loads through automatic load sequencer,

3. maintains steady state voltage

~ 3750 V and::; 4330 V,

4. maintains steady state frequency

~ 58.8 Hz and ~ 61.2 Hz, and

5. supplies permanently connected and auto-connected shutdown loads for

~ 5 minutes.

(continued)

Vogtle Units 1 and 2 3.8.1-11 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

AC Sources - Operating 3.8.1 SURVEILLANCE FREQUENCY SR 3.8.1.11 ---------------------------NOTES-------------------------

1. All DG starts may be preceded by an engine prelube period.

2. This Surveillance shall not be performed in MODE 1 or 2. However, credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated Engineered In accordance with Safety Feature (ESF) actuation signal each DG the Surveillance auto-starts from standby condition and: Frequency Control Program

a. In ~ 11.4 seconds after auto-start and during tests, achieves voltage ~ 3750 V and

~ 4330 V;

b. In ~ 11.4 seconds after auto-start and during tests, achieves frequency ~ 58.8 Hz and ~ 61.2 Hz;

c. Operates for ~ 5 minutes;

d. Permanently connected loads remain energized from the offsite power system; and

e. Emergency loads are energized or auto connected through the automatic load sequencer from the offsite power system.

(continued)

Vogtle Units 1 and 2 3.8.1-12 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

AC Sources - Operating 3.8.1 SURVEILLANCE FREQUENCY SR 3.8.1.12 -----------------------------NOTE-------------------------

This Surveillance shall not be performed in MODE 1 or 2. However, credit may be taken for unplanned events that satisfy this SR.

Verify each DG's automatic trips are bypassed on In accordance with actual or simulated loss of voltage signal on the the Surveillance emergency bus concurrent with an actual or Frequency Control simulated ESF actuation signal except: Program

a. Engine overspeed;

b. Generator differential current; and

c. Low lube oil pressure; SR 3.8.1.13 -----------------------NOTES------------------

1. Momentary transients outside the kW and kVAR load ranges do not invalidate this test.

2. Credit may be taken for unplanned events that satisfy this SR.

Verify each DG operates for ~ 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months while In accordance with maintaining voltage ~ 4330 V: the Surveillance Frequency Control

a. For ~ 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded ~ 6900 kWand Program

~ 7700 kW and operating as close as practicable to 3390 kVAR; and

b. For the remaining hours of the test loaded 2: 6500 kW and ~ 7000 kW and operating as close as practicable to 3390 kVAR.

(continued)

Vogtle Units 1 and 2 3.8.1-13 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.14 ---------------------------N OTES-------------------------

1. This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated ~ 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded

~ 6500 kW and:5 7000 kW.

Momentary transients outside of load range do not invalidate this test.

2. All DG starts may be preceded by an engine prelube period.

Verify each DG starts and achieves, in In accordance with

5 11.4 seconds, voltage ~ 4025 V, and :5 4330 V the Surveillance and frequency ~ 58.8 Hz and :5 61.2 Hz. Frequency Control Program SR 3.8.1.15 ---------------------N0 TE--------------------------

This Surveillance shall not be performed in MODE 1, 2, 3, or 4. However, credit may be taken for unplanned events that satisfy this SR.

Verify each DG: In accordance with the Surveillance

a. Synchronizes with offsite power source Frequency Control while loaded with emergency loads upon a Program simulated restoration of offsite power;

b. Transfers loads to offsite power source; and

c. Returns to ready-to-Ioad operation.

(continued)

Vogtle Units 1 and 2 3.8.1-14 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

AC Sources - Operating 3.8.1 SURVEILLANCE FREQUENCY SR 3.8.1.16 --------------------------N OT E-------------------------

This Surveillance shall not be performed in MODE 1, 2, 3, or 4. However, credit may be taken for unplanned events that satisfy this SR.

Verify, with a DG operating in test mode and In accordance with connected to its bus, an actual or simulated ESF the Surveillance actuation signal overrides the test mode by: Frequency Control Program

a. Returning DG to ready-to-Ioad operation; and

b. Automatically energizing the emergency load from offsite power.

SR 3.8.1.17 ---------------------NOTE----------------------

This Surveillance shall not be performed in MODE 1, 2, 3, or 4. However, credit may be taken for unplanned events that satisfy this SR.

Verify interval between each sequenced load In accordance with block is within +/- 10% of design interval for each the Surveillance load sequencer. Frequency Control Program (continued)

Vogtle Units 1 and 2 3.8.1-15 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

AC Sources - Operating 3.8.1 SURVEILLANCE FREQUENCY SR 3.8.1.18 ---------------------------N OTES------------------------

1. All DG starts may be preceded by an engine prelube period.

2. This Surveillance shall not be perfonned in MODE 1, 2, 3, or 4. However, credit may be taken for unplanned events that satisfy this SR.

Verify on an actual or simulated loss of offsite In accordance with power signal in conjunction with an actual or the Surveillance simulated ESF actuation signal: Frequency Control Program

a. De-energization of emergency buses;

b. Load shedding from emergency buses; and

c. DG auto-starts from standby condition and:

1. energizes permanently connected loads in s 11.5 seconds,

2. energizes auto-connected emergency loads through load sequencer,

3. achieves steady state voltage:

~ 3750 V and s 4330 V,

4. achieves steady state frequency:

58.8 Hz and s 61.2 Hz, and

5. supplies permanently connected and auto-connected emergency loads for

~ 5 minutes.

(continued)

Vogtle Units 1 and 2 3.8.1-16 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.19 Verify fuel transfer pump transfers fuel from each In accordance with the fuel storage tank to the day tank of each diesel Surveillance via the installed cross-connection lines. Frequency Control Program SR 3.8.1.20 ----------------------------N0 TE----------------------

All DG starts may be preceded by an engine prelube period.

Verify when started simultaneously from standby In accordance with the condition, each DG achieves, in ~ 11.4 seconds. Surveillance voltage ~ 4025 V and ~ 4330 V. and frequency Frequency Control

~ 58.8 Hz and ~ 61.2 Hz. Program Vogtle Units 1 and 2 3.8.1-17 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Diesel Fuel Oil, Lube Oil, Starting Air, and Ventilation 3.8.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify each fuel oil storage tank contains In accordance with

~ 68,000 gal of fuel. the Surveillance Frequency Control Program SR 3.8.3.2 Verify lube oil inventory is ~ 336 gal. In accordance with the Surveillance Frequency Control Program SR 3.8.3.3 Verify fuel oil properties of new and stored fuel oil In accordance with are tested in accordance with, and maintained the Diesel Fuel Oil within the limits of, the Diesel Fuel Oil Testing Testing Program Program.

SR 3.8.3.4 Verify each DG has one air start receiver with a In accordance with pressure ~ 210 psig. the Surveillance Frequency Control Program SR 3.8.3.5 Check for and remove accumulated water from In accordance with each fuel oil storage tank. the Surveillance Frequency Control Program SR 3.8.3.6 Verify each DG ventilation supply fan starts and In accordance with the necessary dampers actuate on a simulated or the Surveillance actual actuation signal. Frequency Control

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _I_p_r_og_r_a_m _

(continued)

Vogtle Units 1 and 2 3.8.3-3 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Diesel Fuel Oil, Lube Oil, Starting Air, and Ventilation 3.8.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.3.7 ------------------------NOTE-----------------------------

Not required to be performed when DG is required OPERABLE in accordance with Specification 3.8.2.

For each fuel oil storage tank: In accordance with the Surveillance

a. Drain the fuel oil; Frequency Control Program

b. Remove the sediment; and

c. Clean the tank.

Vogtle Units 1 and 2 3.8.3-4 Amendment No. 158(Unit 1)

Amendment No. 140(Unit 2)

DC Sources - Operating 3.8.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One DC electrical power C.1 Restore DC electrical 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months source inoperable for power source to reasons other than OPERABLE status.

Condition A or B.

D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Associated Completion Time not met. I AND D.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is greater than or In accordance with equal to the minimum established float voltage. the Surveillance Frequency Control Program SR 3.8.4.2 Verify the battery charger supplies: In accordance with

400 amps for System A and B the Surveillance

300 amps for System C, and Frequency Control

200 amps for System D Program at greater than or equal to the minimum established float voltage for;

: 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for Systems A and Band;:: 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months for Systems C and D.

Verify each battery charger can recharge the battery to the fUlly charged state within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state.

(continued)

Vogtle Units 1 and 2 3.8.4-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

DC Sources - Operating 3.8.4 SURVEILLANCE FREQUENCY SR 3.8.4.3 -------------------------N0 TES-------------------------

1. The modified performance discharge test in SR 3.8.6.6 may be performed in lieu of the service test in SR 3.8.4.3.

2. This Surveillance shall not be performed in MODE 1, 2, 3, or 4. However, credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is adequate to supply, and In accordance with maintain in OPERABLE status, the required the Surveillance emergency loads for the design duty cycle when Frequency Control subjected to a battery service test. Program Vogtle Units 1 and 2 3.8.4-3 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Battery Parameters 3.8.6 ACTIONS SURVEILLANCE FREQUENCY F. (continued)

One battery with one or more battery cells float voltage < 2.07 V and float current> 2 amps for systems A or B batteries, or > 1 amp for system Cor D.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.6.1 -----------------------NOTE-----------------------

Not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1.

Verify each system A and B battery float current is In accordance with

s; 2 amps. Verify each system C and D battery float the Surveillance current is :s; 1 amp. Frequency Control Program SR 3.8.6.2 Verify each battery pilot cell voltage is ~ 2.07 V. In accordance with the Surveillance Frequency Control Program SR 3.8.6.3 Verify each battery connected cell electrolyte level is In accordance with greater than or equal to minimum established design the Surveillance limits. Frequency Control Program (continued)

Vogtle Units 1 and 2 3.8.6-3 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Battery Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.6.4 Verify each battery pilot cell temperature is greater In accordance with than or equal to minimum established design limits. the Surveillance Frequency Control Program SR 3.8.6.5 Verify each battery connected cell voltage is ~ 2.07 V. In accordance with the Surveillance Frequency Control Program SR 3.8.6.6 -----------------------NaTE------------------------------

This Survelliance shall not be performed in MODE 1, 2, 3. or 4. However, credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is ~ 80% of the manufacturer's In accordance with rating when subjected to a performance discharge test the Surveillance or a modified performance discharge test. Frequency Control Program 12 months when battery shows degradation or has reached 85% of expected life with capacity < 100% of manufacturer's rating 24 months when battery has reached 85% of the expected life with capacity

~ 100% of manufacturer's rating Vogtle Units 1 and 2 3.8.6-4 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Inverters - Operating 3.8.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct inverter voltage and alignment to In accordance with required AC vital buses. the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.8.7-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Inverters - Shutdown 3.8.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct inverter voltage and alignments to In accordance with required AC vital buses. the Surveillance Frequency Control Program VogUe Units 1 and 2 3.8.8-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Distribution Systems - Operating 3.8.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more DC C.1 Restore DC electrical 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months electrical power power distribution distribution sUbsystems subsystems to AND inoperable. OPERABLE status.

16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND D.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months E. Two or more electrical E.1 Enter LCO 3.0.3. Immediately power distribution sUbsystems inoperable that result in a loss of function.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.9.1 Verify correct breaker alignments and voltage to In accordance with required AC, DC, and AC vital bus electrical power the Surveillance distribution sUbsystems. Frequency Control Program Vogtle Units 1 and 2 3.8.9-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Distribution Systems - Shutdown 3.8.10 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.4 Initiate actions to restore Immediately required AC, DC, and AC vital bus electrical power distribution subsystems to OPERABLE status.

A.2.5 Declare associated Immediately required residual heat removal subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.10.1 Verify correct breaker alignments and voltage to In accordance with required AC, DC, and AC vital bus electrical power the Surveillance distribution subsystems. Frequency Control Program Vogtle Units 1 and 2 3.8.10-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Boron Concentration 3.9.1 3.9 REFUELING OPERATIONS 3.9.1 Boron Concentration LCO 3.9.1 Boron concentrations of the Reactor Coolant System, the refueling canal, and the refueling cavity shall be maintained within the limit specified in the COLR.

APPLICABILITY: MODE 6.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Boron concentration not A.1 Suspend CORE Immediately within limit. ALTERATIONS.

AND A.2 Suspend positive Immediately reactivity additions.

AND A.3 Initiate action to restore Immediately boron concentration to within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.1.1 Verify boron concentration is within the limit In accordance with specified in the COLR. the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.9.1-1 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Unborated Water Source Isolation Valves 3.9.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.2.1 Verify each valve that isolates unborated water In accordance with sources is secured in the closed position. the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.9.2-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Nuclear Instrumentation 3.9.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.3.1 Perform CHANNEL CHECK. In accordance with the Surveillance

, Frequency Control Program SR 3.9.3.2 ----------------------N0 TE----------------------.--

Neutron detectors are excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION. In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.9.3-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Containment Penetrations 3.9.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.4.1 Verify each required containment penetration is In accordance with the in the required status. Surveillance Frequency Control Program SR 3.9.4.2 --------------------N OTE------------------------

Only required for unisolated penetrations.

Verify at least two containment ventilation valves In accordance with the in each open containment ventilation penetration Surveillance providing direct access from the containment Frequency Control atmosphere to the outside atmosphere are Program capable of being closed from the control room.

SR 3.9.4.3 -------------------NOTE-------------------

Only required for an open equipment hatch.

Verify the capability to install the equipment In accordance with the Surveillance hatch.

Frequency Control Program Vogtle Units 1 and 2 3.9.4-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

RHR and Coolant Circulation - High Water Level 3.9.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) AA 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 Vogtle Units 1 and 2 3.9.5-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

RHR and Coolant Circulation - Low Water Level 3.9.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.2 Initiate action to restore Immediately one RHR loop to operation.

AND B.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 Vogtle Units 1 and 2 3.9.6-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Refueling Cavity Water Level 3.9.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.7.1 Verify refueling cavity water level is 2= 23 ft above In accordance with the top of reactor vessel flange. the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.9.7-2 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

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

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

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

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

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

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

Vogtle Units 1 and 2 5.5-20 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 158 TO FACILITY OPERATING LICENSE NPF-68 AND AMENDMENT NO. 140 TO FACILITY OPERATING LICENSE NPF-81 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-424 AND 50-425

1.0 INTRODUCTION

By letter dated June 15, 2010 (Reference 9), as supplemented January 7, 2011 (Reference 10),

Southern Nuclear Operating Company, Inc. (SNC, the licensee) proposed changes to the Technical Specifications (TSs) for Vogtle Electric Generating Plant (VEGP) Units 1 and 2. The supplement dated January 7,2011, provided page numbering clarifications, did not expand the scope of the application as originally noticed, and did not change the staff's original proposed no significant hazards consideration determination as published in the Federal Register on August 24, 2010 (75 FR 52042).

The requested change is the adoption of the Nuclear Regulatory Commission (NRC) approved Technical Specification Task Force (TSTF-425), Revision 3, "Relocate Surveillance Frequencies to Licensee Control-RITSTF Initiative 5b" (Reference 1). When implemented, TSTF-425 relocates most periodic frequencies of TS surveillances to a licensee controlled program, the Surveillance Frequency Control Program (SFCP), and provides requirements for the new program in the Administrative Controls section of the TS. All surveillance frequencies can be relocated except:

Frequencies that reference other approved programs for the specific interval (such as the In-Service Testing Program or the Primary Containment Leakage Rate Testing Program);

Frequencies that are purely event-driven (e.g., "each time the control rod is withdrawn to the 'full out' position");

Frequencies that are event-driven, but have a time component for performing the surveillance on a one-time basis once the event occurs (e.g., "within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after thermal power reaching ~ 95% Rated Thermal Power); and

-2 Frequencies that are related to specific conditions (e.g., battery degradation, age and capacity) or conditions for the performance of a surveillance requirement (e.g.,

"drywell to suppression chamber differential pressure decrease").

A new program is added to the Administrative Controls of TS Section 5 as Specification 5.5.21.

The new program is called the SFCP and describes the requirements for the program to control changes to the relocated surveillance frequencies. The TS Bases for each of the affected surveillance requirements are revised to state that the frequency is controlled in the SFCP. Some surveillance requirements Bases do not contain a discussion of the frequency. In these cases, the Bases describing the current frequency were added to maintain consistency with the Bases for similar surveillances. These instances are noted in the markup along with the source of the text.

The proposed licensee changes to the Administrative Controls of the TS to incorporate the SFCP include a specific reference to Nuclear Energy Institute (NEI) 04-10, "Risk-Informed Technical Specifications Initiative 5B, Risk-Informed Method for Control of Surveillance Frequencies,"

Revision 1 (Reference 2) as the basis for making any changes to the surveillance frequencies once they are relocated out of the TS.

In a letter dated September 19, 2007, the NRC staff approved NEI 04-10, Revision 1, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072570267), as acceptable for referencing in licensing actions to the extent specified and under the limitations delineated in NEI 04-10, and the safety evaluation providing the basis for NRC acceptance of NEI 04-10.

2.0 REGULATORY EVALUATION

In the "Final Policy Statement Technical Specifications for Nuclear Power Plants" published in the Federal Register (FR) (58 FR 39132, July 22, 1993), the NRC addressed the use of Probabilistic Safety Analysis (PSA, currently referred to as Probabilistic Risk Assessment or PRA) in Standard Technical Specifications. In discussing the use of PSA in Nuclear Power Plant Technical Specifications, the Commission wrote in part:

The Commission believes that it would be inappropriate at this time to allow requirements which meet one or more of the first three criteria to be deleted from technical specifications based solely on PSA (Criterion 4). However, if the results of PSA indicate that technical specifications can be relaxed or removed, a deterministic review will be performed .....

The Commission Policy in this regard is consistent with its Policy Statement on "Safety Goals for the operation of Nuclear Power Plants", 51 FR 30028, published on August 21, 1986. The Policy Statement on Safety Goals states in part, "***

probabilistic results should also be reasonably balanced and supported through use of deterministic arguments. In this way, judgments can be made *** about the degree of confidence to be given these [probabilistic] (Note: bracketed addition was made in the original document) estimates and assumptions. This is a key part of the process for determining the degree of regulatory conservatism that may be warranted for particular decisions. This defense-in-depth approach is expected to continue to ensure the protection of public health and safety." ....

-3 The Commission will continue to use PSA, consistent with its policy on Safety Goals, as a tool in evaluating specific line item improvements to Technical Specifications, new requirements, and industry proposals for risk-based Technical Specification change.

Approximately 2 years later, the NRC provided additional detail concerning the use of PRA in the "Final Policy Statement: Use of Probabilistic Risk Assessment in Nuclear Regulatory Activities" published in the Federal Register (60 FR 42622, August 16, 1995). The Commission, in discussing the deterministic and probabilistic approach to regulation, and the Commission's extension and enhancement of traditional regulation, wrote in part:

PRA addresses a broad spectrum of initiating events by assessing the event frequency. Mitigating system reliability is then assessed, including the potential for multiple and common cause failures. The treatment therefore goes beyond the single failure requirements in the deterministic approach. The probabilistic approach to regulation is, therefore, considered an extension and enhancement of traditional regulation by considering risk in a more coherent and complete manner.

The Commission provided its new policy, stating:

Although PRA methods and information have thus far been used successfully in nuclear regulatory activities, there have been concerns that PRA methods are not consistently applied throughout the agency, that sufficient agency PRAlstatistics expertise is not available, and that the Commission is not deriving full benefit from the large agency and industry investment in the developed risk assessment methods. Therefore, the Commission believes that an overall policy on the use of PRA in nuclear regulatory activities should be established so that the many potential applications of PRA can be implemented in a consistent and predictable manner that promotes regulatory stability and efficiency. This policy statement sets forth the Commission's intention to encourage the use of PRA and to expand the scope of PRA applications in all nuclear regulatory matters to the extent supported by the state-of-the-art in terms of methods and data. Implementation of the policy statement will improve the regulatory process in three areas: Foremost, through safety decision making enhanced by the use of PRA insights; through more efficient use of agency resources; and through a reduction in unnecessary burdens on licensees.

Therefore, the Commission adopts the follOWing policy statement regarding the expanded NRC use of PRA:

(1) The use of PRA technology should be increased in all regulatory matters to the extent supported by the state-of-the-art in PRA methods and data and in a manner that complements the NRC's deterministic approach and supports the NRC's traditional defense-in-depth philosophy.

(2) PRA and associated analyses (e.g., sensitivity studies, uncertainty analyses, and importance measures) should be used in regulatory matters, where practical within the bounds of the state-of-the-art, to reduce unnecessary conservatism associated with current regulatory requirements, regulatory guides, license

-4 commitments, and staff practices. Where appropriate, PRA should be used to support the proposal for additional regulatory requirements in accordance with 10 CFR 50.109 (Backfit Rule). Appropriate procedures for including PRA in the process for changing regulatory requirements should be developed and followed.

It is, of course, understood that the intent of this policy is that existing rules and regulations shall be complied with unless these rules and regulations are revised.

(3) PRA evaluations in support of regulatory decisions should be as realistic as practicable and appropriate supporting data should be publicly available for review.

(4) The Commission's safety goals for nuclear power plants and subsidiary numerical objectives are to be used with appropriate consideration of uncertainties in making regulatory judgments on the need for proposing and backfitting new generic requirements on nuclear power plant licensees.

In Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, the NRC established its regulatory requirements related to the content of TS. Pursuant to 10 CFR 50.36, TS are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls.

As stated in 10 CFR 50.36(c)(3), "Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." These categories will remain in TS. The new TS SFCP provides the necessary administrative controls to require that surveillances relocated to the SFCP are conducted at a frequency to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. Changes to surveillance frequencies in the SFCP are made using the methodology contained in NEI 04-10, including qualitative considerations, results of risk analyses, sensitivity studies and any bounding analyses, and recommended monitoring of structures, systems, and components (SSCs), and required to be documented. Furthermore, changes to frequencies are subject to regulatory review and oversight of the SFCP implementation through the rigorous NRC review of safety-related SSC performance provided by the reactor oversight program.

Licensees are required by TSs to perform surveillance test, calibration, or inspection on specific safety-related system equipment (e.g., reactivity control, power distribution, electrical, and instrumentation) to verify system operability. Surveillance frequencies, currently identified in TSs, are based primarily upon deterministic methods such as engineering judgment, operating experience, and manufacturer's recommendations. The licensee's use of NRC-approved methodologies identified in NEI 04-10 provides a way to establish risk-informed surveillance frequencies that complement the deterministic approach and support the NRC's traditional defense-in-depth philosophy.

The licensee's SFCP ensures that surveillance requirements specified in the TS are performed at intervals sufficient to assure the above regulatory requirements are met. Existing regulatory requirements, such as 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," and 10 CFR 50, Appendix B (corrective action program),

-5 require licensee monitoring of surveillance test failures and implementing corrective actions to address such failures. One of these actions may be to consider increasing the frequency at which a surveillance test is performed. In addition, the SFCP implementation guidance in NEI 04-10 requires monitoring the performance of SSCs for which surveillance frequencies are decreased to assure reduced testing does not adversely impact the SSCs. These requirements, and the monitoring required by NEI 04-10, ensure that surveillance frequencies are sufficient to assure that the requirements of 10 CFR 50.36 are satisfied and that any performance deficiencies will be identified and appropriate corrective actions taken.

Regulatory Guide (RG) 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk- Informed Decisions on Plant-Specific Changes to the Licensing Basis," (Reference 5),

describes a risk-informed approach, acceptable to the NRC, for assessing the nature and impact of proposed permanent licensing-basis changes by considering engineering issues and applying risk insights. This regulatory guide also provides risk acceptance guidelines for evaluating the results of such evaluations.

In RG 1.177, "An Approach for Plant-Specific, Risk-Informed Decision making: Technical Specifications," (Reference 3), it describes an acceptable risk-informed approach specifically for assessing proposed permanent TS changes.

In RG 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," (Reference 4), it describes an acceptable approach for determining whether the quality of the PRA, in total or the parts that are used to support an application, is sufficient to provide confidence in the results, such that the PRA can be used in regulatory decision making for light water-reactors.

3.0 TECHNICAL EVALUATION

The licensee's adoption of TSTF-425 for VEGP provides for administrative relocation of applicable surveillance frequencies, and provides for the addition of the SFCP to the administrative controls of TS. TSTF-425 also requires the application of NEI 04-10 for any changes to surveillance frequencies within the SFCP. The licensee's application for the changes proposed in TSTF-425 included documentation regarding the PRA technical adequacy consistent with the requirements of RG 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," Revision 1 (Reference 4). In accordance with NEI 04-10 PRA methods are used, in combination with plant performance data and other considerations, to identify and justify modifications to the surveillance frequencies of equipment at nuclear power plants. This is in accordance with guidance provided in RG 1.174 (Reference 5) and RG 1.177 (Reference 6) in support of changes to surveillance test intervals.

3.1 RG 1.177 - Five Key Safety Principles In RG 1.177, it identifies five key safety principles required for risk-informed changes to TS. Each of these principles is addressed by the industry methodology document, NEI 04-10.

3.1.1 The Proposed Change Meets Current Regulations In 10 CFR 50.36(c)(3), it provides that TSs will include surveillances which are "requirements relating to test, calibration, or inspection to assure that necessary quality of systems and

-6 components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." NEI 04-10 provides guidance for relocating the surveillance frequencies from the TSs to a licensee-controlled program by providing an NRC-approved methodology for control of the surveillance frequencies. The surveillances themselves would remain in the TSs, as required by 10 CFR 50.36(c)(~).

This change is consistent with other NRC-approved TS changes in which the surveillance frequencies are relocated to licensee-controlled documents, such as surveillances performed in accordance with the In-service Testing Program or the Primary Containment Leakage Rate Testing Program. Thus, this proposed change meets the first key safety principle of RG 1.177 by complying with current regulations.

3.1.2 Proposed Change Is Consistent With the Defense-in-Depth Philosophy Consistency with the defense-in-depth philosophy, the second key safety principle of RG 1.177, is maintained if:

A reasonable balance is preserved among prevention of core damage, prevention of containment failure, and consequence mitigation.

Over-reliance on programmatic activities to compensate for weaknesses in plant design is avoided.

System redundancy, independence, and diversity are preserved commensurate with the expected frequency, consequences of challenges to the system, and uncertainties (e.g.,

no risk outliers). Because the scope of the proposed methodology is limited to revision of surveillance frequencies, the redundancy, independence, and diversity of plant systems are not impacted.

Defenses against potential common cause failures are preserved, and the potential for the introduction of new common cause failure mechanisms is assessed.

Independence of barriers is not degraded.

Defenses against human errors are preserved.

The intent of the General Design Criteria in 10 CFR Part 50, Appendix A, is maintained.

In TSTF-425, it requires the application of NEI 04-10 for any changes to surveillance frequencies within the SFCP. NEI 04-10 uses both the core damage frequency (CDF) and the large early release frequency (LERF) metrics to evaluate the impact of proposed changes to surveillance frequencies. The guidance of RG 1.174 and RG 1.177 for changes to CDF and LERF is achieved by evaluation using a comprehensive risk analysis, which assesses the impact of proposed changes including contributions from human errors and common cause failures.

Defense-in-depth is also included in the methodology explicitly as a qualitative consideration outside of the risk analysis, as is the potential impact on detection of component degradation that could lead to an increased likelihood of common cause failures. Both the quantitative risk analysis and the qualitative considerations assure a reasonable balance of defense-in-depth is maintained to ensure protection of public health and safety, satisfying the second key safety principle of RG 1.177.

-7 3.1.3 Proposed Change Maintains Sufficient Safety Margins The engineering evaluation that will be conducted by the licensee under the SFCP when frequencies are revised will assess the impact of the proposed frequency change with the principle that sufficient safety margins are maintained. The guidelines used for making that assessment will include ensuring the proposed surveillance test frequency change is not in conflict with approved industry codes and standards or adversely affects any assumptions or inputs to the safety analysis, or, if such inputs are affected, justification is provided to ensure sufficient safety margin will continue to exist.

The design, operation, testing methods, and acceptance criteria for SSCs, specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the plant licensing basis (including the Updated Final Safety Analysis Report and bases to TS), since these are not affected by changes to the surveillance frequencies. Similarly, there is no impact to safety analysis acceptance criteria as described in the plant licensing basis.

Thus, safety margins are maintained by the proposed methodology, and the third key safety principle of RG 1.177 is satisfied.

3.1.4 When Proposed Changes Result in an Increase in Core Damage Frequency or Risk, the Increases Should Be Small and Consistent With the Intent of the Commission's Safety Goal Policy Statement In RG 1.177, it provides a framework for evaluating the risk impact of proposed changes to surveillance frequencies. This requires the identification of the risk contribution from impacted surveillances, determination of the risk impact from the change to the proposed surveillance frequency, and performance of sensitivity and uncertainty evaluations. The TSTF-425 requires application of NEI 04-10 in the SFCP. The NEI 04-10 satisfies the intent of RG 1.177 requirements for evaluating the change in risk, and for assuring that such changes are small.

3.1.4.1 Quality of the PRA The quality of the VEGP PRA is compatible with the safety implications of the proposed TS change and the role the PRA plays in justifying the change. That is, the more the potential change in risk or the greater the uncertainty in that risk from the requested TS change, or both, the more rigor that must go into ensuring the quality of the PRA.

The licensee used RG 1.200 to address the technical adequacy of the VEGP PRA. The RG 1.200 is NRC's developed regulatory guidance, which in Revision 1, endorsed with comments and qualifications the use of the American Society of Mechanical Engineers (ASME) RA-Sb-2005, "Addenda to ASME RA-S-2002 Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications," (Reference 6), NEI 00-02, "PRA Peer Review Process Guidelines,"

(Reference 7) and NEI 05-04, "Process for Performing Follow-On PRA Peer Reviews Using the ASME PRA Standard" (Reference 8). The licensee has performed an assessment of the PRA models used to support the SFCP against the requirements of RG 1.200 to assure that the PRA models are capable of determining the change in risk due to changes to surveillance frequencies of SSCs, using plant-specific data and models. Capability category II of ASME RA-Sb-2005 was applied as the standard, and any identified deficiencies to those requirements are assessed further to determine any impacts to proposed decreases to surveillance frequencies, including by

-8 the use of sensitivity studies where appropriate. (The NRC staff notes that in Revision 2, the RG 1.200 endorsed, with comments and qualifications, an updated combined standard which includes requirements for fire, seismic, and other external events PRA models. The existing internal events standard was subsumed into the combined standard, but the technical requirements are essentially unchanged. Since NEI 04-10, Revision 1, specifically identified the use of RG 1.200, Revision 1, to assess the internal events standard, the licensee's approach is reasonable and consistent with the approved methodology.)

The licensee identified that there are no open significant facts and observations remaining from its 2001 Industry PRA Peer Review. In May 2009, a peer review of the VEGP internal events PRA model was conducted using the ASME PRA Standard (Reference 6), which identified a three supporting requirements which were not met at capability category II. The staff reviewed the licensee's assessment of these identified deficiencies (Table 2 of Enclosure 2 of the license amendment request). The licensee's disposition of these items identified additional analyses or reviews which were completed to resolve the issue.

HR-G6-01: A check for consistency and reasonableness of human error probabilities was not up-to-date with the existing analyses. The licensee identified that these checks have been completed, and appropriate model changes made to close out this finding.

QU-D3-01: A comparison of the VEGP results with similar facilities has not been completed. The licensee identified that a new study was completed to compare VEGP results with two other similar pressurized water reactor PRAs, which demonstrated consistency of the dominant contributors.

Some differences in results were further evaluated and found to be due to differences in plant design and configuration or due to the use of more recent industry data for VEGP.

LE-G5-01: Limitations of the LERF analysis are not documented. The licensee performed additional review of its LERF model scope and methods in order to identify limitations, and stated that its model included more potential LERF scenarios than required for a dry containment design, and that this deficiency is considered resolved.

Based on the licensee's assessment using the applicable PRA standard and RG 1.200, the level of PRA quality, combined with the resolution of the three identified deficiencies, is sufficient to support the evaluation of changes proposed to surveillance frequencies within the SFCP, and is consistent with regulatory position 2.3.1 of RG 1.177.

3.1.4.2 Scope of the PRA The licensee is required to evaluate each proposed change to a relocated surveillance frequency using the guidance contained in NEI 04-10 to determine its potential impact on risk, due to impacts from internal events, fires, seismic, other external events, and from shutdown conditions.

Consideration is made of both CDF and LERF metrics. In cases where a PRA of sufficient scope or where quantitative risk models were unavailable, the licensee uses bounding analyses, or other conservative quantitative evaluations. A qualitative screening analysis may be used when the surveillance frequency impact on plant risk is shown to be negligible or zero.

The licensee has does not maintain a fire PRA model, but uses an existing fire PRA, which was completed for the Individual Plant Examination of External Events (IPEEE). Similarly, the IPEEE seismic margins analysis will be used to provide seismic insights. Other external hazards were

-9 assessed as insignificant during the IPEEE assessment. Therefore, the risk contribution from these sources will be assessed either qualitatively or by bounding analyses for evaluation of surveillance frequency changes.

The licensee's evaluation methodology is sufficient to ensure the scope of the risk contribution of each surveillance frequency change is properly identified for evaluation, and is consistent with regulatory position 2.3.2 of RG 1.177.

3.1.4.3 PRA Modeling The licensee will determine whether the SSCs affected by a proposed change to a surveillance frequency are modeled in the PRA. Where the SSC is directly or implicitly modeled, a quantitative evaluation of the risk impact may be carried out. The methodology adjusts the failure probability of the impacted SSCs, including any impacted common cause failure modes, based on the proposed change to the surveillance frequency. Where the SSC is not modeled in the PRA, bounding analyses are performed to characterize the impact of the proposed change to the surveillance frequency. Potential impacts on the risk analyses due to screening criteria and truncation levels are addressed by the requirements for PRA technical adequacy consistent with guidance contained in RG 1.200, and by sensitivity studies identified in NEI 04-10.

The licensee will perform quantitative evaluations of the impact of selected testing strategy (Le.,

staggered testing or sequential testing) consistently with the guidance of NUREG/CR-6141, "Handbook of Methods for Risk-Based Analyses of Technical Specifications," 1995 and NUREG/CR-5497, "Common-Cause Failure Parameter Estimations," October 1998, as discussed in NEI 04-10.

Thus, through the application of NEI 04-10 the VEGP PRA modeling is sufficient to ensure an acceptable evaluation of risk for the proposed changes in surveillance frequency, and is consistent with regulatory position 2.3.3 of RG 1.177.

3.1.4.4 Assumptions for Time Related Failure Contributions The failure probabilities of SSCs modeled in the VEGP PRA include a standby time-related contribution and a cyclic demand-related contribution. The NEI 04-10 criteria adjust the time-related failure contribution of SSCs affected by the proposed change to surveillance frequency. This is consistent with RG 1.177 Section 2.3.3 which permits separation of the failure rate contributions into demand and standby for evaluation of surveillance requirements. If the available data do not support distinguishing between the time-related failures and demand failures, then the change to surveillance frequency is conservatively assumed to impact the total failure probability of the SSC, including both standby and demand contributions. The SSC failure rate (per unit time) is assumed to be unaffected by the change in test frequency, and will be confirmed by the required monitoring and feedback implemented after the change in surveillance frequency is implemented. The process requires consideration of qualitative sources of information with regards to potential impacts of test frequency on SSC performance, including industry and plant-specific operating experience, vendor recommendations, industry standards, and code-specified test intervals. Thus the process is not reliant upon risk analyses as the sole basis for the proposed changes.

The potential beneficial risk impacts of reduced surveillance frequency, including reduced downtime, lesser potential for restoration errors, reduction of potential for test caused transients,

- 10 and reduced test-caused wear of equipment, are identified qualitatively, but are conservatively not required to be quantitatively assessed. Thus, through the application of NEI 04-10, the licensee has employed reasonable assumptions with regard to extensions of surveillance test intervals, and is consistent with regulatory position 2.3.4 of RG 1.177.

3.1.4.5 Sensitivity and Uncertainty Analyses In NEI 04-10 it requires sensitivity studies to assess the impact of uncertainties from key assumptions of the PRA, uncertainty in the failure probabilities of the affected SSCs, impact to the frequency of initiating events, and of any identified deviations from capability category II of ASME PRA Standard (ASME RA-Sb-2005) (Reference 4). Where the sensitivity analyses identify a potential impact on the proposed change, revised surveillance frequencies are considered, along with any qualitative considerations that may bear on the results of such sensitivity studies.

Required monitoring and feedback of SSC performance once the revised surveillance frequencies are implemented will also be performed. Thus, through the application of NEI 04-10, the licensee has appropriately considered the possible impact of PRA model uncertainty and sensitivity to key assumptions and model limitations, and is consistent with regulatory position 2.3.5 of RG 1.177.

3.1.4.6 Acceptance Guidelines The licensee will quantitatively evaluate the change in total risk (including internal and external events contributions) in terms of CDF and LERF for both the individual risk impact of a proposed change in surveillance frequency and the cumulative impact from all individual changes to surveillance frequencies using the guidance contained in NRC approved NEI 04-10 in accordance with the TS SFCP. Each individual change to surveillance frequency must show a risk impact below 1E--6 per year for change to CDF, and below -I E-7 per year for change to LERF.

These are consistent with the limits of RG 1.174 for very small changes in risk. Where the RG 1.174 limits are not met, the process either considers revised surveillance frequencies which are consistent with RG 1.174 or the process terminates without permitting the proposed changes.

Where quantitative results are unavailable to permit comparison to acceptance guidelines, appropriate qualitative analyses are required to demonstrate that the associated risk impact of a proposed change to surveillance frequency is negligible or zero. Otherwise, bounding quantitative analyses are required which demonstrate the risk impact is at least one order of magnitude lower than the RG 1.174 acceptance guidelines for very small changes in risk. In addition to assessing each individual SSC surveillance frequency change, the cumulative impact of all changes must result in a risk impact below 1E-5 per year for change to CDF, and below 1E--6 per year for change to LERF, and the total CDF and total LERF must be reasonably shown to be less than 1E-4 per year and 1E-5 per year, respectively. These are consistent with the limits of RG 1.174 for acceptable changes in risk, as referenced by RG 1.177 for changes to surveillance frequencies.

The NRC staff interprets this assessment of cumulative risk as a requirement to calculate the change in risk from a baseline model utilizing failure probabilities based on the surveillance frequencies prior to implementation of the SFCP, compared to a revised model with failure probabilities based on changed surveillance frequencies. The staff further notes that the licensee includes a provision to exclude the contribution to cumulative risk from individual changes to surveillance frequencies associated with insignificant risk increases (less than 5E-8 CDF and 5E-9 LERF) once the baseline PRA models are updated to include the effects of the revised surveillance frequencies.

- 11 The quantitative acceptance guidance of RG 1.174 is supplemented by qualitative information to evaluate the proposed changes to surveillance frequencies, including industry and plant-specific operating experience, vendor recommendations, industry standards, the results of sensitivity studies, and SSC performance data and test history.

The final acceptability of the proposed change is based on all of these considerations and not solely on the PRA results compared to numerical acceptance guidelines. Post implementation performance monitoring and feedback are also required to assure continued reliability of the components. The licensee's application of NEI 04-10 provides reasonable acceptance guidelines and methods for evaluating the risk increase of proposed changes to surveillance frequencies, consistent with Regulatory Position 2.4 of RG 1.177. Therefore, the proposed licensee methodology satisfies the fourth key safety principle of RG 1.177 by assuring any increase in risk is small consistent with the intent of the Commission's Safety Goal Policy Statement.

3.1.5 Impact of the Proposed Change Should Be Monitored Using Performance Measurement Strategies The licensee's adoption of TSTF-425 requires application of NEI 04-10 in the SFCP.

NEI 04-10 requires performance monitoring of SSCs whose surveillance frequency has been revised as part of a feedback process to assure that the change in test frequency has not resulted in degradation of equipment performance and operational safety. The monitoring and feedback includes consideration of maintenance rule monitoring of equipment performance. In the event of degradation of SSC performance, the surveillance frequency will be reassessed in accordance with the methodology, in addition to any corrective actions which may apply as part of the maintenance rule requirements. The performance monitoring and feedback specified in NEI 04-10 is sufficient to reasonably assure acceptable SSC performance and is consistent with Regulatory Position 3.2 of RG 1.177. Thus, the fifth key safety principle of RG 1.177 is satisfied.

3.2 Addition of Surveillance Frequency Control Program to Administrative Controls The licensee has included the SFCP and specific requirements into the Administrative Controls, TS Section 5.5.21, Surveillance Frequency Control Program, as follows:

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 that the associated Limiting Conditions for Operation are met.

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

b. Changes to the Frequencies 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.

The proposed program is consistent with the model application of TSTF-425, and is therefore acceptable.

- 12 3.3 Summary and Conclusions The NRC staff has reviewed the licensee's proposed relocation of some surveillance frequencies to a licensee controlled document, and controlling changes to surveillance frequencies in accordance with a new program, the SFCP, identified in the administrative controls of TS. The SFCP and TS Section 5.5.21 references NEI 04-10, which provides a risk-informed methodology using plant-specific risk insights and performance data to revise surveillance frequencies within the SFCP. This methodology supports relocating surveillance frequencies from TS to a licensee-controlled document, provided those frequencies are changed in accordance with NEI 04-10 which is specified in the Administrative Controls of the TS.

The proposed licensee adoption of TSTF-425 and risk-informed methodology of NEI 04-10 as referenced in the Administrative Controls of TS, satisfies the key principles of risk-informed decision making applied to changes to TS as delineated in RG 1.177 and RG 1.174, in that:

The proposed change meets current regulations;

The proposed change is consistent with defense-in-depth philosophy;

The proposed change maintains sufficient safety margins;

Increases in risk resulting from the proposed change are small and consistent with the Commission's Safety Goal Policy Statement; and

The impact of the proposed change is monitored with performance measurement strategies.

In 10 CFR 50.36(c) (3) it states "Technical specifications will include items in the following categories: Surveillance Requirements. Surveillance Requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." The NRC staff finds that with the proposed relocation of surveillance frequencies to an owner-controlled document and administratively controlled in accordance with the TS SFCP, the licensee continues to meet the regulatory requirement of 10 CFR 50.36, and specifically, 10 CFR 50.36(c)(3), surveillance requirements.

The NRC has concluded, on the basis of the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the NRC's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Georgia State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 or surveillance requirements. The NRC staff has determined that the amendment involves no significant increase

- 13 in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The NRC has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published August 24,2010 (75 FR 52042). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not beendangered by operation in the proposed manner, (2) such activities will be conducted incompliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1. TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control-RITSTF Initiative 5b," March 18, 2009 (ADAMS Accession Number: ML090850642).

2. NEI 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative 5B, Risk-Informed Method for Control of Surveillance Frequencies," April 2007 (ADAMS Accession Number: ML071360456).

3. Regulatory Guide 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking:

Technical Specifications," August 1998 (ADAMS Accession Number: ML003740176).

4. Regulatory Guide 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," Revision 1, January 2007 (ADAMS Accession Number: ML070240001).

5. Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant- Specific Changes to the Licensing Basis," NRC, Revision 1, November 2002 (ADAMS Accession Number: ML023240437).

6. ASME PRA Standard ASME RA-Sb-2005, "Addenda to ASME RA-S-2002, "Standard for Probabilistic Risk Assessment for Nuclear Power Plant Application."

7. NEI 00-02, Revision 1 "Probabilistic Risk Assessment (PRA) Peer Review Process Guidance, Revision 1, May 2006 (ADAMS Accession Number: ML061510621).

8. NEI 05-04, "Process for Performing Follow-On PRA Peer Reviews Using the ASME PRA Standard", Revision 0, August 2006.

- 14

9. M. J. Ajluni to U. S. NRC, "License Amendment Request for Adoption of TSTF-425-A, Rev. 3, Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program Using the Consolidated Line Item Improvement Process," June 15,2010. (ML101690441).

10M. J. Ajluni to U.S. NRC, January 7, 2011 (ML110070455).

Principal Contributor: A. Howe Date: January 19, 2011

.. ML102520083 *memo transmitted SE dated NRR/APLAlBC OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA OGC DIRSIITSB/BC NRRlLPL2-1/BC NAME RMartin SRohrer BHarris REllliott GKulesa DHarrison (VSreenivas) 08/03/2010 DATE 01/11 /11 09/13/10 10/19/10 12/03/10 01/19/11

v t e Letter Sequence Approval
TAC:ME4091, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B (Approved, Closed) TAC:ME4092, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B (Approved, Closed)
Initiation Request, Request Acceptance Administration Questions Answers Results Approval Other:
MONTHYEAR2010-07-19 [Table View]

ML102520083

Text

SUBJECT:

Dear Mr. Ajluni:

Enclosures:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

7.0 REFERENCES

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