Text

Response to Request for Additional Information on License Amendment Request to Permit the Use of Risk Informed Completion Times
	ML16109A338
Person / Time
Site:	Vogtle
Issue date:	04/18/2016
From:	Pierce C; Southern Co, Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-16-0307
	Download: ML16109A338 (25)
	v • d • e

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

40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7872 Fax 205 992.7601 SOUTHERN * \

NUCLEAR A SOUTHER N COMPAN Y Docket Nos.: 50-424 NL-16-0307 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant Response to Request for Additional Information on License Amendment Reques t

to Permit the use of Risk Informed Completion Times Ladies and Gentlemen:

By letter dated September 13, 2012, Southern Nuclear Operating Company (SNC) submitted a license amendment request to permit the use of Risk Informe d

Technical Specification (TS) Completion Times in accordance with Nuclear Energy Institute (NEI) Report 06-09, Revision 0, Risk Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS)

Guidelines, at the Vogtle Electric Generating Station. The SNC submittal was supplemented by letters dated August 2, 2013, July 17, 2014, November 11, 2014, December 12, 2014, March 16, 2015, and May 5, 2015. By letter dated December 17, 2015, the Nuclear Regulatory Commission (NRC) issued a request for additional information (RAI) regarding the SNC TS amendment request.

By letter dated February 17, 2016, SNC provided a partial response to NRC's December 17,2015 RAI questions. SNC's letter answered questions #1 and #2, leaving the response to question #3 for a future date. Accordingly, the response to question #3 is provided in Enclosure 1 to this letter. Changes from the previous marked-up Technical Specifications resulted from the response.

Accordingly, Enclosures 2 and 3 provide the marked-up and the clean typed pages, respectively, to the revised LCO section, 3.8.1.

Additionally, on March 23, 2016, a teleconference was held between SNC and NRC staff to provide clarification, to NRC, on some of SNC's February 17 responses to the NRC's RAI of December 17,2015 . Accordingly, Enclosure 1 contains SNC's responses to the NRC's questions, which were provided to SNC prior to the call via electronic correspondence. The NRC's questions precede the SNC responses.

Finally, an oversight was recently discovered in the mark-up of LCO 3.7.14, "Engineered Safety Features (ESF) Room Cooler and Safety Related Chiller System", for the Risk Informed Completion Time Program. A Loss of Function

U.S. Nuclear Regulatory Commission NL-16-0307 Page2 Condition should have been applied to this LCO but was not. Consequently, a mark-up and clean typed page is also included for this LCO.

This letter contains no NRC commitments.

If you have any questions, please contact Ken McElroy at (205) 992-7369.

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

Respectfully submitted, c.tl~

I 1 C. R. Pierce J Regulatory Affairs Director 1

CRP/OC V I I J, '

i~ed before me this J~ ~ day of AP et L- '2016.

- ---1-------""""'~~ ) - -

Notary Public My commission expires: jo, 1 ~ 0 11

Enclosures:

1) Responses to Request for Additional Information

2) Marked up Technical Specifications Pages

3) Clean Typed Technical Specifications Pages cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. D. R. Madison, Vice Preside nt- Fleet Operations Mr. M. D. Meier, Vice Preside nt- Regulatory Affairs Mr. B. K. Taber, Vice Preside nt- Vogtle 1 & 2 Mr. B. J. Adams, Vice Preside nt- Engineering Mr. G. W. Gunn, Regulatory Affairs Manag er- Vogtle 1 & 2 RType: CVC7000 U. S. Nuclear Regulatory Commission Ms. C. Haney, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manag er- Vogtle 1 & 2 Mr. W. D. Deschaine, Senior Resident Inspect or- Vogtle 1 & 2 Mr. A.M. Alen, Resident Inspect or- Vogtle 1 & 2 State of Georgia Mr. J. H. Turner, Director- Environmental Protection Division

Vogtle Electric Generating Plant Response to Request for Additional Information on License Amendment Reques t

to Permit the use of Risk Informed Completion Times Enclosure 1 Responses to Request for Additional Information

Enclosure 1 to NL-16-0307 Response to Request for Additional Information Request for Additional Information Regarding Emergency Diesel Completion Times The Current Vogtle Technical Specification 3.8.1 contains the following requirements:

Vogtle TS Limiting Condition for Operation 3.8.1 specifies operability requirements for AC electrical sources. With one Diesel Generator (DG) inoperable, Condition 8 is applicable. Condition 8 requires, in part:

Verify the Standby Auxiliary Transformer (SAT) is operable within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter (Required Action 8.2); and, either

Verify an enhanced black-start Combustion Turbine Generator (CTG) is functional by verifying the CTG and the black-start diesel generator starts and achieves steady state voltage and frequency within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months prior to entry into Condition 8 (Required Action 8.5.1)

-OR-

Start and run at least one CTG while in Condition 8 within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months prior to entry into Condition 8 for preplanned maintenance (Required Action 8.5.2).

Additionally Condition 8 requires:

Restore DG to operable status within 14 days from discovery of failure to meet LCO (Required Action 8.6).

LCO 3.8.1 Condition C applies when Required Actions 8.2, 8.5.1 or 8.5.2 and associated Completion Times are not met. Required Action C.1 requires:

Restore DG to Operable Status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

If Required Action C.1 and its Completion Time are not met, the unit must be placed in Mode 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in Mode 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

Request for Additional Information:

The LAR proposes to add the option of either applying the existing front stop Completion Time or applying a Risk Informed Completion Time for Required Action C.1. The proposed change to the Completion Time for Required Action C.1 could permit operation for an extended period of time with one DG inoperable without verifying the availability of SAT or of the CTG. Please provide technical justification, including a discussion of defense-in-depth and safety margin considerations, for the addition of a risk-informed completion time for the Required Actions associated with LCO 3.8.1 Condition C, or propose a modification to the license amendment request that retains the existing CTs for verifying availability of SAT and functionality of a CTG.

E1-1

Enclosure 1 to NL-16-0307 Response to Request for Additional Information SNC Response SNC has modified the license amendment request (LAR) to eliminate the current risk-informed Condition 8 and to apply a Risk-Informed Completion Time only to the Condition with the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months front stop (current VEGP LCO 3.8.1, Condition C).

The new Condition 8 in the VEGP mark-up, Enclosure 2, matches Condition 8 in the NUREG-1431 mark-up for TSTF-505.

Enclosure 2 provides the marked-up Technical Specifications pages, including the change discussed above. For continuity, the entire RICT program mark-up is provided for LCO 3.8.1. Enclosure 3 provides the clean typed Technical Specifications pages; again for continuity, all RICT Program revised pages to date are included for LCO 3.8.1.

NRC Questions and SNC Responses from March 23, 2016 Teleconference NRC Question The response to RAI 1.b.ii states, The PRA Functional room cooling function is accomplished by opening doors instead of the room cooling system SSCs.

How is this consistent with the 1a response that, "SSCs credited in the PRA Functionality determination are the same SSCs relied on to perform the specified safety function ..."?

Is SNC specifically requesting NRC approval of alternate SSCs for use in establishing PRA functionality in this example? If so, are there any other similar instances in this LAR?

SNC Response Yes, SNC is specifically asking for approval for the use of manual action for opening ESF room doors for a TS Loss of Function (LOF) Condition inoperability related to "Engineered Safety Features (ESF) Room Cooler and Safety Related Chiller System".

There are no similar instances in the LAR.

NRC Question Concerning the SNC response to RAI 2.a, The RAI requested, "Please confirm that the acceptable PRA Functional modelled in the PRA is also available and sufficient... "

The response states that SSCs will remain "available" but does not appear to address "sufficient." Was this an oversight or has sufficient capability to accomplish design basis functions not in the PRA not been evaluated or assured?

E1-2

Enclosure 1 to NL-16-0307 Response to Request for Additional Information SNC Response Not addressing "sufficient" was an oversight.

The PRA Functionality evaluation performed following a TS LOF Condition will ensure that SSCs not supporting CDF/LERF will remain available, and will sufficiently perform their safety function with respect to the credited design basis scenario.

NRC Question The SNC Response to RAI 2.c states in part, For design basis initiators modeled in the internal events PRA, PRA Functionality determination performed subsequent to a TS LOF Condition entry will ensure design basis success criteria for parameters (e.g., flow rates, temperature limits) are met.

Are the "design basis success criteria for parameters" identical to "the existing PRA success criteria"? If not, does this response to RAI 2.c supersede the August 2, 2013, SNC Response to NRC Question #4 quoted below?

Nevertheless, SNC will voluntarily include a summary of the Risk Informed Completion Time (RICT) program in Chapter 16 of the FSAR, 'Technical Specifications". This will include a section on PRA Functionality which will list those conditions which must be satisfied before declaring a component as "PRA Functional" per the NEI 06-09 Guidelines. The section will explicitly state that for a TS component to be considered PRA Functional, its PRA success criteria, among other things, must be satisfied. For example, EGGS flow rates satisfying the PRA criteria are determined by the existing PRA success criteria for that system. Therefore, should an EGGS become inoperable due to failing to meet its required TS SR Flow rate, its Functionality status would depend on whether or not the actual measured flow rate met the PRA success criteria.

SNC Response The response to RAI2.c provided in the February 17, 2016letter is valid for a TS LOF Condition inoperabilites. The response from the August 2, 2013 letter remains valid for non-LOF Condition inoperabilites.

Additional SNC Discovery Regarding LCO 3.7.14 An oversight was recently discovered in the mark-up of LCO 3. 7 .14, "Engineered Safety Features (ESF) Room Cooler and Safety Related Chiller System", for the Risk Informed Completion Time Program. A Loss of Function (LOF) Condition should have been applied to this LCO but was not. Accordingly, Technical Specifications pages are included in this letter that add the LOF Condition. This LOF Condition (new Condition B) is consistent with proposed EXAMPLE 1.3-8 Condition B from the September 13, 2012 submittal and is consistent with other LOF Conditions added by the LAR.

E1-3

Vogtle Electric Generating Plant Response to Request for Additional Information on License Amendment Request to Permit the use of Risk Informed Completion Times Enclosure 2 Marked-up Technical Specifications Pages

ESF Room Cooler and Safety-Related Chiller System 3.7.14 3.7 PLANT SYSTEMS 3.7.14 Engineered Safety Features (ESF) Room Cooler and Safety Related Chiller System LCO 3.7.14 Two ESF Room Cooler and Safety-Related Chiller trains shall be OPERABLE.

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

One Safety-Related Chiller train may be removed from service for

~ 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months under administrative controls for surveillance testing of the other Safety-Related Chiller train.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One ESF room cooler A.1 Restore the ESF room 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s*

and safety-related chiller train inoperable.

cooler and safety-related ,..___-1-' ~nsert 21 chiller train to OPERABLE Insert 1 status.

Required Action and 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.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months

For the VEGP Unit 2 August 16, 2010 entry into Technical Specifications 3.7.14 Condition A, one ESF room cooler and safety-related chiller train may be inoperable for a period not to exceed 14 days.

Vogtle Units 1 and 2 3.7.14-1

AC Sources - Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A (continued) A.2 Declare required feature(s) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from with no offsite power discovery of no offsite available inoperable when power to one train its redundant required concurrent with feature(s) is inoperable. inoperability of redundant required feature(s)

AND A.3 Restore required offsite 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months circuit to OPERABLE /

status. /

(continued)

, --ln-s-ert-2--.,/

r--

Vogtle Units 1 and 2 3.8.1-2

AC Sources - Operating 3.8.1 CONDITION REQUIRED ACTION COMPLETION TIME B. One DG inoperable. B.1 Perform SR 3.8.1.1 for the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months required offsite circuit(s).

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter ANQ 8.2 Verify SAT available.

OnGe per 12 he1:1rs thereafter Declare required feature(s) 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from supported by the discovery of inoperable DG inoperable Condition B when its required concurrent with redundant feature(s) is inoperability of inoperable.

redundant required feature(s)

Determine OPERABLE DG is not inoperable due to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months common cause failure.

OR

.2 Perform SR 3.8.1.2 for OPERABLE DG. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (continued)

Vogtle Units 1 and 2 3.8.1-3

AC Sources - Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME lB. (eontin~eel)l u+ lio...,.<:>JI

,I l72 ho~rij

,...,..; ,;.. +h.... rr lhl ... ,. _... , ...,. .... . .... n

..-~ ; ...,

,~ ...~.

~

,,. ......... ,. ~

I OR!

ls.s.2 tt.tS Whf,:ln @Jnauf:9'.~ l72 ho~rij l2BI (continued)

Vogtle Units 1 and 2 3.8.1-4

AC Sources - Operating 3.8.1 Insert 2 ACTIONS CONDITION REQUIRED ACTION B. (continued) Restore DG to OPERABLE 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months status.

~* Req~;~i ree Actions B.2, C.1 Restore DG to OPERABLE 72 t:lo~;~rs B.a.1, or B.5.2 ana stat~;~s .

associates Completion Times not met.

.1 Declare required feature(s) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months fro inoperable when its discovery o redundant feature(s) is Condition inoperable. concurrent with inoperability of redundant required features Restore one required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months offsite circuit to OPERABLE status One required offsite ----------------NOT E---------- -------

circuit inoperable. Enter applicable Conditions and Insert 2 Required Actions of LCO 3.8.9, "Distribution Systems - Operating ,"

when Condition is entered with no One DG inoperable. AC power sourc to one or more trains.

continued )

Vogtle Units 1 and 2 3.8.1-5

AC Sources - Operating 3.8.1 CONDITION REQUIRED ACTION COMPLETION TIME (continued) Restore required offsite 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months circuit to OPERABLE status.

Insert 2a .2 Restore DG to OPERABLE status .

.1 Restore one DG to OPERABLE status.

I. Three or FRere req~:~ireel +:-1.+1---te=tR=Hte~erHb~C~O::J-.da'*

. G*"".a~. lr:}:lFReeliately AC so~:~rses iROJ')erable.

Vogtle Units 1 and 2 3.8.1-6

INSERT 1

--NO TE--- --------

Not applicable when two ESF room cooler and safety-related trains intentionally made inoperable.

B Two ESF room cooler 8 .1 Restore one ESF 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and safety-related room cooler and chiller trains safety-related chiller inoperable train to OPERABLE status In accordance with the Risk Informed Completion Time Program

Insert 2 OR In accordance with the Risk Informed Completion Time Program

Insert 2a

~C>lrE:--------------------------------------------------

~ot applicable when second DG intentionally made inoperable

Insert 9 G. ---NOT E---- G.1 Restore required 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Not applicable when inoperable AC sources to three or more required OPERABLE AC sources status.

intentionally made In accordance with inoperable. the Risk Informed Completion Time Program Three or more required AC sources inoperable.

Vogtle Electric Generating Plant Response to Request for Additional Information on License Amendment Request to Permit the use of Risk Informed Completion Times Enclosure 3 Clean Typed Technical Specifications Pages

ESF Room Cooler and Safety-Related Chiller System 3.7.14 3.7 PLANT SYSTEMS 3.7.14 Engineered Safety Features (ESF) Room Cooler and Safety Related Chiller System LCO 3.7.14 Two ESF Room Cooler and Safety-Related Chiller trains shall be OPERABLE.

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

One Safety-Related Chiller train may be removed from service for

~ 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months under administrative controls for surveillance testing of the other Safety-Related Chiller train.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One ESF room cooler A.1 Restore the ESF room 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s*

and safety-related chiller cooler and safety-related train inoperable. chiller train to OPERABLE status. OR In accordance with the Risk Informed Completion Time Program

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

Not applicable when two ESF room cooler and safety-related trains intentionally made inoperable.

B. Two ESF room cooler B.1 Restore one ESF room 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and safety-related chiller cooler and safety-related trains inoperable. chiller train to OPERABLE status. OR In accordance with the Risk Informed Completion Time Program

For the VEGP Unit 2 August 16, 2010 entry into Technical Specifications 3.7.14 Condition A, one ESF room cooler and safety-related chiller train may be inoperable for a period not to exceed 14 days.

Vogtle Units 1 and 2 3.7.14-1 Amendment No. (Unit 1)

Amendment No. (Unit 2)

ESF Room Cooler and Safety-Related Chiller System 3.7.14 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 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 3.7.14.1 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 Amend ment No. (Unit 1)

Amend ment No. (Unit 2)

AC Sources - Operating 3.8.1 ACTION S CONDITION REQUIR ED ACTION COMPL ETION TIME A (continued) A.2 Declare required feature(s) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from with no offsite power discover y of no offsite available inoperable when power to one train its redundant required concurre nt with feature(s) is inoperable. inoperability of redunda nt required feature(s)

AND A.3 Restore required offsite 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months circuit to OPERA BLE status.

In accorda nce with the Risk Informed Completion Time Program (continued)

Vogtle Units 1 and 2 3.8.1-2 Amendm ent No. (Unit 1)

Amendm ent No. (Unit 2)

AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One DG inoperable. 8.1 Perform SR 3.8.1.1 for the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months required offsite circuit(s).

AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND 8.2 Declare required feature(s) 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from supported by the discovery of inoperable DG inoperable Condition B when its required concurrent with redundant feature(s) is inoperability of inoperable. redundant required feature(s)

AND B.3.1 Determine OPERABLE DG 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is not inoperable due to common cause failure.

OR B.3.2 Perform SR 3.8.1.2 for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE DG.

AND (continued)

Vogtle Units 1 and 2 3.8.1-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

AC Sources - Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.4 Restore DG to OPERABLE 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months status.

OR In accordance with the Risk Informed Completion Time Program C. Two required offsite c. 1 Declare required feature(s) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from circuits inoperable. inoperable when its discovery of redundant feature(s) is Condition C inoperable. concurrent with inoperability of redundant required AND features C.2 Restore one required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months offsite circuit to OPERABLE status OR In accordance with the Risk Informed Completion Time Program D. One required offsite --------------------N 0 TE -------------------

circuit inoperable. Enter applicable Condition? and Required Actions of LCO 3.8.9, AND "Distribution Systems- Operating,"

when Condition D is entered with no One DG inoperable. AC power source to one or more trains.

(continued)

Vogtle Units 1 and 2 3.8.1-4 Amendment No. (Unit 1)

Amendment No. (Unit 2)

AC Sources - Operating 3.8.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. (continued) D.1 Restore required offsite 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months circuit to OPERABLE status. OR OR In accordance with the Risk Informed Completion Time Program 0 .2 Restore DG to OPERABLE 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months status.

OR In accordance with the Risk Informed Completion Time Program

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

Not applicable when second DG intentionally made inoperable.

E. Two DGs inoperable. E.1 Restore one DG to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OPERABLE status.

OR In accordance with the Risk Informed Completion Time Program F. One automatic load F.1 Restore automatic load 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months sequencer inoperable. sequencer to OPERABLE status. OR In accordance with the Risk Informed Completion Time Program (continued)

Vogtle Units 1 and 2 3.8.1-5 Amendment No. (Unit 1)

Amendment No. (Unit 2)

AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME G. --------NOTE----------- G. 1 Restore required 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Not applicable when inoperable AC sources to three or more required OPERABLE status. OR AC sources intentionally made In accordance with inoperable. the Risk Informed

Completion Time Three or more required Program AC sources inoperable.

H. Required Action and H.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, B, AND C, D, E, F, or G not m~t. H.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Vogtle Units 1 and 2 3.8.1-6 Amendment No. (Unit 1)